Proposed structure of the EUROMAT response to the ... - Jogo Remoto

European Gaming and Amusement Federation
Europäische Verband der Unterhaltungsautomatenwirtschaft
Fédération Européenne des Jeux et d'Amusement
Question 13: Are players' accounts a necessary requirement for enforcement and player
protection reasons?
We refer to EUROMAT’s statement of principles and believe that existence and proper audit of
players' accounts are necessary to achieve the equivalent player protection which is achieved
through non remote provision of gambling services. Players’ accounts are – prima facie – the only
means of proper enforcement and player protection.
By way of example, players’ accounts are required in both Denmark and Romania. In the latter a
player must provide at least the following information: name, surname, citizenship, place and date
of birth, address of domicile, personal number (CNP), valid e-mail address, number and series of
their legal identification document, and details of the personal bank account to be used for any
transfers to/from the game account opened with the respective gambling organiser.
Question 14: What are the existing national rules and practices relating to customer verification,
their application to on-line gambling services and their consistency with data protection rules?
How do you assess them? Are there specific problems associated with customer verification in a
cross-border context?
National rules and practices relating to customer verification are an integral part of the provision of
land-based gambling services and EUROMAT is of the view that all forms of gambling service
providers, regardless of the distribution platform they choose to use, should be obliged to adhere to
the same rules. This is, however, clearly not the case as regards remote gambling.
By way of example, in neither Poland nor Bulgaria (where remote gambling operations are still not
regulated), are there any legal obligations in this regard on the remote gambling sector, where the
operator is the one to propose the verification or data protection system. Conversely, the landbased
gaming sector is subject to strict identification and data protection rules, among others.
In Romania, players of online games can register:
directly by accessing the website of the gambling organiser, in which case the player must
also supply to the gambling organiser a copy of legal identity documentation, namely:
1. for citizens who do not belong to any of the Member States of the European
Union: passport, diplomatic or consular identity card, temporary permit;
2. for Romanian citizens or citizens of a Member State of the European Union:
identity book/card or other documents issued by the police authorities, which
bear a photo and the signature of the holder.
At any of the premises where a gambling organiser who holds a licence and authorisation for
online gambling games in which case the player must present to the gambling organiser one
of the legal identity documents mentioned in point above, in original form.
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