Compliance Updates
Montenegro’s evolving legal landscape: recent amendments and controversies in games of chance regulation
Montenegro’s Law on Games of Chance (the “Law”) was enacted in 2004 and has undergone multiple amendments since. The most recent ones came into effect on 1 January 2024.
The aim of the amendments, as stated by the competent authorities, is to ensure a sustainable regulatory system for organising games of chance via the internet or other telecommunication means, as well as to generate additional revenue from these activities. This objective is to be achieved through measures aimed at establishing a variable concession fee for the organisation of online games of chance, a provision not envisaged in the prior legal framework in this area. Another measure to achieve the set goal is to introduce a ban on participation in foreign games of chance via the internet and other telecommunication means for which bets are paid on the territory of Montenegro.
To achieve these objectives through the proposed measures, several amendments to the Law have been proposed and adopted:
- The concept of organising games of chance through the internet or other telecommunication means has been clearly defined for the first time.
- A ban has been introduced on participation in foreign games of chance for which bets are paid within the territory of Montenegro, regarding the organisation of internet betting. Therefore, the competent authorities are now obliged to restrict access to the websites of gaming organisers who accept payments for games of chance from players in Montenegro, through the blocking of IP addresses by an independent regulatory body in the field of electronic communications, as well as the prohibition of all types of payments to foreign organisers. Furthermore, the competent authority is required to maintain and publish a list of unauthorised online gaming organisers ex officio.
- A higher annual fixed fee per casino has been introduced, now amounting to EUR 100,000 instead of the previous EUR 50,000. Additionally, the variable fee for organising games of chance in casinos has increased from 10 % to 15 % of the base.
- A prohibition on organising games in residential-commercial buildings has been introduced.
- A new regulatory framework has been established for the organisation of games of chance on the internet. The most significant changes involve defining the conditions and methods of player registration and identification, as well as establishing the obligation to pay the variable portion of the concession fee for organising betting games of chance over the internet, as well as for organising games of chance in virtual casinos and online slot games. The fee is calculated at a rate of 10 % of the base, which consists of the total amount of stakes reduced by the value of payouts and is paid by the fifteenth of the month for the previous month. The fixed part of the concession fee amounts to EUR 10,000 for all the aforementioned types of games of chance organised over the internet. Additionally, with the introduction of the new Article 68f of the Law, it is stipulated that payments for organising games of chance over the internet can only be made through payment cards or at the premises where games of chance are organised in accordance with the Law.
The new legislative solution has not escaped scrutiny from interested market participants, especially regarding the controversial Article 68f. There has been particular attention in the public sphere to the reactions of associations of gaming organisers, which, through various reviews, have questioned the justification, sustainability and legality of the provision stipulating that payments for organising games of chance over the internet can only be made through payment cards or at the premises where games of chance are organised.
In response to the reaction of the association of gaming organisers, a petition was initiated, gathering over 25,000 signatures. An initiative was subsequently submitted to the Montenegrin Parliament to repeal Article 68f. In addition, another initiative was lodged with the Constitutional Court of Montenegro to review the constitutionality of Article 68f.
The competent authorities are currently processing these initiatives. Meanwhile, legal experts and the general public eagerly await more answers to these legally and practically intriguing questions in the coming period.
Source: schoenherr.eu
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Compliance Updates
A New Analysis by EGBA Reveals Notable Shift Towards Multi-licensing for Online Gambling Across Europe
A new analysis by EGBA concludes that 27 out of 31 European countries employ some form of multi-licensing for online gambling, with an overwhelming majority implementing a full multi-licensing approach.
In recent years, Europe has experienced a remarkable transformation in online gambling regulation. Just fifteen years ago, the landscape was vastly different. Most European countries lacked dedicated regulations for online gambling or operated under exclusive rights models where only state-owned entities had a monopoly to offer online gambling services.
But fast forward to today and the situation has evolved significantly. A new analysis by the European Gaming and Betting Association (EGBA) concludes that the multi-licensing model has become the predominant regulatory approach in Europe. Under this model, multiple companies are permitted to offer online gambling services within a country, provided they comply with strict regulatory obligations.
Key findings of the analysis:
- 27 out of 31 European countries have adopted some form of multi-licensing, indicating a robust trend towards open, competitive markets.
