Formally known as self-service terminals (SSTs), these are electromechanical devices, commonly found in betting shops throughout the EU. They facilitate the players’ betting activities in betting shops (that is, in located in betting-licensed premises), in the sense that diverse human-factor mistakes of the cashiers can be avoided. However, due to a certain level of gambling-related public health risks (the absence of equipped cashier to provide the advice related to problem gambling behaviour), their use and locating is severely restricted. The majority of EU Members States (UK, Austria, Germany and Sweden in particular) strictly regulate that this type of gaming machines cannot be sited in cafes, takeaway and food shops or similar, so called “unlicensed premises”. Placement and use of SSTs is exclusively identified and limited to betting shops and casinos. By no means can the terminals-related gambling activities be classified as distinct form of betting. It is also totally unacceptable, both by the force of law and the elementary imperatives of logic, to tolerate the placing of these devices in catering facilities, given the fact these locations are unlicensed facilities for betting activities to take place.

Betting terminals are just one more variant of digitally-driven betting. However, their placing is very strict and limited to few licensed types of facilities. Every other practice, in contrary with these specific and strict provisions, is by-the-book example of black market betting.

However, throughout Europe lately, we are witnessing severe manipulation and bypassing of these globally accepted regulatory standards. Partly because of inadequate gambling taxation systems, black market gambling has for decades been a severe problem for the European and the EU economies. But let’s stick to our topic. There is a huge amount of constant reports referring to gambling activities via irregular betting terminals, i.e. via devices that are placed in unauthorized premises. Not only the incomes gained from these activities remain totally untaxed, they also induce and boost severe public health and social issues (criminality, problem gambling, loan sharks, money laundering and organized crime in sports).

Such practice, as most recently noticed in Montenegro, also effectively fosters the flourishing of underage gambling, given the fact in catering facilities there are no equipped personnel who would be capable to recognize and prevent neither underage nor problem gambling. These deficiencies are usually combined with the inexplicable omission of state authorities to provide the rule of law and to react accordingly and timely upon these incidents.

Obviously, the harm they produce is far more serious than just related to decline of taxation incomes. Such failures and omissions related to globally – adopted regulatory standards is an alarm bell for all the relevant stakeholders at the EU level – that is the European Commission, European Parliament and the most relevant EU-based Gambling authorities. Once again, our Organization repeats its commitment to fostering dialogue regarding social responsibility, tax reform and the need of broader and intensified partnership cooperation between EU-based regulatory bodies, research institutes, media representatives and decision-makers.

As of 26^th June 2017, based upon the decision of the European Commission (EC), the provisions of The Fourth Anti-Money Laundering Directive (4^th AMLD) have effectively come into force. Accordingly, EU Member States are now obliged to transparently transpose the provisions of the Directive into their respective national legislative provisions. The European Commission has commenced with the check-ups of the state of the transposition, that already resulted in written addresses to the Member States that have not yet initialized the necessary measures (14 member countries, according to mid-August records).

As stipulated, the 4^th AMLD applies to ‘obliged entities’, namely credit and financial institutions, as well as legal or natural persons acting in the exercise of their professional activities. Likewise, according to the Article 2 Paragraph 1 Section F of the Directive, providers of gambling services are the legal entities subject to its provisions.

In that respect, Section 21 of the Introductory provisions, although previses the possibility of exemption (that by no means do not apply to casinos) for the customers that do not pose higher risk, obliges the member states to lower the corresponding threshold for the providers of gambling services to EUR 2000 or more, given the fact, as stated, “the use of gambling sector services to launder the proceeds of criminal activity is of concern”. All the gambling-related transactions are subject to the Risk-Based Analysis, Costumer Due Diligence Assessment and as well as to imperatives of a better understanding of the potential financial system abuse, that are to result in a better quality of recommendations and the risk-mapping of Supranational Risk Assessment Reports.

It is apparent that the logic behind this Directive implies that any further imposition of restrictions via national legislature, regarding the services of online betting, is unnecessary and contrary to this legally binding act, as well as of the EU acquis in whole.