Compliance Updates
Spillemyndigheden Calls Attention to FATF’s Updated Lists of High-risk Jurisdictions
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.
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.
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Africa
South Africa: Tribunal Grants Lottoland Interim Relief – Orders Google to Grant Lottoland Access to its Advertising Platform
The Competition Tribunal (“Tribunal”) has issued an interim order directing Google Ireland Ltd and Google South Africa (Pty) Ltd (collectively, “Google”) to permit Lottoland South Africa (Pty) Ltd (“Lottoland”) to access its advertising services known as “Google Ads”, for so long as Google permits any firm in South Africa to utilise Google’s Ads Services to advertise fixed-odds betting on the outcome of lotteries. The Tribunal’s order applies for a period of six months from its date, or the conclusion of a hearing into the prohibited practices alleged by Lottoland, whichever is the earlier.
This platform enables advertisers to display ads to users who utilise Google search, with Google Ireland acting as the service provider for Google Ads in South Africa.
The Tribunal’s order follows an interim relief application by Lottoland, a licensed bookmaker, which, inter alia, offers fixed-odds bets on the outcome of various lotteries around the world, including the South African national lottery, sporting events and other betting contingencies. Lottoland competes with other licensed bookmakers in South Africa such as Hollywood Bets, World Sports Betting, Betway, Betfred (which owns Lottostar) and Netbet (which trades as Sportingbet).
In summary, Lottoland alleged that Google terminated its access to Google Ads without justification while allowing access to its competitors, causing it financial harm and distorting competition in the market that Lottoland operates in, to the detriment of consumers.
Google contended that Lottoland’s offering of fixed-odds bets on the outcome of the national lottery in South Africa contravenes sections 57(1) and 57(2)(g) of the Lotteries Act. It submitted that in terms of its online advertising policies, which are designed to protect users, restrictions are placed on the promotion of certain gambling activities. Of particular relevance, the promotion of lotteries is limited to state-licensed entities and that this restriction is in place to ensure compliance with the provisions of the Lotteries Act.
Reasons for Decision
A non-confidential version of the Tribunal’s reasons will be published in due course once any confidentiality claims in relation to the reasons have been finalised with the parties involved. In deciding the matter, the Tribunal considered the following three factors holistically, balancing each factor against the other to determine what is reasonable and just:
• Evidence relating to the alleged prohibited practice;
• The need to prevent serious or irreparable damage to the applicant (Lottoland); and
• The balance of convenience.
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Compliance Updates
Massachusetts Gaming Commission Launches Official Seal of Approval
The Massachusetts Gaming Commission (MGC) has recently developed and adopted an official seal of approval, which all licensed sports betting operators in the state are now required to display on their digital platforms. The introduction of this seal represents a significant step in the MGC’s ongoing efforts to promote responsible and regulated gaming within the Commonwealth.
The seal is intended to serve as a clear signal to consumers that they are accessing a sports betting platform licensed and regulated by the MGC. By prominently featuring this seal, customers can easily distinguish between legal, licensed operators and unsafe, illegal alternatives.
“The MGC has spent considerable efforts ensuring that the operators licensed in the Commonwealth share our values and are committed to consumer protections and responsible gaming. Massachusetts residents who choose to gamble on sports deserve to know their data, personal and financial information are protected, and only the legal marketplace offers those protections. By locating this seal, users will be able to easily identify a legal sportsbook from an illegal operator,” said Commissioner Eileen O’Brien.
Offshore and unlicensed sports betting sites have been accessible to patrons across the US for years. However, with the legalization of sports wagering in Massachusetts, these offshore operators may attempt to present themselves as legitimate. Yet, they are not licensed by any state jurisdiction and do not comply with the same regulations and consumer protection standards as the legal market.
The risks of using these illegal platforms extend beyond potential data breaches or financial losses. Unlicensed operators may refuse to honor winning bets, leaving consumers with little to no recourse. Illegal gambling activities are also often tied to other serious crimes. The Massachusetts Attorney General’s Office has issued cease-and-desist orders to several major illicit operators. It will continue to monitor and take action against such unlawful activities in coordination with the MGC. The Commission would urge anyone looking for more information on illegal platforms to visit the website of the American Gaming Association.
This newly adopted seal serves as a visual reminder of the regulations in Massachusetts’s legal sports betting market. It enhances consumer protection and builds trust with members of the public who choose to engage in sports betting. By identifying the official MGC seal, customers can have peace of mind knowing they are accessing a fully licensed platform compliant with the Commonwealth’s laws and regulations.
Compliance Updates
IAGR confirms new Board members
The International Association of Gaming Regulators (IAGR) has announced the appointment of four new trustees to its Board, each bringing unique expertise and leadership to strengthen IAGR’s global regulatory efforts:
- Anders Dorph, Danish Gambling Authority (Europe)
- Peter Kesitilwe Emolemo, Gambling Authority of Botswana (Africa)
- Kevin Mullally, General Commercial Gaming Regulatory Authority (Asia/Oceania)
- Louis Rogacki, New Jersey Division of Gaming Enforcement (North America)
IAGR President Ben Haden said, ‘I’m delighted to welcome our four new trustees to the IAGR Board. Their diverse expertise and leadership across different jurisdictions will bring fresh perspectives to our work, further strengthening our global approach to gaming regulation.
‘I look forward to collaborating with Peter, Louis, Kevin and Anders as we continue to foster innovation and drive forward effective, responsible regulation for the benefit of the global gaming community.
‘We also extend a big thank you to Trude Høgseth Felde and Mabutho Zwane for their dedicated service as they complete their terms on the Board, and I’m pleased to announce that Jason Lane will continue for another term as a Trustee.’
As a leading forum for gaming regulators worldwide, IAGR enables members to meet, share information, discuss legislative developments, exchange views and learn best practices in gaming regulation.
In recent news, IAGR has also confirmed that its 2025 annual conference will be held in Toronto, Canada, from 20 to 23 October 2025, with registrations opening in early 2025.
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