comment


Clive Hawkswood, Chief Executive of Remote Gambling Association. chawkswood@rga.e u.com


“After the UK, Italy was probably the first of the larger EU jurisdictions to introduce a licensing regime for private sector online gambling operators. In contrast to the UK it opted for a phased approach that began with sports betting and tournament poker and has gradually moved towards cash poker, online games etc. The whole system is overseen by AAMS, which is generally seen as a fairly reasonable regulator, and it is fair to say that most of the reforms have been driven by the need to generate tax revenues. Not all companies have found it an easy market to enter and those who have sustained their positions are a mix of online gambling specialists and established land-based operators who have added online products to their businesses. The market itself is significant (in the EU it is probably the third largest for online gambling behind the UK and Germany) and still on an upward curve. This growth can expected to be sustained for the foreseeable future by the licensing of new products and a gradual increase of online gambling within the overall gambling market. Originally Italy had been given numerous hurdles to overcome by the European Commission to ensure its laws were compliant with EU law, but these are certainly less prevalent now and the regime is well bedded in so any fresh regulatory issues that arise are likely to do so for domestic reasons.”


2011. The chart below shows the AAMS data for the month of January.


technical standaRds The AAMS technical standard, entitled Linee Guida per la certificazione della piattaforma di gioco, released 10 March 2011, is one of the most rigorous and comprehensive iGaming standards to be enacted by any European jurisdiction to date.


Furthermore, while many other iGaming regulators focus primarily on the initial ‘pre- live’ compliance of the games and systems, AAMS goes further by also implementing stringent monitoring and controls over the operation of the games throughout their entire lifespan in the live environment.


AAMS accomplishes this with their sophisticated custom-built centralized system. Player account registrations and game authentications take place on the AAMS centralized system, in conjunction with each operator’s iGaming servers. In addition, all game outcome data, such as wagers, wins and results are made available to this centralised system for storage and reporting.


In order to facilitate these stringent live controls, iGaming products must be subjected to two phases of testing before they are permitted to operate in Italy:


1.compliance testinG The games and systems must be certified by


aams implements stRinGent


monitoRinG and contRols oveR


the opeRation of the Games


thRouGhout theiR entiRe lifespan in the live


enviRonment.


an AAMS-accredited test laboratory as complying with all relevant provisions from the AAMS technical standard. In this phase, the operator works closely with the laboratory to facilitate any necessary compliance testing, address any identified issues of non- compliance, and ultimately obtain certification.


The AAMS technical standard is divided into various sections that each deal with a different aspect of iGaming compliance, such as the Random Number Generator (RNG), game rules, game fairness and Information System Security (ISS). A number of appendices supply additional requirements for specific types of games, such as card games and reel games. All technical requirements are spelled out in


ample detail, allowing for clear interpretation.


2.colloquio After the Compliance Testing phase is successfully completed, the subsequent ‘Colloquio’ phase does not require involvement from the test laboratory. Instead, the operator works directly with AAMS, who inspects and verifies the operator’s communication protocol for transferring data between the iGaming product and the AAMS centralized system.


Wherever necessary throughout the above testing, AAMS typically interfaces directly and solely with the operator, or concessionaire, rather than any suppliers contributing software or hardware to the end product. The AAMS generally sees the concessionaire as being ultimately responsible for compliance, so any matters relating to contributing suppliers are left to the concessionaire to sort out. Naturally, suppliers can have their respective components tested and certified by the test laboratory, however the request for AAMS approval of the overall end-product, using a formal testing report, must be undertaken by the operator.


This expectation of role and responsibility is increasingly important for operators utilising numerous suppliers of games and systems. Any necessary communication and coordination with those suppliers, as it relates to the AAMS testing process, must be managed directly by the operator. The larger the number of suppliers, the larger the undertaking in coordinating the compliance process.


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italy


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