Newsletter 45 | Spillemyndigheden

29 May 2020

Annual account 2019

All betting and/or online casino licence holders that have held a licence in the entire period between 1 January 2019 and 31 December 2019 must submit an annual account.

The annual account for 2019 must again this year be completed and submitted via a questionnaire. The questionnaire must be completed in one session. Therefore, we recommend that you have ready all relevant information listed below before you begin the questionnaire. Before you can complete the questionnaire, you will receive a link with a corresponding code from your legal contact person at the Danish Gambling Authority.

Licence holders, for whom 2019 was the first year of providing gambling products, are not required to submit an annual account. Instead, a report on the first year of providing gambling products must be submitted no later than 14 months after the licence has been used for the first time.

A renewal of a licence is considered a new licence. This means that all terms and conditions that apply to the first year of providing gambling products must be fulfilled again, including the requirement of a report one year after the licence has been used for the first time, cf. section 43(1) of the Act on Gambling.

The annual account must be in the Danish Gambling Authority’s possession no later than 30 June 2020.

What must be included in the annual account?

The annual account must include: the company’s key financial data and an account of how the licence holder has complied with the requirements of the law. The account should only concern the offering of gambling services and products in the Danish market in 2019 unless otherwise stated below.

If you hold a licence to provide gambling products in Greenland, the annual account must also cover the provision of gambling products in this area.

Questions in the annual account 2019

Information about the licence holder:

Licence holder        _________________
Contant person for the annual account    _________________
E-mail address of contact person    _________________
Telephone number of contact person    _________________

Do you have a licence to provide online casino?

□ Yes
□ No

Do you have a licence to provide betting?

□ Yes
□ No

Do you offer gambling services and products in Greenland?

□ Yes
□ No

1. Statistics – Online casino

1.1. State the number of registered players who have created an account in 2019 according to age and sex:

Men:
18-25 years       _________________
26-35 years       _________________
36-45 years       _________________
46-55 years       _________________
56-65 years       _________________
66-75 years       _________________
76 + years       _________________

Women:
18-25 years        _________________
26-35 years       _________________
36-45 years       _________________
46-55 years       _________________
56-65 years        _________________
66-75 years        _________________
76 + years       _________________

1.2. State the total number of registered players according to age and sex:

Women:
18-25 years        _________________
26-35 years       _________________
36-45 years       _________________
46-55 years       _________________
56-65 years       _________________
66-75 years       _________________
76 + years       _________________

2. Statistics – Betting

2.1. State the number of registered players who have created an account in 2019 according to age and sex:

State the total number of registered players according to age and sex:

Women:
18-25 years        _________________
26-35 years       _________________
36-45 years       _________________
46-55 years       _________________
56-65 years       _________________
66-75 years       _________________
76 + years       _________________

3. Statistics – Greenland

3.1. State the number of registered players in Greenland who have created an account in 2019 according to age and sex:

1.2. State the total number of registered players in Greenland according to age and sex:

Women:
18-25 years        _________________
26-35 years       _________________
36-45 years       _________________
46-55 years       _________________
56-65 years       _________________
66-75 years       _________________
76 + years       _________________

4. Key financial data – Online casino

4.1. Key financial data - Revenue

All amount of money must be stated in Danish kroner (DKK).

Deposits            _________________
Stakes            _________________
Winnings            _________________
Commission            _________________
Gross gaming revenue (GGR)    _________________
Financial revenue        _________________
Other revenues        _________________

4.1.1. Key financial data - Revenue

Please, describe the other revenues.

4.2. Key financial data - Expenses

All amounts of money must be stated in Danish kroner (DKK).

Payouts           _________________
Gaming tax            _________________
Staff charges          _________________
Financial costs        _________________
Write-offs and depreciations        _________________
Additional costs (excluding bonus)    _________________
Taxes paid on net profits for the year   _________________
Net profit for the year        _________________

5. Key financial data – Betting

5.1. Key financial data - Revenue

All amount of money must be stated in Danish kroner (DKK).

5.1.1. Key financial data - Revenue

Please, describe the other revenues.

5.2. Key financial data - Expenses

All amounts of money must be stated in Danish kroner (DKK).

6. Marketing – Online casino

6.1. Marketing – Media

Enter marketing costs stated in Danish kroner (DKK) for the Danish market on the following media:

TV               _________________
Cinema                _________________
Printed media                _________________
Radio                _________________
Internet: Adwords            _________________
Internet: Banner advertisement on third party websites    _________________
Internet: Social media           _________________
Internet: Affiliates           _________________
Own website                _________________
E-mail                _________________
SMS                _________________
Other               _________________

6.1.1. Marketing – Affiliates

Which affiliates do you use?

