18 Sep Italian online gambling 🎰 shall become offline to survive 📈?
The Italian online gaming market is forced to change its traditional way of doing business in order to survive, following the gambling advertising ban.
I had discussed in several instances about the Italian gambling advertising ban and the potential challenges that can be raised against it. Since operators can offer their games only through remote channels of communication, the ban is actually preventing them from running their business since they cannot inform customers about their games.
However, among the limited offline activities that online gaming operators can perform, there is the possibility to contract players and sell vouchers to top-up their gaming accounts.
How to contract players offline
In the contracting of players, tobacco shops, bars and newspapers shops would just have players executing the gaming account agreement and collect from their the copy of their IDs. Such material would then be sent to the operator according to the terms to be agreed between the parties.
It is important that such shops only support players in the opening of the gaming accounts and do not do it for them, since otherwise the conduct might be challenged as an illegal intermediation in the offering of gambling. Indeed, the best solution would be to have a PC where players can register themselves.
What are vouchers and when can they be sold?
Vouchers are just like top-up cards that can be purchased in cash or through electronic payment means at shops and then redeemed on the website. They are quite popular in Italy since players like cash and do not trust electronic payment means.
The main issue around vouchers is that they are anonymous payment means. Therefore, according to the draft guidelines on anti-money laundering of the Italian gaming authority, they can be used only by players that already sent the copy of their ID to the operator. This makes such activity quite strongly linked with the one of the previous paragraph since shop assistants might also collect the copy of players’ IDs.
In any case, according to the draft guidelines on anti-money laundering referred above, they are considered a high risk payment means and therefore they require the implementation of indicators of suspecious activities.
How can it live with the gambling advertising ban?
As previously discussed in relation to social gaming, the offline contracting of players and the sale of vouchers are part of the activities regulated by the license. Therefore, in my view, they cannot fall under the gambling advertising ban. However, clear guidelines shall be adopted in order to avoid that this is considered as an indirect gambling advertising and therefore to protect operators from potential challenges.
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