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
Vixio Finds Over €36m in AML Fines Issued in Europe in the Last Year

Vixio, a leading provider of regulatory intelligence solutions, is proud to announce its Anti-Money Laundering (AML) Outlook, which found that regulators are cracking down on money laundering weaknesses with severe consequences, totaling over €36m in fines from March 2024 to March 2025 in Europe alone.
Vixio’s AML Outlook examines the challenges of complying with AML requirements in jurisdictions around the world, outlines regulators’ efforts to thwart criminal activity, and considers how payments and gambling firms can prevent being caught up in money laundering scandals.
The report found that in the last year, in the European area alone, there have been around 30 enforcement actions from regulators fining payments and e-money firms for falling short in their adherence to AML/CTF rules.
Financial institutions found to have money laundering weaknesses face profound consequences, with prosecutors and regulators alike generally unwilling to be empathetic on this matter. For example:
- In March 2025, Germany’s regulator, BaFin, fined Ratepay €25,000 over suspected money laundering.
- In February 2025, Estonia’s Money Laundering Data Bureau revoked B2BX Digital Exchange OÜ’s licence for failing to implement proper customer due diligence, transaction monitoring and risk assessments.
- The Bank of Lithuania, meanwhile, revoked Foxpay’s licence in November 2024 for systemic AML/CTF and governance failures, including fund mismanagement and conflicts of interest.
John Gidla, Head of Payments Compliance, Vixio, explains, “Although AML compliance involves significant costs for payments firms – including investment in transaction monitoring systems, customer due diligence (CDD) processes and ongoing staff training – the consequences of failure can be significant. In addition to financial penalties, failing to prevent money laundering can severely damage a firm’s reputation, leading to loss of customers, partners and investor confidence. Maintaining a strong compliance framework is crucial for preserving trust and long-term business viability.”
Until now, the EU’s AML enforcement has been more fragmented, but the EU’s new Authority for Anti-Money Laundering and Countering the Financing of Terrorism (AMLA) could be a significant step towards addressing AML enforcement and closing gaps that criminals have been exploiting for years.
Regulatory scrutiny means that firms need to implement know your customer (KYC) procedures, monitor transactions on their systems for suspicious activity and report concerns through suspicious activity reports (SARs) to the relevant authorities.
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Compliance Updates
EGBA boosts regulatory monitoring with compliance workspace Letzz

The European Gaming and Betting Association (EGBA) is pleased to announce a partnership with Letzz, an AI-powered compliance workspace designed for online gambling, to modernise regulatory monitoring and enhance strategic compliance across Europe’s fragmented online gambling landscape.
Through this partnership, EGBA will implement Letzz‘s AI-powered tool to enhance its own regulatory monitoring capabilities. Launching this week, the Letzz platform offers operators real-time, expert-validated insights and automated regulatory news scanning, creating a single, reliable source of information for compliance management.
“We are committed to promoting the highest standards of compliance across Europe’s online gambling sector,” said Maarten Haijer, Secretary General at EGBA. “With 27 countries in the EU, each with their own gambling laws and a myriad of requirements, accessible tools like Letzz can help both associations like EGBA and operators better understand the complex landscape of regulatory obligations.”
“We founded Letzz with the belief that compliance should be a competitive advantage, not just a necessity,” said Daniel Gambin, Co-Founder and CEO at Letzz. “Our partnership with EGBA allows us to bring this vision to a wider audience of operators who share our commitment to excellence in regulatory compliance. By transforming compliance from a challenge into a strategic business asset, we’re helping operators stay abreast of the latest regulatory changes.”
The collaboration reflects EGBA’s commitment to promoting a well-regulated online gambling market with the highest compliance standards.
Source: egba.eu
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Compliance Updates
BETER joins the Esports Integrity Commission

Fast betting content, data and live streaming provider becomes a Tier 1 Anti-Corruption Supporter to the Esports Integrity Commission helping drive match-fixing and fraud out of the industry
BETER, the award-winning provider of fast betting content, data and live streaming for esports and sports, has joined the Esports Integrity Commission (ESIC) as a Tier 1 Anti-Corruption Supporter.
As a member, BETER will assist the ESIC in identifying and investigating suspicious betting activity while also supporting the Commission’s wider goal of combating match fixing and betting fraud across the esports industry.
BETER is well placed to support the Commission, given its standard-setting approach to ensuring integrity across its fast-betting products and solutions.
As part of its supporter role, BETER will contribute to ESIC’s monitoring and intelligence functions, actively cooperating in the detection and investigation of suspicious betting activity. This includes visibility across its flagship ESportsBattle tournaments, delivering over 36,000 monthly esports events that are thoroughly monitored 24/7 by BETER’s Integrity team. .
The Integrity team ensures that all of BETER’s in-house events are conducted to the highest standards. This is achieved through rigorous e-learning sessions for all athletes participating in its contests, a 24/7 whistleblowing platform, the Integrity BOOTCAMP program, a comprehensive reporting system, partnerships with law enforcement agencies and sporting bodies/federations, and more.
Thanks to this robust integrity ecosystem, only 0.01% of events have been flagged for investigation as suspicious over the past 12 months.
Andrii Nekrutov, Chief Integrity Officer at BETER, said: “BETER’s strict measures and strong commitment to fair play principles in our ESportsBattle tournaments provide us with the qualities needed to be a strong and reliable member of the Esports Integrity Commission.
“We are one of the most experienced esports betting content providers with educational programs and approaches that are unrivalled when it comes to integrity and fairness.
“The team looks forward to working with the Commission to improve the esports ecosystem by eradicating match-fixing and bolstering principles of fair play. We have done a great job of this with our esports tournaments and believe we can help do the same for the wider industry.”
Stephen Hanna, Chief Executive Officer at the Esports Integrity Commission, added: “BETER’s membership to the Esports Integrity Commission is a testament to the company’s alignment with our mission to uphold and promote the highest standards of integrity, transparency and fair play within the global esports ecosystem.
“By becoming a member, BETER joins a growing community of industry leaders dedicated to fostering a safe, transparent and sustainable future of esports.”
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