THE SWEDISH GAMBLING MONOPOLY - IMGL · were Erwin van Lambaart, CEO of Holland Casino, Peter-Paul...

INCLUDES UPDATES ON: UPDATED AML LEGISLATION IN GERMANY, GENERAL DATA PROTECTION REGULATION, SKIN GAMBLING IN MALTA, FUTURE CHANGES TO UK GAMBLING ACT

THE SWEDISH GAMBLING MONOPOLYWILL RE-REGULATION ALLOW THE GOVERNMENT TO REGAIN CONTROL OVER THE GAMING SECTOR

SHAPING THE FUTURE OF EUROPEAN GAMING LAW

SPRING ISSUE 2017

Get in touch with ourGaming & Betting Law Practice GroupDr. Joerg Hofmann, Dr. Matthias Spitzand Jessica Maier LL.M.

[email protected] us an e-mail to subscribe to our newsletter.

That is not the question. It is about being prepared for all contingencies.Our experienced lawyers support you in accomplishing this task.

For over thirty years, our attorneys have been advising leading companiesof the gaming and betting industry. Gaming & Betting Law has thereforebeen established as one of the core competences of our law firm.

Berlin|Frankfurt|Heidelberg

To betor not to

bet

European Gaming Lawyer | Spring Issue | 2017 | 3

4 c s

5 Message from The President

8nting t t i cti

c a ng s a ad o t German market

10 n a ata ot ction

gu ation and its i act on Remote Gaming Operators

1 in a ing cas o gu ation in Malta

2a ing on at itain

utu c ang s to n o c nt actic s in t

onsu co aints in t ga ing indust t a ing o ission

cts o o o ato s, o id s and t o ission its

[ ]Contents

CONTACTSInternational Masters of Gaming Law -www.gaminglawmasters.com

EDITOR Nick Nocton: [email protected]

Designer: Simon BrakeProduction & Studio Manager: Craig Young, [email protected] of iGaming Business: Alex Pratt, [email protected] of Operations: Shona ODonnell, [email protected]

SALES Ian Larcombe, [email protected]

Jake Lemer, [email protected]

SUBSCRIPTIONS Account Manager: Andrew Freeman, [email protected]

Print: Printed in the UK by Pensord Press, www.pensord.co.uk Published by: iGaming Business Ltd, Bedford House, 69-79 Fulham High St, London SW6 3JW, UK. T: +44 (0)20 7265 4112 F: +44 (0)20 7954 3511 www.igamingbusiness.com. European Gaming Lawyer is published bi-annually © International Masters of Gaming Law 2017. All rights reserved. ISSN 2398-1903. No part of this publication may be reproduced or transmitted in any form or by any means, or stored in any retrieval system of any nature without prior written permission, except for permitted fair dealing under the Copyright Designs and Patents Act 1988. Application for

permission for use of copyright material including permission to reproduce extracts in other published works shall be made to the publishers. Full acknowledgement of author, publisher and source must be given.

�e paper used within this publication has been sourced from a Chain-of-Custody certi�ed manufacturer, operating within international environmental standards such as ISO14001 and EMAS. �is is to ensure sustainable sourcing of the raw materials, sustainable production and to minimise our carbon footprint.

2 co atu

The Re-Regulation Of The Swedish Gambling Monopoly

4 | European Gaming Lawyer | Spring Issue | 2017

[ ]IMGL Offi cers 2017

Michael E. Zatezalo

President Kegler, Brown, Hill & Ritter Co., L.P.A. Columbus, Ohio, USA

T: +1 614 462 [email protected]

Douglas L. Florence, Sr.

Vice President, Affi liate MembersAvigilonLas Vegas, Nevada, USA

T: +1 702 683 6016douglas.� [email protected]

Jamie Nettleton

First Vice PresidentAddisons Lawyers, Sydney, Australia

T: +61 2 8915 1030 [email protected]

Justin Franssen

Assistant SecretaryKal� Katz & Franssen Amsterdam, Netherlands

T: +31 20 676 07 80franssen@kal� atzfranssen.nl

Quirino Mancini

SecretaryTonucci & Partners, Rome, Italy


Sue McNabb

Executive DirectorInternational Masters of Gaming Law, Louisiana, USA


IMGL Officers

Michael E. ZatezaloPresident

Kegler, Brown, Hill & Ritter Co.,L.P.A.

Columbus, Ohio +1 614 462 5400

[email protected]

Jamie NettletonFirst Vice PresidentAddisons LawyersSydney, Australia+61 2 8915 1030

[email protected]

D. Michael McBride III Second Vice PresidentCrowe & Dunlevy, P.C.

Tulsa, Oklahoma+1 918 592 9824

[email protected]

Quirino ManciniSecretary

Tonucci & PartnersRome, Italy

39 06 322 [email protected]

Justin FranssenAssistant SecretaryKalff Katz Franssen

Amsterdam, Netherlands31 20 67 60 780

[email protected]

Marc H. EllingerTreasurer

Blitz, Bardgett & Deutsch, L.C.Jefferson City, Missouri

+1 573 634 [email protected]

Marie JonesAssistant TreasurerFox Rothschild LLP

Philadelphia, Pennsylvania1-609-572-2259

[email protected]

Douglas L. Florence, Sr.Vice President, Affiliate Members

AvigilonLas Vegas, Nevada

[email protected]

Keith C. MillerVice President, Educator

Drake University Law School Des Moines, Iowa+1 515 271 2071

[email protected]

Joerg HofmannImmediate Past President

MELCHERS law firmHeidelberg, Germany

[email protected]

Morten RondeDirector of Education and Association Development

International Masters of Gaming Law

[email protected]

45 208 87210

Sue McNabbExecutive Director

International Masters of Gaming Law

[email protected]

1-702-375-5812

Jamie NettletonFirst Vice President

Michael E. ZatezaloPresident

www.gaminglawmasters.com �

D. Michael McBride IIISecond Vice President

Quirino ManciniSecretary

Justin FranssenAssistant Secretary

Marc H. EllingerTreasurer

Marie JonesAssistant Treasurer

Douglas Florence Sr.Vice President, Affiliate Members

Joerg HofmannImmediate Past President

Sue McNabbExecutive Director

Morten RondeDirector of Education andAssociation Development

INTERNATIONAL MASTERS OF GAMING LAW

Keith C. MillerVice President, Educator

AGLSpring2016_Layout 2 3/21/16 2:09 PM Page 2

Marie Jones

Assistant TreasurerFox Rothschild LLP, Philadelphia, Pennsylvania, USA


Joerg Hofmann

Immediate Past PresidentMelchers Law FirmHeidelberg, Germany


Marc H. Ellinger

TreasurerBlitz, Bardgett & Deutsch, L.C.Je� erson City, Missouri, USA


D. Michael McBride III

Second Vice PresidentCrowe & Dunlevy, P.C. Tulsa, Oklahoma, USA


Keith C. Miller

Vice President, EducatorDrake University Law School Des Moines, Iowa, USA


Morten Ronde

Director of Education and Association DevelopmentInternational Masters of Gaming Law, Denmark

T: +45 208 [email protected]


MGL started the New Year where it le� o� in 2016 by o�ering its Masterclass at the National Council of Legislators from Gaming States (“NCLGS”) at the NCLGS winter meeting in Scottsdale,

Arizona, on January 6-8th, 2017. �e IMGL Masterclass included panels on the role of Regulators, Tribal Gaming Legal Issues with States, and eSports and were well received.

On February 3, 2017, IMGL and the law �rm of Kal� Katz & Franssen hosted a pre-ICE gathering of gaming o�cials and industry representatives at the Industrieele Groote Club in Amsterdam, Holland. Over 150 guests attended this invitation only gathering. Justin Franssen, IMGL Assistant Secretary and General Member from Holland, was the host and did a fantastic job. Featured speakers were Erwin van Lambaart, CEO of Holland Casino, Peter-Paul de Goeg, Managing Director of Lottomate and Marja Appelman, head of the Holland Casino Commission. It was a very informative meeting and great networking event.

�en it was on to London for the Annual ICE conference (February 7-9) in London, England, at the ExCel center. IMGL once again held a Masterclass at ICE which was very well attended with 221 attendees (extra chairs needed to be brought into the conference room!) and included panels on worldwide developments, anti-money laundering and the e�ect that Brexit and the election of Donald Trump would have on the gaming industry. IMGL also had its annual ICE reception at Merchant Taylors’ Hall in London and experienced the largest crowd ever to attend the reception.

Our thanks to member Tony Coles and his �rm Gordon Dadds for co-hosting the reception. It was not only a great location but a fascinating historical venue.

However, perhaps the biggest news of the new year is IMGL’s entering into a Memorandum of Understanding with Clarion Event Limited which gives IMGL the option to conduct Masterclasses at all Clarion events. We are very excited about this partnership and the opportunity to extend the reach of the IMGL brand. If any of our members are interested in participating or organizing any of these Masterclasses, please contact Joerg Ho�man, our past President, who is coordinating our Masterclasses and our Executive Director Sue McNabb. We have posted on the IMGL website a list of the con�rmed future IMGL Masterclasses for 2017 as well as the Clarion events where IMGL will have the option of conducting a Masterclass.

