This is a brief update on current affairs on the Danish gambling market.

This update concerns six important issues:

  • Reminder regarding new Danish AML Act
  • EC notified of the regulations for online bingo
  • Standards records for horse, dog and pigeon race betting and online bingo
  • DGA’s report on illegal gambling
  • Q2 gambling data from the Danish market
  • Reorganisation of the DGA.

Reminder regarding new Danish AML Act

As you may be aware, the new Danish Anti Money Laundering Act (“the AML Act”) came into force on 26 June 2017.

The AML Act contains a number of new requirements that all license holders must comply with going forward from 26 June 2017. Horten would like to emphasize that the new AML Act comprises both land-based and online gambling as well as both betting and casino.

One of the most novel changes from the former AML regulation is the requirement that all license holders who employ more than five people must have a whistleblower scheme in place for their employees to report AML irregularities.

In short, the requirements for the whistleblower scheme are:

  • It must be a special, independent and impartial channel
  • The employee must be able to report violations and potential violations of the AML Act and the rules issued pursuant hereto
  • The employee must be able to submit reports anonymously through the scheme.

Please note that according to art. 78 of the Danish AML Act, a license holder can be fined for not having the required whistleblower scheme in place, if the noncompliance is considered intentional or gross negligent. As the AML Act is new, it is uncertain how the requirement will be enforced.

Horten has many years of experience setting up and managing whistleblower schemes, and we are of course be available for assistance in this matter.

The DGA is still working on their guidelines on the new AML Act. It remains uncertain whether the guidelines will be included in the general guidelines issued by the Danish Financial Supervisory Authority or as a separate guideline.

EC notified of the regulations for online bingo

In connection with the upcoming liberalisation of online bingo, which comes into force on 1 January 2018, the Danish government has notified the EC of the proposed online bingo regulations. The requirements are not final, but it is our opinion that the final re-quirements will most likely be similar or identical to these.

The overall requirements are:

  • Bingo cards shall consist of five rows and five columns with 75 numbers or symbols, or three rows and nine columns with 90 numbers or symbols.
  • The printed numbers or symbols are drawn and called out one at a time.
  • The player shall have the option to manually mark the printed numbers or symbols at all times.
  • The player may not choose the combination of numbers or symbols on the bingo card.
  • Licence holders shall ensure that numbers or symbols are called out at intervals of at least 3 seconds, and that the game is put on hold for at least 10 seconds each time there is a winner.
  • The game shall end when the first board has been completely filled.
  • The purchase of bingo cards must, with the exception of online bingo provided via television, be possible no earlier than 10 minutes before the game starts.

Other specific requirements apply to online bingo offered via television.

Standard records for horse, dog and pigeon race betting and online bingo

In connection with the upcoming liberalisation of horse, dog and pigeon race betting and online bingo, which enters into force on 1 January 2018, the DGA has issued standard records for the reporting of these games.

Report on illegal gambling

The DGA has issued their 2016/2017 report on illegal gambling on the Danish market. The report is a follow-up of the report from last year and provides an overview of the DGA’s work regarding illegal gambling.

The DGA has primarily been focusing on illegal online gambling.

It is the DGA’s overall opinion that the number of websites which are illegally targeting Danish customers are decreasing. However, the DGA notes that there are still some is-sues with transmission websites. Most cases concern recommendation websites, e.g. websites that mention “top 10 best gambling websites”.

Secondly, the DGA has seen an increasing number of problems with illegal provision of games on Facebook. Most cases concern Facebook groups that offer illegal lotteries.

Thirdly, the DGA has experienced extensive problems with skin betting, which is a bet-ting area that in many cases is directed towards kids. Thus, skin betting issues have re-ceived a lot of negative media attention in Denmark lately, which has also resulted in some political focus on the issue. The DGA is focusing on this area and will continue to do so in the future. The next batch of website blockings will include skin betting web-sites.

Lastly, the DGA has been looking at the offering of bets on under-18 sports games. The DGA has reviewed all current betting licence holders’ websites multiple times and has found that in a few instances, betting on under-18 sports games was available on some of the licence holders’ websites. The DGA will send an information letter to all betting licence holders regarding the general rules.

As for land-based gambling, the DGA has only handled a small number of cases regard-ing non-profit lotteries and illegally placed slot machines/betting terminals.

The report does not touch upon the issues on the “grey market” – operators not tar-geting Denmark with their marketing but accepting bets from Danish players.

The report is not yet available in English.

Q2 gambling data from the Danish market

The DGA has issued the latest Danish gambling market statistics.

Since Q1 the Danish market has experienced a five percent growth. This has primarily been driven by online casinos. With 1,462 billon, Q2 set a record for the combined gross gambling revenue.

Reorganisation of the DGA

On 1 October 2017 an internal reorganisation of the DGA came into effect.

In the future, each office is responsible for all the processes belonging to a specific area; from issuing permits to ongoing supervision. The DGA will still be an authority under the Danish Ministry of Tax. The DGA will be divided into four divisions:

  • Finance, Policy and Market Analysis
  • Lottery and Monopoly
  • Remote Gambling
  • Slot Machines and Responsible Gambling