Mr Green faces triple Danish injunction over anti-money launching breaches

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Spillemyndigheden identified three areas of concern regarding Mr Green and its activities in Denmark. These include insufficient risk assessment, defective and missing business processes, and lack of documentation for checks.

Separately, Mr Green also faces prosecution over another matter related to anti-money laundering processes. 

Breaking down the injunctions

The first point of concern refers to what Spillemyndigheden described as a “flawed” risk assessment. Specifically, this was in reference to Section 7 of the Money Laundering Act.

This, the regulator said, states a risk assessment should include a separate assessment of risks regarding individual payment solutions and delivery channels. As Mr Green does not currently have such a separate assessment, this places it in breach of the Act.

“Companies covered by the law must identify and assess the risk that the company may be misused for money laundering or the financing of terrorism,” Spillemyndigheden said.

The second injunction covers a lack of sufficient business procedures for internal controls. 

Spillemyndigheden said the current systems in place at Mr Green do not reference the interval at which controls must take place. Here, the regulator also notes Mr Green does not have written business procedures for how checks should run.

Section 8 of the Act states companies must have sufficient written business procedures, including internal controls.

“The requirement for internal control also implies that a check must be carried out as to whether the controls are carried out – i.e. that a control is carried out with the controls,” the regulator said. “Mr Green has not sufficiently complied with business process obligations for controls.”

The final injunction looks at a lack of documentation for checks. According to the regulator, Mr Green did not document information about checks or internal controls.

Again, this ties in with Section 8 of the Act. This states companies must document checks that have taken place.

Mr Green faces prosecution 

Spillemyndigheden has also elected to pursue prosecution against Mr Green over a breach of Section 26 of the Act. 

This refers to a requirement for companies to notify the Money Laundering Secretariat over any suspicion of money laundering or the financing of terrorism. As Mr Green failed to comply with these requirements, it will now face prosecution. 

“Mr. Green has not complied with the obligations regarding notifications, as there has been no immediate notification,” Spillemyndigheden said.

What next for Mr Green?

In terms of its future conduct, Spillemyndigheden set out details about a “duty to act” for Mr Green. This references the three injunctions filed against the operator.

First, Mr Green should submit a revised risk assessment and business process for internal controls by 10 June. It must also submit prepared business processes for how controls take place.

Furthermore, Mr Green must submit documentation to show checks have taken place by 10 October.

Spillemyndigheden added that the indictment entails no obligation to act for Mr Green, as it is a non-existing infringement.

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