EU BYTES
Former Executive Director of the European Casino Association and current Managing Director of Time & Place Consulting, Glenn Cezanne provides the latest info on what’s trending and what’s coming down the pipeline in Brussels and around the EU.
EU Bytes A
Glenn Cezanne Anti-Money Laundering Alongside Data Protection, the 4th AML Directive
was considered one of the most complex legislative initiatives to do its rounds in Brussels in recent times. The transposition deadline into national law was 26 June 2017, and it seems several countries still have to take that step. On that day the Commission also published its
Supranational Risk Assessment to help Member States identify potential risks for current and future AML initiatives. It sees land-based betting and poker, and
10 AUGUST 2017
s we know, there is no EU-wide gambling- specific regulation. And, the Commission is keen not to engage in such an endeavour, especially in light of the constant tug-of-war that exists between
the various branches of the gambling industry on the questions of national self-determination (subsidiarity principle), confirmed by case law and infringement of the Internal Market. But this does not mean that the European institutions are sitting back on their laurels and doing nothing. Plenty of initiatives have been introduced and evaluated, from responsible gambling research to equipment standardisation. Not to mention the infringement cases against Member States’ gambling regulation based on the scrutiny that the Commission is responsible for. This covers national and regional regulatory developments which are constantly adapting to accommodate anything from new technologies to consumer trends. And the list goes on, including parallel initiatives directly affecting gambling operations such as: Data Protection, Anti-Money Laundering, and cash payment limitations, to name just a few. With an ear to the ground in Brussels, I would like
to dedicate this first edition of EU Bytes to providing you with an overview of some ongoing dossiers that could affect your business and your markets. Each month, I will run through key developments and flag up what’s coming next.
gambling online as high risk. Lotteries and gaming machines at moderate level. Casinos are under “inherent high risk exposure” but unlike other forms of gambling have been subject to AML scrutiny since 2005 which has had a mitigating effect. And be aware, AML officers, experts, lawyers and
lobbyists, the draft Directive of 2016 to amend the 4th AMLD, is currently doing its rounds in the EU institutions with virtual currencies and prepaid cards under discussion.
Cash Payment Limitations A cousin to the Anti-Money Laundering
Directive, the European Commission is seeking to understand what action it should take in the field of cash payment limitations. A public consultation was held earlier this year with an overwhelming 94.94% of the 30,317 replies stating that no cash payment limitations should be introduced at EU level. It will be interesting to see how the Commission will move forward when it publishes its impact assessment in 2018.
Europe Digitally
It is nothing new to tell you that innovation in gambling technology is fast-paced. How does regulation correspond? Legislative initiatives in the pipeline include geo-blocking and audio- visual media services. More recently, preliminary findings of a European Commission public consultation were published on the European data economy with nearly 400 responses, also receiving traction from the gambling sector. A key question was on how restrictions on data locations could inhibit the free flow of data in Europe. In light of potential further initiatives, it is of interest to understand how these could potentially affect national licensing conditions pertaining to server locations. All in all, the new Council of the EU Presidency
Trio which started in July (Estonia-Bulgaria-Austria) for the next 18 months should increase the digital
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