6.1.2. Marketing – Other

State what is covered by “Other”

6.2. Marketing – TV channels

State how much is spent on TV-marketing on the following TV channels stated in Danish kroner (DKK).

TV 2                _________________
Discovery Networks Denmark (e.g. Kanal 4, 5, 6, 7 og 9)   _________________
Viasat (e.g. TV 3, 3+, 3 puls, 3 sport)       _________________
Other                _________________

6.2.1. Marketing – Other TV channels

Please state other TV channels.

6.3. Marketing – Social media

State how much is spent on social media marketing on the following social media stated in Danish kroner (DKK).

Youtube            _________________
Instagram            _________________
Facebook            _________________
Twitter            _________________
Influencer            _________________
Other social media       _________________

6.3.1 Marketing – Influencer

Which influencer(s) do you use?

6.3.2 Marketing – Other social media

Please state the other social media used.

7. Marketing – Betting

7.1. Marketing – Media

Enter marketing costs stated in Danish kroner (DKK) for the Danish market on the following media:

7.1.1. Marketing – Affiliates

Which affiliates do you use?

7.1.2. Marketing – Other

State what is covered by “Other”

7.2. Marketing – TV channels

State how much is spent on TV-marketing on the following TV channels stated in Danish kroner (DKK).

7.2.1. Marketing – Other TV channels

Please state other TV channels.

7.3. Marketing – Social media

State how much is spent on social media marketing on the following social media stated in Danish kroner (DKK).

7.3.1. Marketing – Influencer

Which influencer(s) do you use?

7.3.2. Marketing – Other social media

Please state the other social media used.

8. Bonus – Online casino

8.1 Bonus – Welcome bonus

State the allocation of welcome bonuses for new players in 2019 divided into number of bonuses and Danish kroner (DKK).

By “allocation of bonus” is meant the time when a player accepts a bonus but has not yet fulfilled the bonus terms and conditions.

DKK        Number of bonuses
Q1        _________________   _________________
Q2        _________________   _________________
Q3        _________________   _________________
Q4        _________________   _________________

8.2. Bonus – Welcome bonus

State the allocation of welcome bonuses for new players that have been realised in 2019 divided into quarters of the year by number of bonuses and Danish kroner (DKK).

By “realised number” is meant the number of bonuses, where players have fulfilled all bonus terms and conditions and thereby gain access to winnings derived from the bonus. By “realised amount of money” is meant the amount of money that players have gained access to by fulfilling the bonus terms and conditions.

8.3. Bonus – Existing customers

State the allocation of bonuses for existing players in 2019 divided into quarters of the year by number of bonuses and Danish kroner (DKK).

By “allocation of bonus” is meant the time when a player accepts a bonus but has not yet fulfilled the bonus terms and conditions.

8.4. Bonus – Existing customers

State the allocation of bonuses for existing players that have been realised in 2019 divided into quarters of the year by number of bonuses and Danish kroner (DKK).

8.5. Bonus – Free spins

State the total payout of winnings in 2019 where free spins have been awarded to players minus the stake. Please do this for each quarter of 2019 by number of payouts and the total amount in Danish kroner (DKK).

By “stake” is meant the amount of money deposited on the account to activate the bonus.

9. Bonus – Betting

9.1. Bonus – Welcome bonus

State the allocation of welcome bonuses for new players in 2019 divided into number of bonuses and Danish kroner (DKK).

By “allocation of bonus” is meant the time when a player accepts a bonus but has not yet fulfilled the bonus terms and conditions.

9.2. Bonus – Welcome bonus

State the allocation of welcome bonuses for new players that have been realised in 2019 divided into quarters of the year by number of bonuses and Danish kroner (DKK).

9.3. Bonus – Existing customers

State the allocation of welcome bonuses for existing players in 2019 divided into quarters of the year by number of bonuses and Danish kroner (DKK).

By “allocation of bonus” is meant the time when a player accepts a bonus but has not yet fulfilled the bonus terms and conditions.

9.4. Bonus – Existing customers

State the allocation of welcome bonuses for existing players that have been realised in 2019 divided into quarters of the year by number of bonuses and Danish kroner (DKK).

