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New Italian AML obligations arise for Italian gaming operators from the draft guidelines issued by the Italian gambling authority. As previously discussed, after the adoption of the 4th AML directive in Italy, there had been a number of concerns for their impact on gaming operators. These concerns were meant to be clarified by guidelines from the Italian gambling authority whose first draft is now available and it provides for the obligation on both land-based and online operators to run strict checks on players based on
- the type of game,
- their location,
- the behaviour pattern and
- the impossibility or difficulty to identify them.
These same stringent checks shall be performed in relation to land-based games with reference to distributors and gaming hall/betting shop managers, also running trainings on the personnel that is in charge of performing anti-money laundering checks on players.
In particular the guidelines provide clarification on the following topics:
1. AML Identification of players on online gaming platforms
At the time of the registration, operators shall only collect all the information provided by the gaming account agreement issued by the Italian gambling authority, while no simplified registration as the so called “fast registration” is allowed.
This provision does not clarify whether players’ IDs have to be collected at the time of the registration which was one of the main concerns arising from Italian law implementing the 4th AML directive.
2. Identifiers of anomalous behavior
Operators shall put in place systems able to detect unusual behaviors based on both financial criteria such as the amount of deposits and withdrawals and the timing of performance of unusual activities such as the frequency of deposits/withdrawals in a time window.
These identifiers shall also consider circumstances such as an anomalous concentration of winnings and losses during a period of time, especially in relation to games where there is interaction between players.
Also, with reference to sports betting and horse betting, it is necessary to be able to connect data in order to identify potentially fraudulent behaviours.
3. Any payment means can be “traceable“
The Italian law integrating the 4th AML directive provided that only “traceable” means could be used to perform payments on online gaming platforms. This provision had created concerns in relation to anonymous payment means such as vouchers and scratch cards.
The guidelines provide that these payment means can be used, but only after the receipt by the operator of a copy of the player’s ID which is the same requirement currently provided by Italian gaming law.
As a further safeguard, the guidelines require that operators need to monitor the frequency of usage of vouchers by players and the ration between the total amount of deposits and those performed by means of vouchers.
4. New obligations and new tests for VLTs
The decree implementing the 4th AML directive already provide for specific obligations in relation to VLTs, but the guidelines are more specific on the traceability and identification obligations applicable to VLTs.
The changes impact also on the technical features of machines since they need to be able to identify anomalous behaviors and provide that information to gaming hall manegers. This is why machines need to be submitted for verification of compliance with the new requirements by the 4th of July 2018 and be in place by 31 March 2019.
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