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Compliance Updates

Navigating New Frontiers: AI’s Role in Reinventing iGaming Compliance



Navigating New Frontiers: AI's Role in Reinventing iGaming Compliance
Reading Time: 4 minutes


By Paul Addicott-Evans, Managing Director for Products at ComplianceOne Group

In high-stakes world of iGaming, regulatory compliance is not just a box to be checked – it is the bedrock upon which the industry’s integrity and customer trust are built. As we navigate this complex landscape, the emergence of Artificial Intelligence (AI), especially through Large Language Models (LLMs) like ChatGPT, promises a revolution in how we approach regulatory processes. Yet, with great power comes great responsibility, and the integration of AI in compliance raises crucial questions about the verifiability and accuracy of its data inputs.

The Data Verification Dilemma

At the core of this AI-driven transformation in iGaming compliance is ChatGPT, a marvel of modern technology powered by a sophisticated Large Language Model. ChatGPT opened the world’s eyes to the possibilities of AI, whilst simultaneously creating a major question with wide-spread adoption: Can we trust it?

Despite its impressive capabilities, a fundamental challenge persists: verifying the accuracy and currency of the information it provides. In many walks of life, not least the ever-changing regulatory environment of iGaming, relying on AI tools without verifiable data sources could lead to non-compliance, legal challenges, and potentially financial penalties.

This dilemma is intensified by the dynamic nature of iGaming regulations, which can vary significantly across jurisdictions and are subject to frequent updates. Non-compliance can be extremely costly, so ensuring that AI tools are not only informed by but also aligned with the latest legal standards is paramount. This calls for a robust framework where AI tools are continuously fed with up-to-date and verified regulatory data, and their outputs are regularly audited for accuracy and compliance.

The science bit…

How do we approach this problem? The availability of large language models is now almost a commodity. The technology is available for everyone to use. However, when faced with such an important problem as reliability and verifiability, there is a need to weave supporting technologies into the AI-framework. This is where vector embeddings come into play, acting as a bridge between raw data and the AI’s ability to understand and verify it.

Imagine vector embeddings as a vast library, not of books, but of words, phrases, and concepts, each with its own unique location. This library is created by a neural network, a type of AI, which reads and understands vast amounts of text, then organizes this information into a map.

Each word or phrase is placed precisely, so that words with similar meanings are neighbours.

For iGaming compliance, this library becomes invaluable. When AI uses vector embeddings, it’s like consulting this map to understand not just words, but the context and meaning behind them. This is crucial for verifying vast, complex regulatory information.

In essence, vector embeddings allow AI to comprehend and verify information much like an expert human would, but with the speed and accuracy that only a machine can offer. This boosts the reliability of AI in iGaming compliance, ensuring that the operators get accurate and up-to-date information, crucial for staying within regulatory boundaries.

AI’s Edge in iGaming Compliance

The use of AI in iGaming compliance, when done correctly, can offers a suite of advantages:

  • Enhanced Precision and Efficiency: AI’s ability to swiftly and accurately synthesize regulatory information ensures that operators are always in step with the latest compliance requirements. For instance, an AI tool could analyse recent amendments to anti-money laundering laws across different jurisdictions within minutes, a task that would take humans significantly longer.
  • Customized Regulatory Insights: AI can offer bespoke guidance, adapting to the unique operational and geographical nuances of each iGaming operator. An example of this is how AI tools can provide tailored advice to operators based on specific games offered or markets targeted, considering the unique regulatory landscape of each area.
  • Automated Compliance Oversight: Continuous AI surveillance of iGaming operations guarantees adherence to regulatory standards, proactively identifying and rectifying instances of non-compliance. This could include real-time monitoring of player interactions to ensure responsible gaming practices are maintained.


Looking Ahead

The journey of integrating AI into iGaming compliance is fraught with challenges, yet the potential rewards are substantial. By anchoring AI in the principles of data verifiability and source transparency, we can redefine how the iGaming industry navigates its regulatory maze – a shift not just in technology but in establishing a new era of trust and reliability.



