This document reflects the continuation of our approach aimed at creating the EU-wide policy proposals and information summaries to best familiarize the broad spectrum of the Industry’s stakeholders onto key regulatory challenges lying ahead.

The paper puts the emphasis on a comparative method, by comparing the current regulatory regime (with the 4 AML Directive in force) and the anticipated changes.

The document, part of our AML section, is available at the following page.

Our position paper tends to identify and highlight several conceptual deficiencies introduced by the Draft Law which, if adopted, could affect the core values of EU acquis and the functioning of the Internal market. As the most disputable, we have identified the provisions and definitions, envisaged by the Lawmaker, relating to the vicinity of gaming establishments in general, vicinity of the latter to hospitals, and to the extent of personal data asked by the players.

The proposed amendments do not, in an unambiguous manner, explain the exact minimal required vicinity of the gaming establishments from categories of objects encompassed by this Draft Law.

Furthermore, the Draft Law intends to include the hospitals in provisions regulating the distance of the Class IV gaming facilities. Our Organization would like to highlight the redundancy of this legislative intent. In our position paper, we emphasized that not a single study on gambling has so far outlined the vicinity of hospitals and similar facilities as a risk factor for developing problematic behaviour or underage gambling.

We believe that the foreseen mandatory documenting of occupation and place of birth of players while entering a gaming facility, represents a bad practice which will infringe players’ privacy, given it is to be expanded on irrelevant and unauthorized types of personal data.

However, there are several provisions of the Draft Law which our Organization finds very properly designed, in terms of achieving a more strengthened approach to responsible gambling. They are also included in our official letter addressed to the European Commission.

You can find the complete position paper of EOGL, sent to the European Commission, in Studies section of the page, or by clicking here