�e IMGL spring conference will be held in Miami, Florida, this year and takes place on May 10-12th, 2017, at the Turnberry Isle. If you have not made your reservations to attend, I would suggest you do now. It should be another great conference and o�ers a side trip to the Gulfstream racetrack on Saturday, May 13th, with a private suite at the �nish line for IMGL guests to enjoy the day. I encourage everyone to make plans to stay in Miami over the weekend and enjoy the Day at the Races. Finally, our fall conference will be held in Copenhagen, Denmark, September 10-12th, 2017. Please mark your calendars accordingly. As you can tell, 2017 will be a very busy and exciting year for IMGL. I look forward to seeing many of you in Miami.

Mike Zatezalo, [email protected]

President Mike Zatezalo

[ ]President’s Message

I

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RefreshinglyPractical Solutions

Affiliation • Blockchain Technology • Brand Protection

Competition (antitrust) • Compliance • Company Incorporation

Company Maintenance • Company Protection • Consumer Protection

Corporate Finance • Cryptocurrency • Data Protection

Domain Name Disputes • eCommunication • Employment • eMoney

eSports • EU Cross Border Trade • Financial Services • Gaming & Gambling

ICT • Image Rights • Insolvency • IP Payments • Licensing

Mergers & Acquisitions • Privacy • Restructuring • Real Estate

Sponsorship • Software Licensing • Taxation • Wealth management

Level 5 Quantum House 75 Abate Rigord Street Ta’ Xbiex XBX 1120 • Malta

Telephone: (+356) 2092 5100 Web: www.whpartners.eu


’ve lost a million and a half on the horses and dice in the last two years. And the funny part is, I still like ‘em, and if someone handed me another million I’d put it right in the nose

of some horse that looked good to me.” (Al Capone on his gambling habit)

IntroductionAl Capone certainly is not the kind of patron modern-day online gambling operators would wish to form part of their customer base. Yet, so far horse-race betting has not been subject to anti-money laundering (‘AML’) requirements under federal law in Germany and this may well stay like this under the future German AML regulation that is to enter into force by June 2017. Hence, Al Capone’s heirs would still be able to enjoy a gamble on German racetracks. In contrast, retail and online sports betting will be subject to strict AML requirements from June 2017 onwards.

Implementing the 4th AML Directive of the European Union1 (the ‘4AMLD’) the Federal Government of Germany approved a dra� AML Act on 22 February 2017 and initiated the parliamentary procedure. � is article will summarise the key elements of the dra� law and the challenges the gambling industry may face implementing them in practice.

Status QuoUnder the current AML Act, only two types of gambling operations are subject to AML requirements as per the federal AML Act: Bricks-and-mortar casinos and operators of online gambling. � ese are obliged to implement internal safeguards against money laundering (‘ML’). � ese include internal policies to combat ML, which have to be created and periodically reviewed by an AML o� cer who has to be appointed, together with a deputy AML o� cer. Further key requirements include the vetting and

training of sta� , monitoring of customer transactions and the establishment of implementing procedures for suspicious transaction reporting (‘STR’). Customer due diligence – commonly also referred to as “know-your-customer” (‘KYC’) has to be applied in bricks-and-mortar casinos for transactions exceeding 2,000.– EUR, i.e. single or combined purchases of chips in that amount. For online gambling operations, the current law already prescribes a general KYC obligation upon customer registration, i.e. irrespective of a certain transaction threshold. Consequently, it would have been a surprise if the German legislator reverted to the 2,000.– EUR threshold provided for in the 4AMLD for KYC obligations in relation to gambling services now when implementing the directive into national law.

Scope of the new lawConsequently, the online gambling market in Germany continues to be subject to AML requirements under the new law, and KYC will have to be applied irrespective of a certain threshold of online gaming transactions being met.

In contrast – and this is where Mr Al Capone enters the scene again –, the dra� AML Act that was approved by the Federal Government provides for considerable exemptions for other gambling sectors. � ese include:

1) Slot machine operations in gaming halls and restaurants;2) Land-based horse-race betting at racetracks; and3) Retail lottery sales.

� e parliamentary explanatory notes attached to the dra� AML Act provide some sketchy considerations as to why the above should be entirely (!) excluded from the scope of the new law. � ese mainly focus on a “rather low ML risk” being associated with these products which allegedly allows for these products to be excluded from the scope of the law. While this may be plausible from a product-centred point of view, the 4AMLD stipulates that Member States may decide to

”I

1 Directive (EU) 2015/849 of 20 May 2015 on the prevention of the use of the

fi nancia s ste for t e purposes of one aunderin or terrorist fi nancin

Joerg Hofmann

Matthias Spitz

Jessica Maier

Implementing the 4th AML Directive: New challenges ahead for

the German market by Dr Joerg Hofmann, Dr. Matthias Spitz and Jessica Maier, of C a fi r


exempt providers of certain gambling services from national provisions when transposing the 4AMLD – “following an appropriate risk assessment”. Such a risk assessment would also have to take into account speci�c risks arising from a certain gambling sector or market and not only the product-related ML risks. It, therefore, does not come as a surprise that the Federal Assembly (Bundesrat, i.e. the representation of the German states at federal level) has demanded that the exemptions with regard to gaming halls and horse-race betting be reversed. �en again, the privilege for retail lottery sales is unlikely to be touched. It might even have been been caused by the states seeing as their gambling policies aim at preserving the state monopoly on lottery operations and treating it in a patronising manner.

KYC and provisional player accountsFrom the perspective of the online gambling industry, KYC requirements will be a key challenge under the new laws. �e German AML law follows the concept of an ID card-based identi�cation and veri�cation, where, in terms of a provisional identi�cation, at least a copy of an ID card would have to be submitted by the player prior to him/her being allowed to participate in online gambling activities on a provisional basis. Pursuant to the dra� AML Act, the operator, however, is obliged to “promptly conduct a full veri�cation” a�er the provisional player account is opened. Obviously, this concept of KYC has not been happily received by the online gambling industry (sec. 16(8) dra� AML Act). Yet, following substantial lobbying e�orts of the German Sports Betting Association (Deutscher Sportwettenverband – DSWV), the wording in the version approved by the Federal Government was amended.

Online gambling operators, as a second option, may also choose to conduct KYC “in accordance with the requirements for identi�cation and authentication under gambling regulations”. Interestingly, the German regulation of gambling, including the Interstate Treaty on Gambling (the ‘Interstate Treaty’) as the overarching law, do not stipulate any particulars in relation to KYC. Essentially, it is only required to “ensure the exclusion of minors and barred players through identi�cation and authentication” (sec. 4(5) no. 1 Interstate Treaty). In April last year, the Gambling Committee (i.e. the

interstate body representing the leading state regulators) published a paper setting out “Key Aspects of Internet Requirements” to �ll in the gaps. According to this paper, identi�cation and authentication will have to meet the following requirements in order to comply with gambling law:

1) A multi-level video identi�cation process and online gambling on a provisional basis up to 150 EUR, where the player account has to be activated within 30 days; or2) Veri�cation based on databases featuring data from face-to-face checks with su�cient match ratio and provisional gambling up to 150 EUR; again, the player account would have to be activated within 30 days, and login credentials would have to be submitted using secure email services or a 1-Cent-bank transfer; or3) Identi�cation using electronic ID card functions.

Albeit not really convenient for online gambling operations, the above requirements arguably may be feasible. Payment restrictions, however, could turn out to be a higher threat to the business going forward. Whilst it was obvious that the Federal Government would exclude cash vouchers (the use of any anonymous payment method is already prohibited under the current law with regard to online gambling), the fact that the federal states expressed the view that credit cards might not qualify as permissible means of payment through the statement submitted by the Federal Assembly must be considered a threat to the business. �e underlying idea appears to be that credit cards essentially are a kind of anonymous payment method, since it is contended that the customer cannot be automatically matched with the credit card holder. Obviously, this does not take into account that many EU-licensed operators will have complementary measures ensuring a “closed loop policy” is in place.

It is clear that for the remaining months of the legislative procedure, the industry, through its lobby groups (i.e. the DSWV and the German Online Casino Association – DOCV), will make considerable e�orts to ensure that such a restriction will not expressly be included in the �nal law

Further internal security measuresAs indicated above, the dra� AML Act that was approved by the Federal Government now extends general AML requirements also to retail sports betting operations. Having to implement individual security measures, such as a risk analysis for each franchisee and appointing an AML o�cer for each betting shop or betting agent (while ensuring su�cient protection under employment law from dismissal as demanded by the law) as well as storing KYC data for at least 5 years, would certainly amount to an undue compliance burden for the retail betting sector. Interestingly, the Federal Assembly seems to have acknowledged this promlem and is proposing to treat franchisees as part of the sports betting operator’s distribution network. Accordingly, responsibilities for AML obligations could be shared between the franchiser (i.e. the operator) and the franchisee (i.e. betting shop owners or agents). It remains to be seen whether this amendment will be implemented in the �nal law.