Introducing IntelligentOne AI

At Complitech, we stand at the forefront of this exciting frontier with OneAI. Developed as part of the comprehensive Complitech database of global regulations, this groundbreaking AI product is poised to redefine iGaming compliance. OneAI distinguishes itself by providing current, accurate data, free from the common ‘hallucinations’ of LLMs, thereby offering responses to regulatory inquiries that are not just swift, but also dependable and verifiable.

Take the example of a Games studio assessing the impact of Germany’s regulations on slot games, particularly concerning the maximum bet limit and the mandatory delay between spins.

Using OneAI, the studio inputs a query about slot regulations in Germany. The AI tool quickly processes this request, providing a detailed analysis of the current German regulations on slot games. It highlights that the maximum bet per spin is capped at €1 and that there is a required minimum interval of 5 seconds between spins. This information is directly linked to the relevant sections of the German Interstate Treaty on Gambling, ensuring accuracy and verifiability.

This targeted insight allows the studio to make informed decisions about game design and offerings in the German market, ensuring compliance while optimizing their product for the new regulatory environment.

With OneAI, iGaming companies can access instant, reliable insights for complex technical compliance questions, streamlining decision-making processes. This innovative tool represents a significant leap in the application of AI in iGaming compliance, marrying the linguistic dexterity of LLMs with the robust, updated Complitech database. It heralds a new chapter in iGaming regulation, where technology not only expedites but also elevates the trustworthiness and accuracy of compliance processes. As AI continues to evolve, tools like OneAI are set to play a pivotal role in fostering a safer, more compliant, and trustworthy iGaming ecosystem.

Compliance Updates

Amid Public Outcry, Montenegro’s Anti – Digital Gambling Law Set for August Revisions



Reading Time: 2 minutes


In January 2024, Montenegro enacted amendments to its gambling laws that effectively ban the use of modern electronic payment methods, including Apple Pay, PayPal, mobile banking, IPS, and e-banking. This move has raised eyebrows across the global financial community, including the European betting and iGaming sectors.

Public Outcry and Anticipated Changes Expected in August

The controversial ban led to significant public outcry and industry backlash. In response, a new version of the law is allegedly expected in August, yet remains to be seen whether it will address some of these concerns.

The Montenegro EU Paradox

Ironically, a few months ago, the case gained media focus and went viral after the Minister of Finance stated that the country has no obligation to comply with EU rules. This paradoxical stance is surprising for a nation actively seeking EU membership and aiming to integrate into the digital business world.

Historical Context

In 2021, the European Commission urged Montenegro to strengthen its efforts to counter money laundering. However, the January 2024 amendments seem to move in the opposite direction, potentially isolating the country from EU practices and global financial community trends.

Industry Response

Since the beginning of 2024, Montenegro’s gambling sector has been in turmoil. The amendments, which force bettors to use cash or specific terminals for transactions, have caused significant inconvenience. This has led to business disruptions and investor uncertainty.

The industry has responded strongly against these changes. A petition to halt the amendments received 25,000 signatures in just five days. Montenegro Bet, the country’s trade association, has submitted the petition to the assembly and initiated a constitutional review. They are also engaging with international institutions to highlight the negative impacts of the law changes.

Massive Lawsuits Ahead

Multiple operators are preparing legal action, including a lawsuit before the International Court for Settlement of Investment Disputes, due to the apparent corruptive practices and unequal market access facilitated by the new law.

Looking Ahead

As August approaches, the industry and public are hopeful for revisions to the law that will align Montenegro with EU standards and global financial trends. The prohibition of safe and advanced online payment methods, in favor of promoting cash transactions, remains a troubling development that demands urgent attention and action.


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Central Europe

Navigating International Regulatory Landscapes: A Guide for Expanding iGaming Businesses



Navigating International Regulatory Landscapes: A Guide for Expanding iGaming Businesses
Reading Time: 4 minutes


Boris Pashnev, CEO of Alpha Affiliates

Taking an iGaming business global opens up vast possibilities for expansion and progress. However, along with new markets and opportunities, comes the complex regulatory landscapes of different countries. To ensure a smooth and compliant expansion, businesses must familiarise themselves with international legal frameworks and understand regulatory considerations. Still, it is much easier said than done.

