No obligation to act on Mr. Green

Under Denmark’s Anti-Money Laundering and Anti-Terrorism Funding Act (AML Act), businesses must immediately notify the Money Laundering Secretariat whenever there is “reasonable grounds” to suspect that funds, activities or transactions “have or have been related to money laundering or terrorist financing.”

The DGA explained that the reprimand does not oblige the operator to act because no more violations have occurred, but Mr Green has received three orders: violations related to internal control, risk assessment and lack of necessary paperwork.

As the DGA explained, the violation related to internal control was caused by a lack of written procedures for the in-house control approach with respect to the interval at which controls should be performed.

Regarding the insufficient risk assessment order, the regulator confirmed that the procedure used by Mr Green did not include an individual assessment of the payment solution.

Danish law uses separate risk assessments for “individual payment solutions and delivery channels” and requires additional risk assessments for risk factors related to these factors.

Mr Green also failed to sufficiently document the controls used to evaluate internal controls, which forced regulators to issue a third order. 바카라

As explained by a spokesperson for 888, all three audit results were revealed at the end of the regulator’s routine audit.

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