It is expected that the gambling regulators of each state will also be responsible for supervising gambling operations with regard to AML compliance. Rumours suggest that they have understood what powerful enforcement tool AML regulation can be – also bearing in mind their failure in implementing and enforcing Interstate Treaty regulations. Hence, the gambling industry is well advised to prepare and, where necessary, mitigate risks arising from new AML requirements in relation to the German market.

Joerg Hofmann is the Head of the Gaming Law practice at a fi and President of the IMGL. He can be reached by email: [email protected]

Matthias Spitz is a partner at a fi and

of the IMGL. He can be reached by email: [email protected]

Jessica Maier, LL.M. is a gaming atto n it a fi She can be reached by email: [email protected]


he regulatory environment for remote gaming operators in Europe has been signi� cantly unclear during the last decade(s). � e legal regime of many member states still does not comply

with the freedom of services granted under Union law. � erefore, there has been a tendency of remote gaming operators to put the focus of their strategy on how to survive under nebulous and di� cult legal circumstances. � is might be the reason why in the past data protection issues were not treated with high priorities even though remote gam(bl)ing is nothing other then a permanent processing of personal data.

� e General Data Protection Regulation (GDPR) marks a turning point in the relevance of data protection law.

I. General InformationAfter long lasting discussions the GDPR was adopted by the European Parliament on 14 April 2016, published in the Official Journal on 4 May 2016, came into force on 25 May 2016 and will apply from 25 May 2018 (Art. 99). Different from the old Data Protection Regulation of 1995 the new Directive does not need to be transposed by the Member States into national law. The GDPR includes 99 Articles (instead of 34 Articles in the old Regulation) and a high number of 173 Recitals which almost make up 40% of the complete published text.

� e aim was to modernise and harmonise data protection law in the EU. However, it seems questionable to which extent a EU wide harmonisation will be achieved since the GDPR includes nearly 50 opening clauses which allow the Member States to specify, to complete or even to amend regulations of the GDPR. As a result, the GDPR turns out to be a hybrid between a directive and a regulation. � erefore, it is to be assumed that the legal framework as well as the application by Member States will continue to di� er substantially.

E. g. the current bill being discussed within the legislative procedure in Germany and transposing the GDPR into national law 32 times refers to the opening clause in Art. 23 GDPR (BR-Drs. 110/17).

� e GDPR adheres to general principles set forth in the Data Protection Directive of 1995. However, the GDPR includes several substantial amendments which require a complete reassessment of data processing structures by authorities and private entities.

� e list below includes a summary of the most signi� cant elements of the GDPR.

Like the old regime data processing is only lawful if speci� cally allowed. Under the new regime processing is lawful if and to the extent that at least one of the following conditions apply (Art. 6):(1) the individual has given consent to the

processing of his or her personal data for one or more speci� c purposes;

(2) processing is necessary for the performance of a contract to which the individual is party or in order to take steps at the request of the individual prior to entering into a contract;

(3) processing is necessary for compliance with a legal obligation to which the controller is subject;

(4) processing is necessary in order to protect the vital interests of the individual or of another natural person;

(5) processing is necessary for the performance of a task carried out in the public interest or in the exercise of o� cial authority vested in the controller;

(6) processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

T

The General Data Protection

Remote Gaming Operatorsby


For private entities options (1), (2) and (3) are most relevant. However, the requirements for option (1) have increased. Art. 7 provides that if the data subject’s consent is given in the context of a written declaration which also concerns other matters, the request for consent shall be presented in a manner which is clearly distinguishable from the other matters, in an intelligible and easily accessible form, using clear and plain language. Any part of such a declaration which constitutes an infringement of the Regulation shall not be binding.

Moreover, any data processing shall follow the six principles laid down in Art. 5: lawfulness, fairness and transparency; purpose limitation; data minimisation; accuracy; integrity and con� dentiality.

2. Sanctions, additional o ers for Supervisory AuthoritiesIt has been the intention to increase awareness for data protection issues and to make data protection a high-level management issue. Under the GDPR Supervisory Authorities will have the power to issue � nes of up to 4 % of the turnover or 20 million € whatever is more (Art. 82 subsequent). Regarding group companies, it is likely but not completely clear that the turnover of a group and not of the company involved constitutes the calculation base for the � ne (Art. 4 No. 18 and 19, Recital 150). � is substantial amendment is surrounded by additional powers of Supervisory Authorities like the possibility to demand information from data processors and controllers or to perform audits.

3. Extra-territorial Applicability, Obligation to appoint a Representative� e extension of the territorial reach of the GDPR constitutes one of the most fundamental legal changes. Under the old Data Protection Directive (Art. 4) and its adoption into national law the applicability of data protection law generally spoken was related to an establishment in the EU and not too clear.1 � e new GDPR clearly provides that it is also applicable to all data processing activities of controllers or

processors not established in the Union provided that the data processing activities are related to o� ering goods or services to individuals in one or more Member States in the Union (Recital 23, Art. 3). It also applies to controllers or processors not established in the Union when data processing is related to the monitoring of the behaviour of individuals located in the Union in so far as their behaviour takes place within the Union (Recital 24). What is more, controllers or processors established outside the Union are obliged to appoint a Representative in the Union who may be held liable for breaches of the Regulation (Recital 80, Art. 4 (17), Art. 27 with some exceptions).

4. Privacy Notices� e aim of privacy notices is to inform the individual about how his or her personal data are processed in a way that the individual is in a position to exercise his or her rights. Art. 12 - 14 comprise detailed and extensive obligations on the information of individuals. At the same time there is the obligation to “provide any information referred to in Articles 13 and 14 and any communication under Articles 15 to 22 and 34 relating to processing to the data subject in a concise, transparent, intelligible and easily accessible form, using clear and plain language, in particular for any information addressed speci� cally to a child. � e information shall be provided in writing, or by other means, including, where appropriate,

by electronic means.”

Art. 13 includes the following information to be disclosed to the individual:• the identity and the contact details

of the controller;• the contact details of the data

protection o� cer; • the purposes of the processing for

which the personal data are intended as well as the legal basis for the processing;

• the recipients or categories of recipients of the personal data, if any;

• where applicable, the fact that the controller intends to transfer personal data to a third country;

• the period for which the personal data will be stored, or if that is not possible, the criteria used to determine that period;

• the existence of the right to request from the controller access to and recti� cation or erasure of personal data or restriction of processing concerning the data subject or to object to processing as well as the right to data portability;

1 ECJ C-230/14 – Weltimmo, ECJ C-131/12 – Google Spain.


means, including, where appropriate, by electronic means.”


• the existence of the right to withdraw consent at any time, without a�ecting the lawfulness of processing based on consent before its withdrawal;

• the right to lodge a complaint with a supervisory authority;

• whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether the data subject is obliged to provide the personal data and of the possible consequences of failure to provide such data;

• the existence of automated decision-making, including pro�ling, as well as the signi�cance and the envisaged consequences of such processing for the data subject;

• Where the controller intends to further process the personal data for a purpose other than that for which the personal data were collected, the controller shall provide the data subject prior to that further processing with any relevant information.

It will be a challenge to comply with all information and transparency requirements under the GDPR in a concise, transparent, intelligible form, using clear and plain language. However, a failure to do so may not only constitute a breach of the GDPR but may also question the consent of the individual granted pursuant to Art. 7.

5. Changes for Data Processors: Direct Applicability and LiabilityAlready under the old regime it has been di�ered between Controllers and Processors of data (Art. 2 (d) and (e) of the Directive). However, responsibility and liability mainly were related to the Controller. Under the new Regime the position of the Processor has changed substantially. Many provisions are directly applicable to Processors. Moreover, a joint liability of Processor and Controller has been established (Recital 146, Art. 82). �erefore, the risk for Processors of data has increased substantially.

6. Agreements between Data Processors and Controllers�e requirements for processing personal data by a Processor on behalf of a Controller have been strengthened substantially. Such

processing inter alia requires a written contract or other legal act under Union or Member State law, that is binding on the Processor and that sets out the subject-matter and duration of the processing, the nature and purpose of the processing, the type of personal data and categories of data subjects and the obligations and rights of the controller. Additional requirements for the agreement and relationship between Controller and Processor are speci�ed in Art. 28 and 29. �e legislation of some Member States already comprises similar obligations. However, from May 2018 the obligations are applicable to all data processing by Processors on behalf of Controllers within the extended reach of the GDPR (see above Sec. II 3).

