In May 2024, Finnish Operator Veikkaus received a request for clarification from the Police Board about its advertising in connection with television programmes that are also watched by minors. The company responded to the clarification request and adjusted its operations in cooperation with the authority. As a result, Veikkaus’ advertising will no longer appear in certain programme environments.

Veikkaus has received a marketing ban from the Police Board dated 12 November 2024 enhanced by a fine. It refers to the clarification request from May and highlights the wrongly placed advertisement that happened in July as a violation. In addition to this, it brings out new perspectives on the placement of advertisements in connection with television programmes. They have now included new programmes aimed at adults, but may also be of interest to minors. Examples include popular Saturday night entertainment programmes.

“It seems that the Police Board may interpret the matter in a new and broader way. We have been in contact with the Police Board as soon as the decision was made and we are going through this issue with them. We need clarity so that we know how to act correctly,” Anu Kytö, sales and marketing director at Veikkaus, said.

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“We are very sorry that, despite our joint development measures, our advertising has been seen in the advertising breaks of programs aimed at minors due to human error,” Kytö added.

Veikkaus’ advertising is bought in such a way that the target group is people aged 25 and over. The media office books and the television channel places the ads based on viewer profiles. The instructions have been reviewed together with the Police Board.

“Veikkaus has been buying TV advertising from us for years, with an age distribution set for the purchase: more than 70% of the program’s viewers must be adults. This is a jointly agreed model that has been valid for years and is known to the authorities. Now we are waiting for possible new instructions,” MTV’s commercial director Sauli Asikainen said.

The ban is valid for three months and its validity begins 30 days after notification. The Police Board imposed a fine of 2.9 million euros as an effect of the marketing ban.

The Danish Gambling Authority has called attention to FATF’s (Financial Action Task Force) updated lists of high-risk jurisdictions: the Grey List (jurisdictions under increased monitoring) and Black List (call for actions). Among other things, gambling operators must include FATF’s lists of high-risk jurisdictions when risk assessing players.

Jurisdictions listed on the Grey List are Algeria, Angola, Bulgaria, Burkina Faso, Cameroon, the Ivory Coast, Croatia, DR Congo, Haiti, Kenya, Lebanon, Mali, Monaco, Mozambique, Namibia, Nigeria, the Philippines, South Africa, South Sudan, Syria, Tanzania, Venezuela, Vietnam and Yemen.

Jurisdictions listed on the Black List are Democratic People’s Republic of Korea, Iran and Myanmar.

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Gambling operators are required to conduct enhanced customer due diligence (EDD) pursuant to section 17(1) of the Danish AML Act, if a player is assessed to impose a higher risk of the gambling operator being misused for money laundering or terrorist financing.

Gambling operators shall conduct this risk assessment based on Annex 3 to the AML Act (high-risk factors) which includes the FATF high-risk country lists (the so called black list and grey list).

It is not required that gambling operators perform EDD if a country is listed on the FATF’s list. EDD are only a requirement for players from jurisdictions listed in the EU Regulation of High Risk Third Country list pursuant to 17(2) of the AML Act.