9.5. Bonus – Free bets

State the total payout of winnings in 2019 where free bets have been awarded to players minus the stake. Please do this for each quarter of 2019 by number of payouts and the total amount in Danish kroner (DKK).

By “stake” is meant the amount of money deposited on the account to activate the bonus.

9.6. Bonus – Risk free game

State the total amount of reimbursements in DKK in 2019, where you have reimbursed the players stake, when a bet is lost (risk-free game). Please state this for each quarter of the year by number of reimbursements and in Danish kroner (DKK).

DKK        Number
Q1        _________________   _________________
Q2        _________________   _________________
Q3        _________________   _________________
Q4        _________________   _________________

10. Limitation of player accounts

Do you limit accounts?

By “limitation” is meant placing limits on stakes from certain players or limiting the amount of money that certain players can win.

□ Yes
□ No

11. Complaints

A complaint is defined as a player’s disagreement with a licence holder’s handling of a case or the result hereof, or if the player has used the word “complaint” in the enquiry/request.

11.1 State the number of complaints received from players

_________________

11.2 Number of complaints received, in which the word “complain(t)” is used

_________________

11.3 State the average casework time of a complain

_________________

11.4 State the number of complaints, where the casework time has exceeded 14 days.

The casework time is calculated from the day, when the complaint is received to the day, when the complainant receives a final answer. _________________

12. Responsible gambling

12.1 Is it possible for persons under 18 to create and play via a temporary account?

□ Yes
□ No

12.1.1 If yes, how many persons under 18, have you found, have created and played via a temporary account?

Number _________________

12.2 How many players under 18, have you found, have played from another person’s account?

Number _________________

12.3. Deposit limit

Number of registered players who have set a deposit limit in each quarter of 2019:

Daily – Q1      _________________
Daily – Q2       _________________
Daily – Q3      _________________
Daily – Q4      _________________

Weekly – Q1      _________________
Weekly – Q2       _________________
Weekly – Q3      _________________
Weekly – Q4      _________________

Monthly – Q1      _________________
Monthly – Q2       _________________
Monthly – Q3      _________________
Monthly – Q4      _________________

12.4. Self-exclusion

Number of players who have chosen a cool-off period or temporary exclusion at the licence holder:

24 hours            _________________
30 days           _________________
More than 30 days       _________________
Permanent self-exclusion       _________________
Other           _________________

12.4.1. Self-exclusion – Other

State what is covered by “other”.

12.5. Have you taken any measures to ensure that you do not send marketing material to players who have self-excluded from gambling?

□ Yes
□ No

12.5.1. Elaborate on how it is ensured that marketing material is not sent to self-excluded players.

12.6 Have you taken any measures to ensure that land-based betting products are not sold to persons under 18?

□ Yes
□ No

12.6.1 State the measures applied.

12.7. Have you, in the period between 1 January 2019 and 31 December 2019, found that land-based betting products have been sold to persons under 18?

□ Yes
□ No

12.7.1 In how many cases have you found that land-based betting products have been sold to persons under 18?

Number _________________

12.7.2. Do you have a procedure in place in case that land-based betting products are sold to persons under 18?

□ Yes
□ No

12.7.3. Account for the contents of the procedure

13. Money laundering

You must answer the following questions for the use of the Danish Gambling Authority’s risk assessment of the businesses covered by the Anti-Money Laundering Act. The information is requested on the basis of section 65(2) of the Anti-Money Laundering Act.

13.1 Is the person responsible for anti-money laundering placed in another company than the licence holder?

□ Yes
□ No

13.2. Is the person responsible for anti-money laundering part of the licenced company or the board or management of the group?

□ Yes
□ No

13.3 Is the person responsible for anti-money laundering placed in the same company as the department that monitors money laundering activities?

□ Yes
□ No

13.4 Is the anti-money laundering department concerned with tasks other than anti-money laundering?

□ Yes
□ No

13.5 State the number of employees who conduct anti-money laundering supervision.

□ Ja
□ Nej

13.6 Do you use third party assistance to apply customer due diligence measures, cf. section 22 of the Anti-Money Laundering Act?

□ Yes
□ No

13.6.1 If yes, who?

13.7 Is there another company within the group who applies customer due diligence measures, cf. section 23 of the Anti-Money Laundering Act?

□ Yes
□ No

13.8 Have you, based on section 24 of the Anti-Money Laundering Act, outsourced tasks that you are obligated to carry out pursuant to the Anti-Money Laundering Act?