7. Obligation to appoint a Data

Under the old Data Protection Directive there was no obligation for Member States to require the appointment of Data Protection O�cers. Nevertheless, the legislation of many States (like Germany) already comprises a respective obligation. In future, all companies processing personal data as core activity as well as Public Authorities are obliged to appoint a Data Protection O�cer (Art. 27). Art. 28 sets forth strict provisions for the position of a Data Protection O�cer (like independence, no con�ict of interests, etc.). �e Data Protection O�cer shall report to the highest management level of the processor or controller. He particularly shall have the task to inform and advise the controller or processor and the employees of their obligations, to monitor compliance with the Regulation and national data protection law and to communicate and to cooperate with the Supervisory Authority (Art. 39). Given the risks involved with such position including the new sanction regime it might be hard to �nd third party providers who act as Data Protection O�cer.

8. Transfer of Data outside the UnionAlready under the old regime the transfer of personal data to third countries has been a substantial hurdle unless a third country has been accepted by the European Commission as having an adequate level of data

protection (like Argentina, the Isle of Man, Israel, or Switzerland). �e new regulations (laid down particularly in Art. 44 – 50) emphasize that the transfer of data is only allowed if additional requirements are met. Options for transferring data outside the Union include the Consent of the individual (which will be harder to validly obtain), Standard Data Protection Clauses, Binding Corporate Rules (Art. 47), Codes of Conduct (Art. 40) or an accepted Certi�cation (Art. 42). �ere is not enough room here to go into details. Anyhow, the transfer of data in third countries remains a di�cult task and all respective processes should be reviewed in detail in order to be compliant with the new regime. �e legislation of some Member States already comprises similar obligations. However, from May 2018 the obligations are applicable to all data processing by Processors on behalf of Controllers within the extended reach of the GDPR (see above Sec. II 3).

9. Data Security�e obligation of Controller and Processor to implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk is not new. However, Art. 32. Includes more details and measures for data security. Moreover, it establishes the obligation to demonstrate compliance with data security requirements and refers to respective measures like Codes of Conducts and Certi�cations (Art. 40, 42).

In the case of a personal data breach, the controller shall without undue delay and, where feasible, not later than 72 hours a�er having become aware of it, notify the personal data breach to the competent supervisory authority, unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons. Where the noti�cation to the supervisory authority is not made within 72 hours, it shall be accompanied by reasons for the delay. Further details of a breach noti�cation and the obligation to document data breaches are set forth in Art. 33. �e obligation to inform the Supervisory Authority is accompanied by an obligation to inform the individual (Art. 34).

11. Right to be forgotten� e individual shall have the right to obtain from the controller the erasure of personal data without undue delay and the Controller shall have the obligation to erase personal data without undue delay provided that the requirements set forth in Art. 17 are met. � e right to be forgotten or the obligation to erasure does not apply if the processing of personal data remains necessary in relation to the purposes for which they were (lawfully) collected or otherwise processed. Moreover, the right or obligation to erasure particularly does not apply to the extent that processing is necessary for compliance with legal obligations (like applicable tax laws).

12. Data portability� e individual shall have the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where the processing is based on consent or on a contract and the processing is carried out by automated means. In exercising his or her right to data portability the individual shall have the right to have the personal data transmitted directly from one controller to another, where technically feasible (Art. 20).

13. Privacy by Design and by Default� e Controller shall implement appropriate technical and organisational measures for ensuring that, by default, only personal data which are necessary for each speci� c purpose of the processing are processed. � at obligation applies to the amount of personal data collected, the extent of their processing, the period of their storage and their accessibility. Moreover, the Controller shall implement appropriate technical and organisational measures which are designed to implement data-protection principles, such as data minimisation, in an e� ective manner and to integrate the necessary safeguards into the processing in order to meet the requirements of the Regulation and protect the rights of data subjects (Art. 25).

III. Consequences for Remote Gaming OperatorsIn the past data protection law for many operators and their contractual partners has been unpopular and has not been considered intensively. In future, such negligence could become expensive.

As shown above the GDPR comprises fundamental changes for all entities processing data. Since the core business of remote gaming operators is the processing of data it will be crucial to review all processes and to adapt to the new regime. Due to the extraterritorial reach the GDPR does not only a� ect entities in Europe but also Controllers and Processors in third Countries.

� e e� orts to be compliant di� er depending on the current data protection laws in each Member State. Whereas in some Member States many elements (like the requirement for Data Protection O� ers or for agreements between Controllers and Processors) are already laid down in present legislation the changes in other Member States will be tremendous. However, the goal of a real harmonisation has not been reached due to many opening clauses which give the Member States room for deviations.

Considering the amount of obligations included in the GDPR the transition period until May 2018 is short and the GDPR is to be taken seriously.

Frieder Backu is Partner of SSW c ne e c e e e elle

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tec nolo law. He st e law at the universities of Munich an Lon on. ollow n ac ’s studies at university he passed an e cat on as ce t e e e t o ta law an o n o at on

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Relation to Customer

• review privacy notices• review process for obtaining consent and withdrawal

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Need for Action under GDPR

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• appoint Data Protection Officer• review existing and implement new processes (privacy by design, data security, etc.)• prepare documentation

• review agreements with processors• Processor: appoint Data Protection Officer• joint liability

• review process and agreements• Consent, Standard Clauses, Binding Corporate Rules, Codes of Conduct, Certification


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eing a relatively recent development within the gaming and gambling industry, there are elements within the concept of skin gambling which require the

attention of regulators, operators and consumers alike. �is article seeks to discuss the constitutive elements of skin gambling and its prevalence amongst consumers, its place within the de�nition of gambling according to Maltese law and following this analysis, recomendations to the Malta Gaming Authority (MGA).

What are skins?In order to achieve a better understanding of skin gambling, it is pertinent to begin with the origin of the term within the gaming industry. It can be argued that the term ‘skin gambling’ traces its origins to Counter Strike: Global O�ensive (CS:GO), an electronic game developed by Valve Corporation which sees two teams of players earning points by virtually killing players from the opposing team. In order for one team to beat its opponents, players make use of virtual weapons such as AK47s and knives. In order to give the game a personal aspect, players may personalise the weapons used – for instance an AK47 is available in customary black, but players may also spice up their AK47s by making use of a ‘skin’ to have a camou�aged weapon available for use during the game. Skins are cosmetic items that can

be used in electronic games such as CS:GO, having the sole aim of altering the aesthetic appearance of a player’s in-game weapon, gear or avatar. It is worth mentioning that a skin does not improve the power or functionality of an in-game weapon but merely changes its aesthetic appearance.

�ere are various ways for players to acquire these skins. In CS:GO, players are awarded skins in-game whilst playing or through promotional events. �ey can also trade skins with other players through ‘Steam’, an online platform operated by Valve Corporation, third party platforms or purchase skins through available online marketplaces. �e rarer a particular skin is, the more valuable it is.

Another way in which players may acquire these skins is by purchasing keys to unlock cases which contain a quantity of various skins as a prize. �is model could be compared to casino slot machines since the game involves the purchasing of a key for the opportunity to win a number of skins as a prize. Acquired CS:GO skins are added to the player’s inventory on the Steam account.

Skin GamblingLike a casino chip, a skin can serve as a de-facto virtual currency which can be used for gambling purposes. Players may make use of skins acquired in one of the above mentioned methods to bet and place wagers and gamble. Several products allowing skin gambling are available, including roulette, sportsbook

Skin Gambling – A case for regulation in Malta

B

by Alistair Facciol


and lotteries. Similar to the more traditional forms of gambling, players transfer their skins to the particular website o�ering skin gambling products in order to play these kind of games. In the eventuality that the player wins, the winnings given by the website are in the form of additional skins, which the player may then ‘withdraw’ back to the Steam account.

�ere is no arguing that the market for skin gambling is signi�cant. During 2016, it was estimated that $7.4bn worth of skins would be wagered worldwide across a wide spectrum of gambling products.1 However, these estimates are based on studies which do not take into consideration recent events within the gaming industry.

Recent EventsIn the US, the Washington State Gambling Commission (WSGC) was one of the �rst regulators to address skin gambling by taking legal action against Valve Corporation, alleging that Valve violated gambling laws by facilitating the use of skins for gambling via its Steam platform. �e WSGC is requesting the Court to order Valve to take all necessary actions to stop third party websites from making use of skins for gambling purposes through its platform. On their part, Valve Corporation argue that it is not engaged in the promotion of gambling and that it does not in any way facilitate gambling, arguing also that the operation of Steam and CS:GO is lawful under Washington law. Valve Corporation contends that as per its policy,

it sent cease and desist letters to gambling operators, conceding however that operators made use of bots in order to disguise gambling transactions. Proceedings are still under way.