- Four countries currently do not have any form of multi-licensing: Finland, Iceland, and Norway maintain exclusive rights models, granting state-owned entities a monopoly over all online gambling services, while Luxembourg lacks dedicated regulations for online gambling.
- Of the 27 countries with multi-licensing, 23 countries have a full multi-licensing model for all regulated online gambling products in those countries.
- Four countries have a mixed model with partial multi-licensing: Slovenia and Switzerland each have a monopoly for online sports betting, while Austria and Poland each have a monopoly for online casino gaming and poker, with multi-licensing for all other online gambling products.
- Cyprus (casino gaming and poker) and France (casino gaming) each impose product-specific prohibitions but both have multi-licensing for all other regulated online gambling products.
- Finland is currently undergoing legislative reforms, and is expected to establish a multi-licensing framework for online gambling in 2026.
Maarten Haijer, Secretary General of EGBA, said: “The momentum towards full multi-licensing for online gambling in Europe is undeniable. While a few exceptions still exist, governments are concluding that public policy objectives, particularly related to consumer protection and tax generation, are more effectively met through well-regulated online competition. Finland’s current transition towards multi-licensing signals the impending end of the last online gambling monopoly in the EU, marking a significant regulatory milestone.
“Similar deliberations regarding the future of the online monopoly are inevitable in Norway and Iceland. Furthermore, the handful of countries with either partial monopolies or product prohibitions should strive for greater consistency and effectiveness in their policies by phasing these out. With over 15 years of regulatory experience in Europe, it’s clear that full multi-licensing offers the best pathway to enhance consumer protection, increase tax revenues, and ensure stronger regulatory control. The time has come for the last remaining European countries to embrace this optimal form of online regulation.”
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Spinomenal, the leading iGaming content provider, has expanded its Latin American presence by registering as a service provider in Peru. The approval from Peru’s Ministry of Foreign Trade and Tourism (MINCETUR) allows Spinomenal to provide its casino titles to the country’s locally licensed operators.
With Peru’s recent introduction of new gaming regulations, the iGaming environment is set for an exciting transformation. Spinomenal is thrilled to be part of this dynamic evolution, offering our state-of-the-art gaming solutions to energise and enhance the gaming experience within Peru’s thriving iGaming community.
Peruvian players will now be able to enjoy Spinomenal’s popular portfolio of games and some of the gems available are Majestic King and Demi Gods V.
Spinomenal CO-CEO, Lior Shvartz commented: “Latin America continues to be a key region for us and we’re proud to now be able to offer our titles within the regulated Peruvian market. Games have been hand-picked for Peruvians based on localised knowledge of player preferences gained by our experience in the market prior to the new regulation.”
Department of Trust (dotrust.co.uk), the award-winning provider of financial risk assessments for safer gambling is poised to meet the challenges of the newly announced regulations on frictionless financial checks by the UK Gambling Commission and Betting and Gaming Council.
Under the new rules published by the Gambling Commission, operators have until August 30th to implement frictionless checks on all customers making £500 net deposits in any rolling 30-day period. These frictionless checks form part of a new regime designed to protect players at risk of financial harm and replace the current ad hoc approach to affordability checks.
Department of Trust also welcomes the interim voluntary code published today by the Betting and Gaming Council (BGC), the standards body representing over 90% of UK-regulated market operators. This code focuses on how responsible operators should support customers spending above the lower threshold set out by the Gambling Commission.
The supplier’s DoTrust Complete solution offers an integrated suite of frictionless and enhanced financial risk checks with a high level of automation capability -the only such tool built solely for safer gambling – and is perfectly positioned to help businesses navigate the newly regulated waters.
Charles Cohen, CEO of Department of Trust, said: “These important announcements flag the end of gambling’s ‘sus law’ where players faced seemingly arbitrary requests for personal information, operators were placed under a significant burden, and no one won
“We now know that in 120 days, every operator will need to perform frictionless checks on all players with net deposits in a 30-day rolling period of £500. A few months later this will fall to a much lower level.
“If operators want to protect their business, keep their customers and reduce costs, smart automation is the only answer.
“Department of Trust has spent over two years building the leading plug-and-play solution specifically for the gambling industry. Complete already automates over 90% of the processes required in both the new LCCP and BGC code. Now we know what the requirement will be, we are today committing to the goal of 100%. We want every operator and player to have instant assessments and sensible decisions cost-effectively. No one needs to lose sleep over this.”.
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