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FATF’s warning on illegal and offshore gambling will resonate in Denmark. Last year, Spillemyndigheden secured a court order to block 178 unlicensed gambling sites, the largest such action in the regulator’s history.
The case highlighted how illegal operators disguise their presence through multiple site variations, a tactic the FATF report also flags as a red flag indicator.
Denmark’s approach reflects a wider pattern that FATF has tracked for years through its own grey and black listing system. Under this system, jurisdictions with weak AML/CTF controls face increased monitoring or reputational sanction.
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Harris Tsangarides, executive director of the Gaming & Casino Supervision Commission, said his department had noticed spikes in gambling activity coinciding with GMI payment dates, prompting the regulator to consider “technical solution” to cross-reference GMI beneficiary lists with casino membership records.
An issue raised by Giannis Vasiliadis, director of WBAS, was the limited access to recipients’ banking information. This limited data can hint at suspicious activity but cannot conclusively verify gambling transactions.
Data Protection Commissioner Maria Christofidou said her office had reevaluated a 2022 legal opinion and now recognised a potential legal basis for more granular access to banking information.
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Notably for highly engaging verticals light online slots, if players are receiving a smaller-than-expected RTP (return to player), or bonuses have been restricted, they could again transition to an illegal offering where there are no such restrictions.
As has been flagged in previous reports, Regulus highlighted that the top 1% of active customers accounts for almost 50% of black market revenue across Europe. This follows a similar trend across licensed gambling as the report highlights “online gambling is a consumer discretionary expenditure item. This means a large proportion of expenditure is concentrated into a relatively small number of players.”
In its market-specific breakdown, the report noted a “rapid reduction in channelling” in the UK, following the increased use of affordability checks.