In the UK, the UK Gambling Commission (UKGC) instituted proceedings against Craig Douglas and Dylan Rigby, owners of the website ‘FUTgalaxy’ which is based on the best-seller electronic game ‘FIFA’ developed by EA Sports. FUTgalaxy provides players with the opportunity to make use of the coins earned in FIFA (FUT Coins), which can then be exchanged on the website for the in-game currency FG credits to bet on events. FG credits can also be purchased in real currency. Players earn FUT Coins in FIFA by competing in and winning matches and completing tasks in the game’s Ultimate Team mode. �ese FUT coins earned in FIFA can then be converted to FG credits through FUTgalaxy in order to place bets on real events, a�er which players can convert the winnings back to FUT Coins. �e court heard how Douglas promoted the site to more than 1 million subscribers of his YouTube channel, including minors and speci�cally, how one 14-year-old boy lost around GBP586 in a day. Rigby was �ned by GBP174,000, whilst Douglas was �ned GBP91,000.

In March of this year, the UKGC issued a position paper on virtual currencies, eSports and social casino gaming.2 �e UKGC, dedicating a whole section to

gambling with in-game items and virtual currencies, explains how it is also the video game industry which acknowledges that even though in-game items, such as skins, were provided in a “closed-loop fashion”, “users of their game networks are occasionally exploiting their open nature to o�er players opportunities to buy and sell in-game items”.3 �e UKGC went on to clarify that this ability to convert skins into cash, and the ability to trade such skins for other items of value means that these skins attain a real world value and become “articles of money or money’s worth”.4 (�e UKGC went on to conclude that a licence is required in the same manner as the use of casino chips as a method of payment for gambling requires a license.

�e Isle of Man has addressed the situation by taking measures earlier this year to allow its licensees to o�er betting using virtual currencies, including skins, thereby placing such operators within a regulated framework. Earlier this year, the Norwegian Gaming Authority published a note by virtue of which skin gambling was legally placed within the de�nition of ‘gambling’ a�er reports of minors in Norway having spent considerable sums of money on such games. �e Authority concluded that a gaming site which allowed betting and winnings in skins was e�ectively an online casino, and that operators, apart from the state monopoly Norsk Tipping, faced sanctions if skin gambling were to be o�ered in Norway.

1 C Grove, Narus Advisors, ‘Understanding Skin Gambling’, July 2016.

2 UK Gambling Commission, ‘Virtual Currencies, eSports and Social Casino Gaming – Position Paper’, available at <http://www.gamblingcommission.gov.uk/PDF/Virtual-currencies-eSports-and-social-

casino-gaming.pdf>, accessed 22 March 2017.

3 ibid.

4 (no. 2).

| European Gaming Lawyer | Spring Issue | 2017

Skin Gambling – a Maltese perspectiveMalta’s Remote Gaming Regulations, (the ‘Regulations’), de�ne ‘gaming’ as an “agreement, scheme, or arrangement between two or more parties to play together at a game of chance in which a prize or reward consisting of money or some other item of value, worth, advantage, or opportunity is o�ered or can be won and become the property of the winner under de�ned conditions established for the purpose of the game”.5

�e Lotteries and other Games Act, (the “Act”), de�nes ‘game’ as being a game of chance and/or a game of chance and skill.6 A ‘game of chance’ is de�ned by the Act as “a game for money and, or prizes with a monetary value, the results of which are totally accidental”.7 A ‘game of chance and skill’ is de�ned as “a game for money and, or prizes with a monetary value, the results of which are not totally accidental but depend, to a certain extent, on the skill of the participant”.8 Both the Act and the Regulations prescribe that a licence is required in respect of these two scenarios.

In view of the fact that skins such as those used in CS:GO can be traded or converted into cash by means of virtual marketplaces and platforms, there exists a strong argument in favour of them attaining the status of an ‘item of value or worth’ for the purposes of the Regulations. Furthermore, in light of the fact that some, if not all, of these skins may be converted into cash,

one may also argue that these skins attain a monetary value. Consequently, it follows that websites o�ering skin gambling should require a license to operate as such.

Cases such as that of FUTgalaxy, which is mentioned above, demonstrate that in-game items are particularly attractive to minors who are especially drawn to video games such as CS:GO, FIFA and other similar games. �e UKGC commented in respect of FUTgalaxy that “the defendants knew that the site was used by children and that their conduct was illegal” 9 and how the defendants “turned a blind eye in order to achieve substantial pro�ts”.10 �e court, in this case, described the e�ect of gambling on children as ‘horri�c’ and ‘serious’ leading the UKGC to conclude that licensing websites o�ering skin gambling such as FUTgalaxy was the only way to protect minors and other vulnerable persons.

As has been demonstrated in this article, several jurisdictions are taking o�cial positions and issuing decisions in respect of skin gambling. �e Malta Gaming Authority has not taken a position yet. �ere is therefore a strong case to be made for the Malta Gaming Authority to give due attention to the topic of skin gambling, particularly a�er taking into consideration the e�ects it has on minors and other groups of vulnerable persons. Awareness should be raised and controls put in place to protect minors and vulnerable persons from the risks brought about by skin gambling.

�e Malta Gaming Authority should take the opportunity to place Malta, as a gambling jurisdiction and as one of the leading industry innovators of the past ��een years, back to the forefront of consumer protection and regulation, whilst clarifying the boundaries within which skin gambling providers are to operate.

Alistair Facciol is an Associate at Fenech & Fenech Advocates and has been practicing in the gaming and betting industry since 2011. He holds a Doctor of Laws degree from the University of Malta and is currently reading for a Master in Laws (Computer and Communications Law) degree from the Queen Mary University of London. Alistair is also

i nc d in di nt a as of Intellectual Property and ICT law, especially within the gaming sector and takes keen interest in new and upcoming trends and technologies. He can be reached by email: [email protected]

5 Regulation 2, ‘Remote Gaming Regulations’, SL 438.04 of the Laws of Malta.

6 Article 2, ‘Lotteries and other Games Act’, Chapter 438 of the Laws of Malta.

7 ibid.

8 ibid.

9 (no. 2).

10 ibid.

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he Present Market One of the most prevailing Swedish myths is that the public Swedish gambling monopoly is designed to limit gambling and thereby prevent

detrimental public health e� ects. Nowadays, there is an overwhelming consensus that, during the last 20 years or so, there has never been a true public ambition to limit gambling. Back in the days, the marketing budget of the state-controlled gaming services o� ered by Svenska Spel and ATG reached new heights every year and the range of products o� ered grew broader and broader. � is market strategy still prevails. � e Government policy came to create a culture of gambling. � is culture together with a world class level of internet penetration (well over 90 percent), a � ourishing climate for tech innovations, access to venture capital and a lenient stock market, were to set strong incentives for the establishment of highly successful private gambling operators such as Betsson, Unibet and many others, all established abroad targeting Swedish customers. � ese companies are founded, run and owned by Swedish privates and corporations. Today, Sweden is one of the most competitive online gambling markets in the world.

Gambling companies licensed or authorized elsewhere within the EU can more or less freely pursue an Internet-based gambling business on the Swedish market. Swedish authorities acknowledge that Swedish residents are unimpeded to participate in foreign gambling and that online gambling operators duly licensed or authorized in another EU member state are allowed to o� er such services.

Moreover, the Swedish Government has expressed that the Lotteries Act does not have exterritorial application. Hence, Swedish authorities lack jurisdiction to enforce the Lotteries Act to undertakings and individuals outside of Sweden.

Gambling services can consequently be o� ered cross border to Swedish customers without violating Swedish law. Also, the room for maneuver for marketing and promoting activities that target the Swedish market is extensive. Marketing through cross border-media such as television commercials and web marketing is legal. Given the inherent limitations of the system for administrative and criminal sanctions, sponsoring of sports events and other commercial marketing co-operations could be carried out without risk of sanctions, if structured properly. � e only remains of the public monopoly is the marginalized and circumvented marketing prohibition. Hence, globalization, market practice, internet penetration and political passivity have made the current legal regime obsolete and created a fairly liberal market for online gaming in Sweden. However, this situation might be over. For the third time the Swedish government have taken the initiative to regulate the market.

Introduction Of LicensesFor the � rst time in 20 years there seems to be a broad political consensus to regulate the market by introducing a licensing system for predominantly online gaming. � e Inquiry on the Re-regulation of the Swedish gaming market (SOU 2017:30) published its comprehensive report on March 31.

The Re-Regulation Of The Swedish Gambling Monopoly

T

by Dr. Ola Wiklund


� e proposed licensing regime covers a broad spectrum of gambling products: online casino, online betting, online poker and online bingo. Land based sports betting and land based horse-race betting will also be included in the licensing regime. Lotteries and land based slot machines will remain monopolized. � ere will be a 18% tax on the net gambling revenue. No payout ceiling on wins is recommended.

A license will allow private online gambling companies, Svenska Spel’s and ATG to operate on the competitive section of the market. It is proposed that ATG no longer have a monopoly on horse race betting. � is will open up for competition from other operators that o� er horse race betting. Like other gambling companies, ATG will have access to the competitive gambling sector on the same conditions and become a licensee like others.

Svenska Spel’s exclusive rights will cover token gaming machines and land based casinos in designated premises – Casino Cosmopol. � e company will also have to continue to compete with the public interest associations with respect to online and land based lotteries. According to the Inquiry’s proposal, the future competitive section (Svenska Spel K) will get licenses that will cover online and land based sports betting, online casino, online poker and online bingo.