□ Yes
□ No

13.8.1. If yes, to whom?

13.8.2 State which tasks you have outsourced.

13.9 Do you allow a player to create a temporary account, cf. section 6 of the Executive Order on online betting and the Executive Order on online casino?

□ Yes
□ No

13.10 Please, tick the payment options you offer in connection with payment of deposits for online gambling.

□ Credit card
□ Betalingsoverførsler
□ Prepaid credit cards

13.10.1 If others, state the options.

13.11 Please, tick the payment options you offer in connection with withdrawals from online gambling.

□ Credit cards
□ Betalingsoverførsler
□ Prepaid credit cards
□ NemKonto

13.11.1 If others, state the options.

13.12 Please, tick the payment options you offer in connection with payment of deposits for land-based gambling.

□ Credit cards
□ Betalingsoverførsler
□ Vouchers
□ Prepaid credit cards
□ Cash

13.12.1 If others, state the options.

13.13 Please, tick the payment options you offer in connection with withdrawals from land-based gambling.

□ Credit cards
□ Betalingsoverførsler
□ Vouchers
□ Prepaid credit cards
□ Cash
□ ”Spilkort” (Gambling cards) with transfer to bank account

13.13.1. If others, state the options.

13.14 State the number of customer relations in 2019 that you hae categorized as hifh-risk customers.

Number: ________________

13.15 State the total amount of money in cash received in 2019 (in thousands DKK).

Amount of cash: ________________

13.16 State the number of X in 2019 connected to a politically exposed person, a family member of a politically exposed person or a close associate of a politically exposed person.

Number: ________________

13.17 State the number of successful deposits and withdrawals in 2019.

Number: ________________

13.18 State the number of notifications sent to the Anti-Money Laundering Secretariat in 2019.

Number: ________________

13.19 State the number of players in 2019, who are connected to previous notification to the Anti-Money Laundering Secretariat.

Number: ________________

13.20 State the number of business relations that have been closed in 2019 based on a suspecion of money laundering or financing of terrorism.

Number: ________________

13.21 State the number and reason(s) if your group has been subject of anti-money laundering sanctions in other jurisdictions in 2019.

Number of orders issued to the group:       ________________
Reason(s) for orders issued to the group:       ________________
Number of actions brought against the group:   ________________
Reason(s) for actions brought against the group:   ________________
Number of court rulings against the group:        ________________
Reason(s) for court rulings against the group:       ________________
State, if other sanctions:           ________________

13.22 State the total number of administrative decisions received by the group in 2019.

Number of administrative decisions in the group: ________________

14. Money Laundering – Greenland

Questions 14.1 and 14.2 cover the compliance with the decree on the entry into force of the Act on preventive measures against money laundering and financing of terrorism (the Anti-Money Laundering Act) for Greenland. The questions are asked based on section 65(2) of the decree.

14.1 Section 7 of the decree on the entry into force of the Act on preventive measures against money laundering and financing of terrorism states that you must have a in place a risk assessment for your provision of gambling services and products in Greenland.

State if and how your risk assessment differs from your risk assessment for provision of gambling services and products in Denmark cf. section 7 of the Anti-Money Laundering Act.

14.2 Section 26 of the decree on the entry into force of the Act on preventive measures against money laundering and financing of terrorism states that you must report to the Anti-Money Laundering Secretariat of transactions or enquiries that raise suspicion that the transaction or enquiry has been or is connected to money laundering or financing of terrorism.

State how the reports are divided between the two categories:
STR (Suspicious transaction report) ________________
SAR (Suspicious activity report) ________________

14.2.1 State the number of your reports from Greenland during the period covered by the account and divide them between the following categories:

STR: Suspicious Transaction Report: ________________
SAR: Suspicious Activity Report: ________________

15. Match-fixing

You must answer questions about your use of alarm systems to combat match-fixing. In this context, an alarm system is defined as a system that is based on reports from a network of members. If you are not connected to an alarm system, you must only answer the question under item 15.1.7

15.1. Are you connected to an external alarm system?

□ Yes
□ No

15.1.1 What is the name of the alarm system to which you are connected?

Name: ________________

15.1.2 How many cases have you reported to the alarm system?

Number: ________________

15.1.3 How many alarms have you reported to the alarm system before the beginning of the event, during the event and after the event?

Before   ________________
During   ________________
After   ________________

15.1.4 How many of the alarms you receive from the alarm system do you receive before the beginning of the event, during the event and after the event?

