• Σχόλιο του χρήστη 'The Stars Group' | 4 Φεβρουαρίου 2019, 11:10

    (a) Par. 3 provides that the bank letter of guarantee (to be issued in favor of all applicants) shall also cover an operator’s liability towards players for non-payment of attributable profits and for other claims as provided in the draft regulation. On the other hand, the Bank Letter of Guarantee sample (see Appendix of the draft regulation) does not cover this kind of liability. We propose that that all disputes shall be resolved before the competent courts (to be based in any EU country) as provided in the respective contract (i.e. an operator’s TCs). That means that the Bank Letter of Guarantee shall not cover liability towards players. (b) Par. 4 provides that a licensee shall be entitled to offer gaming services (after its license is issued) only after it proceeds with submission of all documents provided in sub paragraphs 6.4.1 to 6.4.9. Special attention shall be given to sub paragraph 6.4.6 which provides for the submission for all contracts with third parties if related with the conduct of gaming! This could encompass all contracts with employees, consultants, software vendors etc.! It is understood that article 6.4 has been drafted in that way by mistake. We propose that a licensee shall be obliged to provide all this data within 12 months as from the date the license is issued and that if he fails to do so, the license shall be revoked (so the phrase: “In order to commence conducting gamin under the license” shall be deleted). Sub-paragraph 6.4.5 shall also use plural tense so as to allow the use of multiple bank accounts (the term “exclusive” shall be deleted).