� e Inquiry’s proposal will include horse race betting in the licensing system and in the competitive section. � is means that ATG will become an operator like any other private gambling operator. � ese gambling companies may enter into agreements with the harness and horse racing organizations that own the courses and other infrastructure. It is proposed that the Government withdraw from its involvement in ATG and equestrian sport in the form it has hitherto had.

� e Inquiry proposes a tax rate of 18 per cent on gambling in the competitive sector. � e tax rate is to be calculated on net gambling revenue, i.e. the company’s pro� t a� er paid winnings. � e Inquiry hopes that through a tax rate of 18 per cent and a regulation that does not entail an excessive administrative burden, at least 90 per cent of the competitive market will be channeled into regulation.

� e Inquiry proposes that in principle all gambling companies pay a license and supervision fee. � e fees are based on the companies’ turnover and the number of games involved. � e license fees in the competitive area vary from SEK 60,000 to SEK 700,000 and the annual supervision fees in the same area are between SEK 30,000 and SEK 1 million.

All gains from wins that stem from unlicensed operators will be taxed as income. � e Inquiry thinks that this will deter consumers to gamble on unlicensed sites.

An e� ective system of sanctions is a prerequisite for the sought channeling e� ect. A number of criminal o� ences are introduced. A party that intentionally or through gross negligence provides (in Sweden), arranges (in Sweden) or otherwise facilitates (in Sweden) participation in gambling for a person resident or permanently staying here without a license when this is required under the Gambling Act shall be sentenced for unlawful gambling activities to a � ne or imprisonment of at most two years. If the crime is gross, the penalty is imprisonment of at least six months and at most six years.

For the promotion of illegal gambling, i.e. a breach of the promotion ban, the Inquiry believes that the range of punishment should be signi� cantly raised in relation to what is applicable today. It is proposed that the range of punishment be the same as for the principal o� ence, i.e. from � nes or imprisonment of at most two years or, if the crime is gross, imprisonment of at least six months and at most six years.

If a gambling company that has a


Swedish gambling license violates the Gambling Act, regulations or conditions issued by virtue of the Act, a sanction charge shall be imposed in the � rst instance. � is can vary between SEK 5,000 and SEK 50 million. � e sanction charge may not exceed ten per cent of the company’s turnover in Sweden.

It is furthermore proposed that internet service providers be required to display a warning message when a visitor attempts to play on illegal sites. � e message shall inform the visitor that the game provider does not have a license in Sweden and is not under Swedish supervision.

� e Inquiry does not propose the blocking of electronic communication to sites o� ering games that are not legal in Sweden. However, it is proposed that the blocking of payment transactions between illegal gambling companies and players should be considered. For reasons of competition, this should be introduced simultaneously by all concerned parties or payment transfer providers. � e provision of payment transfers to and from unlicensed operators will be criminalized with a range of punishment from � nes or imprisonment of at most six months.

A new crime classi� cation will be introduced, the o� ence of cheating at gambling (match-� xing and other types of manipulation of the outcome of a game). � e o� ence shall be able to be imposed with a prison sentence of at most two years. If the o� ence has been committed intentionally and has been conducted systematically or on a major scale or has otherwise been of a particularly dangerous nature, it is classed as gross, resulting in imprisonment of at least six months and at most six years.

Apart from these sanctions the Inquiry introduces a number of additional burdens on operators: most notable are marketing restrictions and a wide arsenal of player responsibility provisions to be complied with.

Analysis � e Inquiry is rather brash when it comes to the stated � nancial purpose of the proposed bill and highlights that cross-border gambling companies represent a market share of approximately 23 per cent and their market share is increasing and that the � � een online gambling companies publicly listed in Sweden represent a market value of SEK 69 billion (SEK 11 billion in 2011). � e Inquiry wants to bring some of these pro� ts to the state-purse:

“� is re� ects the large pro� ts made by these companies and the market’s even greater expectations. Few online companies have as great pro� t margins as the online gambling companies. In 2016, the net turnover of the online gambling companies un-regulated in Sweden was SEK 5.1 billion. � e motive of central government to re-regulate the gambling market is to gain control over this part of the market through regulating and licensing. � is involves issues regarding taxes, gambling responsibility and consumer protection.”

To ensure that a large share of these revenues end up in the state purse the Inquiry uses war rhetoric to underline the purpose of the proposed legislation:

“� e proposed re-regulation mobilizes a large part of central government’s combined arsenal of legal, economic and administrative measures in order to take control of the gambling market and of conditions in which the old Act has become increasingly unmodern.”

� e Act is a product of political pressure to quickly produce new legislation for the purpose of transferring private pro� ts to the state purse. � is has in� ated the pressure on the Inquiry. In volume the Report amounts to one of the biggest bureaucratization of a market in modern time. One could question whether this bulk of new legislation really re� ects the demands of the market.

In the case of Framework laws such as the new Gambling Act, constitutional

requirements of predictability and legality is neglected when timing is vital for political gains. � is re� ects the Governments fear of losing timing. A� er three dropped balls the market’s con� dence in the politicians is at an all-time-low. If the political momentum is lost the bill is likely to fall.

� e result of the Framework law might well be a discrepancy between what is considered politically necessary and, on the other hand, what is feasible in terms of available resources. � e proposed vast criminalization and sanction arsenal would require that huge new resources are transferred to police, prosecutors and the courts. And without proper enforcement against unlicensed operators the licensing regime amounts to a high risk project for the licensees. Moreover, large new burdens regarding player responsibility, marketing and administrative liabilities are laid on the licensee. But the greatest risk for the operators come with the chosen legislative vehicle.

A Framework Law has to be � lled out and completed through regulations by the government and the administrative authorities such as the new Gaming board (Spelmyndigheten), or by court practice. In the Act we � nd a number of indeterminate and vague objectives to be achieved, and the general principles to be respected in the enforcement of the law. � ese vague provisions must be � lled with the standards of more tangible impact if they are to be meaningful. When you leave this wide discretion to the courts and authorities it creates legal uncertainty and sharply divergent court practice. � e father of the Report, Håkan Hallsted, label this � exibility.

A prevailing fear is that the state controlled companies will use the time lapse between the publication of the Inquiry’s proposal and its coming into force to abuse their dominant position on the market. ATG is already trying to

hurt competitors through abuse of its dominant position on the horse racing-market. Moreover, since Sweden hasn’t recovered from the hang-over of the vast privatizations of the 1990s the politicians might be reluctant to privatize Svenska Spel (K). In the mean time Svenska Spel is likely to use its acquired political leverage to further abuse its dominant position in a similar way as has been the case in France and Denmark.

Last but not least, if the Swedish government fails to negotiate a tax exemption with the EU Commission for the vaguely de� ned non-pro� t sector according to the EU-state aid rules the proposal is likely to fall. � e reason is

that the ruling Social Democratic Party is mainly funded by an entity of the sector.

Hence, for the market actors that seek foreseeability, legality and predictable business conditions the Inquiry’s proposal presently seems rather fragile. � e operators and service providers of the market should prepare for a bumpy road ahead.

Dr. Wiklund has been legal counsel for major online gaming operators since 2003. His sector expertise ranges from commercial and regulatory to M & A. He’s giving strategic regulatory and commercial advice to global corporates in the sector. He’s the head of Hansen Law’s Malta offi ce. He has also acted as counsel in proceedings before the European Courts in Luxemburg and has represented clients in the European Commission and the Swedish Competition Authority.

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n 1st November 2014, the day on which the Gambling (Licensing and Advertising) Act 2014 came into force, all gambling operators with facilities capable of being used in

Great Britain were required to hold a licence from the UK Gambling Commission (the Commission). Since that day, many of the operators that wished to continue to operate in the lucrative UK market have succeeded in bearing the additional regulatory burden – some choosing to merge with competitors in order to consolidate operations, and others piggy-backing on third party licences through turnkey white label solutions. However, two years on, the Commission is consulting on its enforcement strategy and spurring further change within the sector. But, why is change still needed, and what else do operators need to do to comply? In this article, Gemma Boore discusses the new enforcement regime, the reasons why it is being introduced, and its implications for the sector.

Why is change needed?It’s undeniable: the UK gaming industry is under serious scrutiny. 2017 sees the sector in the midst of three ongoing investigations. � e UK’s Department of Culture Media and Sport (DCMS) is undertaking a

review of gaming machines and social responsibility measures, the Competition and Markets Authority (the CMA) is investigating whether operators are treating their customers fairly, and the Information Commissioner’s O� ce (ICO) is targeting more than 400 companies that it believes to be illegally using people’s personal details to promote gaming sites. To top it all o� , businesses operating in the sector also need to consider the implications of the transposition of the 4th Anti-Money Laundering Directive on current operations, work out how best to deal with the changes to the treatment of ‘free plays’ for remote gaming duty purposes later this year, and keep on top of possible changes to the VAT regime. Rather a lot to be considering on top of the usual operational concerns…

� e gaming sector is however, not alone in its plight. Ticket reselling (or ‘ticket touting’) businesses are facing investigations from both the CMA and Her Majesty’s Revenue & Customs, the energy market is under scrutiny as ministers condemn suppliers’ price hikes, and the UK’s � nancial watchdog, the Financial Conduct Authority, is reviewing the £2.7bn peer-to-peer crowdfunding sector for the second time in two years following widespread concerns over whether consumers who lend and invest money on such platforms truly understand the risks.

