• Σχόλιο του χρήστη 'The Remote Gambling Association (RGA)' | 4 Φεβρουαρίου 2019, 11:28
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    Preliminary statement The Remote Gambling Association (RGA) welcomes the Greek Government’s plan to amend the Law 4002/2011 in that it would put an end to the temporary regime that has been in place since 2011 and create a permanent and more transparent licensing regime for online gambling. In doing so, we are of the view that the government should aim to channel customers away from the unregulated market, better protect consumers from the harm caused by gambling, in particular the most vulnerable and underage people, and generate new tax revenues. Importantly also, this reform offers a good opportunity to address outstanding concerns about the compliance of Greece’s online gambling regulations with EU law. It goes without saying that the secondary legislation should also reflect these objectives. Before setting out our comments with regard to the secondary legislation, we would like to reiterate our position about the ban on RNG-based games that is laid down in the draft amendments to the Law 4002/2011. We are of the view that in order to achieve the objectives of compliance with EU law, reducing the size of the unregulated market, protecting consumers and levying additional tax revenues, it would be strongly recommended to opt for a licensing regime for online gambling covering all the major products, i.e. betting (fixed-odds and exchanges), poker and casino games (Random Number Generated games as well as dealer games). As per EU law, there needs to be a consistent and non-discriminatory treatment between both gambling products and operators. Furthermore, any lack of consumer choice will ultimately push consumers away from the regulated market. Experience shows in Europe that discriminatory treatment of international operators/protection of locally based operators fails to prevent customers from seeking alternative gambling offers with international operators. Any exclusivity granted in relation to any specific products is likely to lead to legal challenge. In addition, considering that most operators are interested in offering the full range of online gambling products, opting for a single licensing system for all products would facilitate the work of operators and the regulator during the application process.