MONTENEGRO Law and Practice Contributed by: Luka Popović and Milana Savović, BDK Advokati
be temporary or indefinite. Operators must implement exclusion requests immediately and notify the Games of Chance Administration within 24 hours. Procedures for managing exclusion and limitation requests must be detailed in internal policies accessible to players and regulatory authorities. 8. Anti-Money Laundering (AML) 8.1 AML Legislation The key AML regulation, which also applies to the gambling sector, is the Act on Prevention of Money Laundering and Financing of Terrorism. Providers of gambling services (gambling operators) are regulated as obliged entities under this piece of legislation and hence are required to have in place policies, controls and procedures for mitigating and effectively manag- ing the risks of money laundering and terrorism financ- ing. When assessing the risk of money laundering and the financing of terrorism, gambling operators are obliged to observe the list of indicators of suspicious trans- actions prescribed under the Rulebook on the List of Indicators for Recognition of Suspicious Clients and Transactions ( Pravilnik o listi indikatora za prepozna- vanje sumnjivih klijenata i transakcija , “Official Gazette Gambling operators (providers of lottery games, spe- cial games of chance, online games, etc) are obliged to establish the identity of the customer, upon the collection of winnings or the wagering of a stake in the amount of EUR20 or more, or when carrying out transactions amounting to at least EUR2,000, wheth- er the transaction is carried out in a single operation or in several linked operations. Additionally, the new Games of Chance Act requires organisers of betting games to maintain records of individuals who have made payments in the amount of EUR50 or more, as well as of winners who have been paid EUR300 or more. The operator must collect information on the name, residential address and date of birth of the customer, among other things, and must verify the customer’s of Montenegro”, No 29/24). 8.2 AML Requirements
identity on the basis of documents, data or informa- tion obtained from a reliable and independent source. This obligation also applies to online gambling opera- tors when opening customers’ accounts, and to casi- no operators when the customer enters the casino.
9. Advertising 9.1 Regulatory/Supervisory Agency
The new Games of Chance Act sets out detailed rules governing the advertising of gambling activities. Supervision over the advertising of games of chance in the media is conducted by the ministry responsible for media affairs and the regulatory authority. 9.2 Definition of Advertising The Games of Chance Act distinguishes between the following types of advertising. • Advertising of games of chance operators is a noti- fication by a specific operator of games of chance with the aim of presenting and drawing attention to the name, brand, logo, or activity of that operator. • Advertising of games of chance services is the presentation and drawing attention to the games of chance offered by that operator, including invita- tions to participate in the games, as well as refer- ences to the operator’s address, website, or mobile application. • Advertising of benefits related to games of chance services is any notification by an operator of games of chance intended to promote benefits related to a specific game of chance (such as bonuses, jack- pots, prizes, free spins, and similar). 9.3 Key Legal, Regulatory and Licensing Provisions Advertising of games of chance, including indirect ref- erences, is conducted with a notice regarding the pro- hibition of participation of minors in games of chance and an appropriate warning text on the prevention of addiction-related disorders. Operators are required to protect players’ personal data in games of chance in the most effective manner and in accordance with the Games of Chance Act.
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