Gambling on Great Britain: future changes to enforcement

practices in the UK

O

by Gemma Boore


As many will have noticed, the common theme amongst these ongoing investigations is treatment of the consumer. Since the introduction of the Consumer Rights Act in October 2015, there has been an increased focus on industries that are deemed not to be at the frontline of consumer protection, and the gaming industry is � rmly amongst them. � e reasons for this are readily apparent. According to the Advertising Standards Authority, remote operators are routinely amongst the top ten worst o� enders for spamming and last year, the Commission received over 40,000 emails and nearly 37,000 phone-calls from the public concerning the activities of gambling-related companies, representing “well over 300% [increase] on the last two years”.

� e in� ux of complaints has not goneunnoticed, and the Commission is now insisting that the sector does more to put the consumer � rst. It has been instrumental in working with DCMS, the CMA and the ICO in their respective investigations and, in her recent public addresses, CEO Sarah Harrison has repeatedly told operators that consumer protection should be their priority. In particular, at the Raising Standards conference in November last year, Harrison suggested that, although the sector is moving in the right direction, the pace of change needed to quicken to bring it into line with consumer-facing businesses in, for example, the � nancial services and retail sectors. Her core message was that organisations need to take steps now to prevent events akin to the banking crisis and the Volkswagen emissions scandal occurring and damaging public trust. As Harrison put it: “Don’t wait for a crisis to happen that shakes the very foundation of customers’ trust in your industry: act now

and demonstrate to consumers that your interest in their needs is genuine”.

So, what needs to be done?� e Commission’s message is that, ultimately, the industry needs to increase the trust and con� dence that consumers have in gaming. Not only should customers be able to get the best prices and the best experience gambling online, but they should also be well informed,treated fairly and kept safe - in particular those who are vulnerable to the risks and realities of gambling-related harm.

In order to achieve this, the Commission has advised licensees to assess, amongst other things: their social responsibility, how fairly they are treating customers and their anti-money laundering practices.

1. Social responsibility� e Commission wants the sector to review its social responsibilities and take measures to achieve them. At last year’s Responsible Gambling Trust conference, Harrison set out � ve initiatives that the Commission would look for from the sector:• Clarity of purpose – is the work operators

are doing on social responsibility aimed at preventing harm – or just dealing with it where it is already occurring?

• Evaluation – how will sector assess the impact of measures and share � ndings?

• Added value – are operators doing the minimum, or taking their responsibilities further?

• Customer focus – are businesses considering every aspect of the customer journey?

• Transparency – will operators take stakeholders with them, and be open about the inputs to their work, as well as the conclusions and actions?

2. Treating customers fairly� e Commission wants licensees tomove focus away from the bottom lineand take a more customer-focussedapproach. � e in� ux in customercomplaints over the past 12 monthsdemonstrates that there are seriousissues to be addressed and, althoughsome of these issues will be consideredduring the DCMS, CMA and ICOinvestigations, the Commission wantsto see the sector step up and drivestandards now. A further review ofcurrent practices and requirementswith regard to complaint processes isalso planned, so operators would bewell advised to take a proactive stanceand ensure adequate policies andprocedures are in place before thereview commences later this year.

3. Money launderingMoney laundering has been an areaof concern in the sector for years.However, Harrison revealed that theCommission’s recent casework intoAML standards showed “a lack ofcuriosity, and at worst, a leadershipculture which puts commercial gainover compliance”. � e Commissiontherefore wants licensees to adopt amore risk-based approach and stopwaiting until a source of funds is provento be illegal before taking action.

Sharpening the regulatory toolkitIn order to regulate existing licensees more e� ectively and reprimand entities that knowingly � aunt the licensing objectives, the Commission is consulting on proposed changes to its enforcement strategy. � e consultation paper

| European Gaming Lawyer | Spring Issue | 201

(released in January 2017) sets out proposals for how the Commission will ‘sharpen’ its regulatory toolkit to encourage a faster pace of improvement within the sector. As well as emphasising the Commission’s expectations in terms of operators putting consumers � rst, the proposed changes will a� ect four of the Commission’s guidance documents.

1. Statement of Principles for Licensing and Regulation� e statement of principles for licensingand regulation sets out the principlesthat the Commission applies whenexercising its regulatory functions.Of note, the Commission has revisedparagraph 2.7 so, in future, it will onlyensure not to impose “unnecessary regulatory burdens” in upholding thelicensing objectives: a lesser requirementthan the current statement, which requiresthe Commission to impose the minimumburden necessary. Wording in paragraphs4.5 and 4.6 that previously suggestedthat, although the Commission wouldcommence investigations in connectionwith complaints, it would not necessarilyconduct licence reviews, has also beenremoved. Indeed, all references to“voluntary settlement” have beenreplaced with “regulatory settlement”(as the Commission considers that thesewords more accurately re� ect the processand outcome of negotiationsin enforcement proceedings) and therevised statement is clear that, goingforward, methods that stop short offormal licence reviews (such as thenewly named regulatory settlements)will only be considered in “certain, limited, circumstances”.

2. Licensing, Compliance and Enforcement under the Gambling Act 2005: Policy Statement� e policy statement is intended to beread in conjunction with the abovestatement of principles and sets outthe Commission’s regulatory policiesin relation to assessing risk, licensingoperators and key personnel, carryingout compliance activities and regulatoryand criminal enforcement. � e keychanges are concentrated on chapter� ve (which has indeed been renamed“Regulatory enforcement” instead of“Dealing with non-compliance”) and, inessence, communicate the Commission’srevised approach - in that it will moveaway from entering into settlements withnon-compliant licensees as a matter ofcourse and move back to a position whereit has discretion on how to approachinstances of non-compliance, includingby way of licence review. � ere is newguidance on revocation of approval for testhouses where there are repeated failingsby an approved test house to prevent non-compliant products entering the marketand the revised statement also clari� es that,even where a licensee surrenders its licencewhilst a licence review is under way, theCommission may nonetheless continue itsinvestigation and publicise the results.

3. Statement of Principles for determining Financial Penalties� e statement of principles for determining� nancial penalties sets out the principlesthat the Commission applies when it usesits powers to require licence holders topay � nes. � e amendments proposed inthe consultation clarify that (a) � nancialpenalties can apply to both holders of

operating licences and holders of personal licences, and (b) the statement of principles will apply both where the Commission exercises its powers to impose a � nancial penalty and when the Commission accepts a payment in lieu of a � nancial penalty as part of a regulatory settlement.

� e list of matters that the Commissionwill consider when determining whether to exercise its powers has also been expanded, to include (i) whether the breach is an example of repeat behaviour, (ii) whether the Commission haspreviously publicised its investigationsin connection with similar cases with theintention that lessons should be learnedby the industry, and (iii) the timeliness ofany admissions being made by the licenseeand actions taken to remedy the breach- with the intention being to encourageearlier disclosure of relevant facts, andadmissions, during the investigationprocess by giving more credit (and reduced� nes) to licensees making such disclosures.Further amendments also seek to ensurethat, conversely, heavier penalties will beimposed on repeat o� enders who showfailures to report breaches, take remedialactions, or learn from their mistakes goingforward, and there is new guidance onhow monies obtained from regulatorysettlements (which do not need to be paidinto the Consolidated Fund – essentiallythe UK Government’s general bankaccount) will be deployed.

4. Indicative Sanctions Guidances� e indicative sanctions guidance is a newdocument introduced by the consultation,which sets out a framework for decision-making about regulatory enforcement and

European Gaming Lawyer | Spring Issue | 2017 |

Gemma Boore is a corporate and commercial associate at Bates Wells & Braithwaite London LLP with a specialist interest in the regulation of gaming, betting and gambling. Gemma speaks frequently at industry events and, on a day to day basis, handles a broad range of corporate and commercial transactions for both start up and established tech companies including mergers and acquisitions, fi nancing and commercial advisory work.

the possible � nancial and other sanctions that could apply. Of note for potentially uncompliant licensees, it sets out clear criteria for determining the amounts of � nancial penalties and settlements – including by applying discounts to the � nancial penalty element of a � ne where licensees have made early disclosures, made admissions, and cooperated with the Commission’s investigations.

� e consultation paper contains moredetail on the Commission’s proposals and interested parties are invited to respond in writing by 21st April 2016 using an online form. If you or your clients intend to submit a response to the Commission in connection with this or any other matter, you should consider taking proper advice on the implications of the proposed amendments on your business and/or liaising with other representatives in your sector to submit a joint response.

