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
In Hungary, gaming machines outside casinos can only be operated with a control device, which
records the movement of counters, the process of the game, the opening of the door of the
machine, etc. In bigger gaming halls, there is also a video control system. However, a different set of
rules with regard to money laundering applies to the casino sector. There are no money laundering
rules applied to the remote gambling sector.
In the Netherlands, anti-money laundering principles fall within the scope of the Dutch “Unusual
Transactions Law” which sets the obligations for casinos to report all unusual financial transactions
(which are officially identified by the Ministry of Finance) to a special agency of the Ministry of
Finance when there are certain indicators. As online gambling is still not legal in the Netherlands, in
2007 the Ministry of Justice officially indicated that banks and credit card companies should not
process payments from and to illegal online gaming operators. There are however no official
regulations which force the financial institutions to do so.
In Poland, during the licensing process, companies, owners, board members and the supervisory
board are subject to additional scrutiny (by Tax Control Office, Internal Security Agency, Police and
Courts). Internal financial cash flows are controlled on a daily basis and bank account information
must be disclosed for all licensing procedures.
In Romania, if there are any suspicions, before transferring the winnings to the player's bank
account, the operator can, within 10 days, carry out tall necessary verification and then decide to
make the transfer or notify the competent bodies. The operator should not allow any transfer of
money, impulses, chips, etc. between players’ game accounts. A sum of money can only be paid by
the gambling organiser to the player to the same bank account from which the funds were
transferred by the player. There is an obligation to register all financial transactions conducted
between remote gambling operators and the player, in both directions, for a period of 5 years.
Furthermore, operators cannot accept stakes from a player unless there are enough funds in the
game account to cover the value of the stake, or if these have been transferred in accordance with
the law.
In Spain, the Third Money Laundering Directive was transposed into Spanish law without major
changes and it is currently in force. In terms of the gambling sector, it applies mainly to casinos and
does not currently apply to the remote gambling sector.
Question 36: Is there evidence to demonstrate that the risk of money laundering through online
gambling is particularly high in the context of such operations set up on social web-sites?
No, although this question highlights the need for proper enforcement at national level of all
operators providing gambling services in that territory.
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