Before   ________________
During   ________________
After   ________________

15.1.5 Describe your procedures for dealing with alarms to and from the alarm system.

15.1.6 How many alarms have caused you to suspend an event?

Number: ________________

15.1.7. State how many suspension of events you have made based on a suspicion of match-fixing.

Number: ________________

15.2 The purpose of this section is to clarify to which extent you make use of suspension and closure of accounts as a tool to combat match-fixing.

15.2.1. How many accounts have you closed based on a suspicion of match-fixing?

Number: ________________

15.2.2 How many accounts have you suspended based on a suspicion of match-fixing?

Number: ________________

15.2.3 Describe the most common reasons for closure or suspension of accounts in connection with a suspicion of match-fixing.

15.2.4 How many payouts have you suspended based on an investigation of match-fixing?

Number of suspended payouts ________________

15.2.5 How many payouts have you confiscated based on an investigation of match-fixing?

Number of confiscated payouts ________________

15.2.6 If you have suspended payouts based on investigations of match-fixing, how long time have the suspensions lasted?

15.3 Guide to items 15.3-15.8 Match-fixing – In this section you must state whether the below measures are included in your measures to reduce the risk of match-fixing.

15.3.1. Do you have a written risk assessment that accounts for the risks of your company being abused for the purposes of match-fixing?

□ Yes
□ No

15.3.1.1 Describe the 3 greatest risks of your company being abused for the purposes of match-fixing.

1. Risk    ________________
2. Risk    ________________
3. Risk    ________________

15.4. Do you have a general policy on how tasks related to match-fixing must be conducted? Har I en overordnet politik om, hvordan opgaver relateret til matchfixing skal bekæmpes.

□ Yes
□ No

15.5. Do you have operational written procedures to combat match-fixing?

□ Yes
□ No

15.5.1 Describe how you ensure control of company compliance with operational procedures.

15.6. Do you have a proces to ensure that relevant staff is trained in reducing the risk of match-fixing?

□ Yes
□ No

15.6.1 Who manages the training of relevant staff in reducing the risk of match-fixing?

15.6.2 Do you control that the training takes place?

□ Yes
□ No

15.7. Do you investigate whether a customer gambles on events that the customer has an influence on affecting?

15.7.1. Describe when you typically would start an investigation of whether a customer has an influence on affecting an event.

15.8. Are there types of bets or events that you choose not to offer bets on, because you assess that the risk of being abused for purposes of match-fixing is too great?

□ Yes
□ No

15.8.1 State five examples of types of bets or events that you choose not to offer bets on, because you assess that the risk of being abused for purposes of match-fixing is too great.

1. Example    ________________
2. Example   ________________
3. Example   ________________
4. Example   ________________
5. Example   ________________

16. Set-off free account

16.1 State the average deposits on the 1 percent of accounts with the largest amount of money on the 31st of December 2019.

State amount ________________

16.2 State the deposits on the set-off free account on the 31st of December 2019.

State amount ________________

17. Inactive accounts

17.1 State the number of inactive accounts on the 31st of December 2019.

By an “inactive account” is meant an account that has not been used within the reference period from 1 January 2019 to 31 December 2019.

Number of inactive accounts ________________

17.1.1 Deposits on the total number of inactive accounts on the 31st of December.

Amount of money ________________

18. Account on how you have complied with the requirements of the law.

The account must as a minimum address:
A management report including information about the company’s main activities and developments hereof, as well as a description of significant factors that have or are expected to impact the company. If the company is part of a group, it must be described which uncertainty factors that fall on the company and the group respectively. In addition, it must inform of the main events, such as campaigns, changes to the provision of gambling products or gambling platforms, as well as other significant initiatives etc. Moreover, it must also include an account of the expectations for the coming year.

19. Contact persons

State the contact persons that must appear from the Danish Gambling Authority’s internal systems and the contact information on the following persons:

The company’s contact person/e-mail/tel. no.        ________________
Legal contact person/e-mail/tel. no.             ________________
Technical contact person/e-mail/tel. no.             ________________
The person responsible for gambling software
and day-to-day operation/e-mail/tel. no.            ________________
The person responsible for finance/e-mail/tel. no.        ________________
The person responsible for anti-money laundering
and combat of terrorism financing/e-mail/tel. no.         ________________
The person responsible for system changes/e-mail/tel. no.         ________________
The person responsible for IT security/e-mail/tel. no.         ________________

Thank you for completing the annual account 2019

The completed annual account will be sent to the e-mail stated in the beginning of the annual account as soon as possible and no later than five working days. It will be sent via digital post or BlueWhale.