The FutGalaxy saga� e amendments proposed in theconsultation paper have yet to takee� ect, but as the following case clearlydemonstrates, the Commission is notgoing to hold back from pursuing theprosecution of unlicensed o� enders,particularly where their activities arepresented as real gambling products,involve a stake or are aimed at children.

� e Commission’s recent actionagainst Craig Douglas, aka NepentheZ, and co-defendant Dylan Rigby (which is covered in more detail elsewhere in this journal) has been cited as the most serious case investigated by the Commission to date and is likely to be a sign of things to

come. � e prosecution centred on the o� enders’ operation of www.FutGalaxy.com, a website which allowed its customersto buy virtual currency called FUT coinsand use them to gamble on a variety ofproducts including sports betting, a jackpotstyle lottery game, and a ‘higher or lower’style game. FUT coins could also beconverted into FIFA coins, which couldin turn be sold for real money. Evidencepresented during the trial included a videoof Douglas on his YouTube channel sayingto the camera: “You don’t have to be 18 forthis, because this is a virtual currency”.In other words, the defendants encouragedchildren to use the site in order to gamble.� e Commission was successful in itsprosecution and Judge Jack McGarvaordered Rigby to pay £174,000 in � nesand costs, whilst Douglas was orderedto pay £91,000

ConclusionSince the introduction of point of consumption regulation, the Commission has faced an astronomical increase in the number of licensees subject to its remit. It has therefore pooled its resources by bringing potential issues to the attention of watchdog organisations and government departments, such as DCMS, the CMA and the ICO, resulting in a plethora of investigations into all di� erent types of activity in the sector, along with a consultation on how best to take action against operators that don’t conform to the new norms. In summary, the increased scrutiny into market practice is not a passing phase and, in this author’s opinion, the scope for future reviews seems likely only to expand. Businesses operating in the sector will do well to take a step

back now and consider how their current practices appear to ‘Joe Public’, what e� ect their operations might have on children and other vulnerable people, and what steps they can take to prevent harm before it happens. If the industry keeps looking through a prism of self-interest and doesn’t take steps now to put the consumer � rst – it will face the consequences.

7-8 June 2017Villa Rosa Kempinski

Nairobi, Kenya

wrbriefing.com/africa I #WrBriefing

Global knowledge withlocal connections

European Gaming Lawyer | Spring Issue | 2017 |

peaking at a Parliamentary All Party Betting & Gaming Group seminar on 29 March 2017, Sarah Harrison, CEO of the Gambling Commission, encouraged gambling operators to

build businesses highly focused on consumers, aiming not just for consumer enjoyment but also consumer trust. On the same day, the Commission published a review, “Complaints processes in the gambling industry (March 2017)”, the foreword to which makes clear that e� ective handling of consumer complaints is a key element in building this consumer trust.

European regulations on alternative dispute resolution (ADR) came into e� ect in October 2015. � ese tasked the Gambling Commission with responsibility for certifying ADR providers in the British gambling sector. � e Commission is now reviewing the impact the regulations have had and taking the opportunity to look more generally at complaints procedures across the gambling sector.

� e Commission’s proposals and areas of focus for further consultation cover not just what the Commission will expect from gambling operators and ADR providers, but also ways in which the Commission itself can more e� ectively put in place rules and standards to support those operators and providers.

In particular, the Gambling Commission is challenging operators to “take complaints more seriously by operating complaints procedures that are genuinely accessible and that give consumers trust that their concerns have been listened to and acted upon in a timely way”. � e Gambling Commission also states that it wants to make it easier for consumers to make complaints.

A wider range of disputes to be subject to ADR? As the Commission notes in its review, ADR providers can look only at disputes relating to the outcome of gambling transactions. � e Commission’s view is that this includes disputes related to the application of bonus o� ers, account management, or the ability to access funds and winnings, since those are all part of the overall gambling transaction.

However, the ability of ADR providers to adjudicate on these disputes can be complicated where the operator has suspended or closed the customer’s account because of AML/problem gambling concerns.

� e Commission is concerned that the ADR process may be frustrating for consumers, because their complaints may not be resolved for long periods, and the consumer may be le� in the dark regarding the progress of their dispute.

Consumer complaints in the gambling industry: the Gambling Commission expects

more from operators, ADR providers and the Commission itself

by Stuart McMaster and Nicholas McVeigh

SStuart McMaster

Nicholas McVeigh


�e Commission has therefore indicated that it will look at this area further, to see whether it is possible for better information to be provided to consumers, and whether ADR providers can adjudicate on some aspects of a dispute notwithstanding the fact that there may be some form of investigation taking place.

�is is a very di�cult area, because of the fact that it is a criminal o�ence under the Proceeds of Crime Act (POCA) to tip o� a customer if a suspicious activity report has been �led about him. In these circumstances the POCA regime means that a suspicious-but-innocent customer will inevitably be le� frustrated.

Gambling operators: emphasis on data and information requirements�e Commission is concerned that the data it receives from operators about their complaints is not always accurate. It therefore intends to improve its instructions to businesses about how and when to send the Commission their data. E�ective use of data to improve consumer protection was an area of focus at the Parliamentary seminar on 29 March 2017, not only from the UK perspective but also for the representatives who attended from the Netherlands and Maltese regulators. Operators are encouraged to collect data e�ectively not just because it could be useful to the regulators, but also because it can help operators identify areas where they can improve their customers’ experience.

�e Commission is also going to consider whether businesses should be providing more information to consumers in their complaints policies and making them more visible (i.e. having them as a standalone document rather than something which is included within the operator’s general

T&Cs). To make the process of bringing complaints easier, the Commission will introduce the use of “Resolver”, an independent online tool that supports customers in raising complaints (including by providing templates which consumers can use to make their complaints) and is already used in a number of other sectors. �e Commission will need to provide information to the Resolver tool so that it can help route complaints correctly to either an ADR provider, or the Commission, as appropriate.

ADR providers: consistent standards needed�e ADR regulations do not prescribe gambling-speci�c standards and as a result decision making standards can vary across gambling industry ADR providers. �e Commission will consider setting out a framework of requirements for providers in the gambling sector. In addition, the Commission is going to consider reducing the number of approved ADR providers (the Commission appears to have taken particular account of the fact that in many other sectors there are only two or three approved ADR providers). �e framework would include standards around customer service, decision making and supporting the gambling industry.

The role of the Gambling Commission To supplement the measures proposed in relation to operators and ADR providers, the Commission will make it clearer (on its website) what it does with the information it receives from consumers and what actions it might take in response. It will also make clearer which complaints an ADR provider can look at, and look at other ways to help consumers understand where to get help.

Next steps�e Gambling Commission aims to introduce its proposals from mid-2017, starting with providing information to Resolver so that consumers can use this tool to make complaints. Other proposals will be rolled out during the rest of 2017 and in the “next few years”; in areas where consultation is required, implementation may take longer. �e �rst step will be collecting feedback from consumers on the proposals.

�e Commission’s review paper and Sarah Harrison’s statements at the March 2017 Parliamentary seminar make clear that the Commission does not want gambling operators to focus merely on meeting their regulatory and legal requirements in respect of ADR (or indeed any area of consumer protection). It wants to see industry participants focusing on what is best for customers and aspiring to excellence in handling complaints.

Stuart McMaster is a partner in Mishcon de Reya LLP’s Betting & Gaming group. He advises on M&A transactions and gambling regulatory issues. E: [email protected]

Nicholas McVeigh is a Managing Associate and Professional Support Lawyer in Mishcon de Reya LLP’s Corporate department and Betting & Gaming group. E: [email protected]

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IMGL Autumn ConferenceSEPTEMBER 10-12 • Copenhagen, Denmark

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2 0 1 7 S C H E D U L E

2 0 1 7 C O N F E R E N C E S

Visit the IMGL website for all of the latest event information as it is added. For information on sponsorships or speaker opportunities for IMGL conferences, contact Morten Ronde at [email protected].

For additional information on any upcoming events, contact Sue McNabb, Executive Director at [email protected].

APRIL 26-27 IMGL Masterclass at GiGseSan Diego, California

JUNE 9-11IMGL Masterclass at NCLGS Denver, Colorado

JULY 11-14IMGL Masterclass at iGaming Super ShowAmsterdam, the Netherlands

OCTOBER 31-NOVEMBER 1IMGL Masterclass at EiGBerlin,Germany

NOVEMBER 21- 22 IMGL Masterclass at EEGSSo�a, Bulgaria

I N T E R N A T I O N A L M A S T E R S O F G A M I N G L A W

EVENTS IN 2017

IMGL Autumn ConferenceSEPTEMBER 10-12 • Copenhagen, Denmark

V I S I T I M G L O N L I N E AT I MG L . ORG

IMGL Spring ConferenceMAY 10-12 • Turnberry Isle, Miami, Florida

2 0 1 7 S C H E D U L E

2 0 1 7 C O N F E R E N C E S

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