ITALY Law and Practice Contributed by: Stefano Sbordoni, Sbordoni & Partners
• SOGEI costs – audit and compliance (between EUR30,000 and EUR60,000). The B2C operating models are as follows: • operator with own licence – high investment, but total control; • white label/skin – relies on an existing licensee (ADM or foreign); • affiliate/pay-per-click (PPC) – does not require a licence if it does not offer gaming. 6.2 B2B Licences (Suppliers, Software, Etc) In Italy, there is no specific ADM licensing regime for software suppliers and B2B operators. A B2B licence does not allow the public to offer games, but is used to provide technology platforms, payment systems, gaming software, random number genera- tors (RNGs), management services, maintenance ser- vices, server housing, and technical support. • obtain contracts with major Italian operators; and • expand within the sector by offering additional services. A B2B supplier, on the other hand, cannot: • offer gaming services directly to end users; • manage players’ sensitive data unless specifically authorised; • intervene in the final payout; and • operate independently without being linked to a concessionaire. The B2B “licensing” works in Italy in four operational models, as follows. • Game suppliers (casino, skill, bingo, virtuals) – each game must be tested by an accredited labo- ratory, approved by the concessionaire, integrated with SOGEI and authorised for release on the.it market. A supplier with ADM certification can: • sell games to Italian concessionaires; • operate within the regulated.it market; • gain greater credibility across Europe;
• Sportsbook suppliers (feeds and betting engines) – a sportsbook B2B supplier must provide certi- fied data feeds, generate odds in accordance with ADM requirements, and transmit transactions in real time. • Gaming (player account management, or PAM) platforms – PAM platforms must strictly comply with requirements relating to security, user man- agement, bonus systems, wallet management, and anti-fraud systems. Often, the B2B platform is integrated as a “technical provider”. • Additional modules ‒ these include responsible gaming/self-exclusion modules, automated AML systems, AML/KYC modules, and behavioural tracking systems. The ADM formally communicates: • the supplier’s name; • the module or game used; and • the outcome of the certification The supplier’s system must connect to the ADM/ SOGEI central systems. Every transaction (bet, win, game state) must be recorded in real time. The ADM carries out periodic checks, including: • audits; • functional tests; • document checks; • RNG integrity verification; and • statistical and payout analyses. 6.3 Affiliates In Italy, affiliates are NOT considered gaming opera- tors, therefore: • no ADM licence is required; • no technical certification is required; and • no individual authorisation is required. However, affiliation in the gaming sector is permitted only if the affiliate promotes operators authorised by the ADM and complies with all rules on commercial communications.
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