As a business working closely with iGaming brands, we at Alpha Affiliates have first hand experience expanding within these new regulatory landscapes. We have helped several iGaming operators and affiliates to grow their businesses and comply with the regulations in various jurisdictions. Moreover, in the last year, we have successfully expanded our own business into new geographical markets, including France, Italy, Belgium, Greece, Norway, Slovenia, Slovakia, and Hungary. This expansion not only broadened our global reach but also ensured a more comprehensive and inclusive gaming experience for iGaming enthusiasts worldwide.

This is the hope for many aspiring iGaming operators looking to go global. So, how can businesses successfully navigate new regulations when expanding their business globally?


Make regulation your team’s number one priority

In the iGaming world, regulations must be the cornerstone of your business strategy to going global. You need to go in with the mindset that it isn’t just about compliance – it’s about building a sustainable, reputable business. Only with this mindset, can you successfully launch an iGaming business, and develop long-term trust and support from regulators and consumers alike.

By making regulation your foundation, you’re sure to be on track for success. Of course, for any CEO, this starts by looking to the regulatory experts, and putting together a dedicated compliance team who can manage and advise on the regulatory landscape in the region you are looking to expand into.

For instance, in the case of licensing, operators should seek assistance from their in-house legal departments who can ensure licensing application requirements to be met and the corporate structure to be set up properly. This way they can prevent making any mistakes when switching their operations to comply with the new guidelines and ensure that they set up a well equipped and responsible environment for their players.

By having a dedicated team focused on regulation, operators can confidently and consistently ensure their operations meet regulatory guidelines within new regions.


Remain flexible and embrace new frameworks

Regulation is always subject to review and change  – it’s a natural part of progress to ensure consumers, and businesses are better served and protected.

We saw this most recently with Curaçao’s new regulation known as the National Ordinance for Games of Chance, or LOK, which set out new requirements for anti-money laundering, fraud prevention and player protection. The LOK framework changes brought new change, and with that new considerations for iGaming operators to address. Operators had to reflect and adjust the ways in which they disclose certain information, ensure data protection, address anti-money laundering, privacy measures for gaming and monitoring tactics.

Alongside the regulatory changes, the licensing fees also increased, in order to foster a safer and more responsible environment. And the licensing process changed too. The Gaming Control Board (GCB) opened the new licensing portal on September 1st earlier last year, leaving iGaming companies with two options – to either apply for new licences and follow the regulations outlined in the LOK, or register as sublicensees.

This is a prime example of how quickly things can change, and the need to remain flexible and ready to adapt when expanding into different regions. To stay ahead, it’s important to conduct regular regulatory assessments, budget for potential increases in licensing fees and develop flexible systems that can adapt to new requirements.

Consider creating a regulatory roadmap for each market you’re entering and operating in, from the current requirements, anticipated changes, plus your strategy for addressing them.


Take responsibility: Prioritise player protection

Remember that any international authority or regulator will want to see that player protection is not only met, but prioritised. After all, responsible gaming isn’t just a regulatory requirement, it’s a business imperative.

Ensuring your operations develop comprehensive responsible gaming policies, including self-exclusion programmes, session time limits, and staff training in identifying and addressing problematic iGaming behaviours, will be key.

At Alpha Affiliates, we encourage users to act conscientiously by providing a safe and organised platform to advertise their offerings. We are committed to ensuring responsible gaming is upheld in our services globally and make sure to follow regulations, only expanding into regions in which iGaming is properly regulated.

It’s crucial to consider how you can improve your policies to better protect players – as this will be a number one concern for regulators internationally. We implement industry-standard measures for players who want to control their gambling habits. These include applying various limits on losses, deposits and bets. In addition, we make sure to display reminders for the amount of time spent in a casino and for players to take a step back to step away and cool off. I’d encourage other operators to do the same.


Be patient and carefully lay down the groundwork

Launching abroad successfully takes a well-thought-out and well-planned strategy. It also requires a lot of patience. “Getting your ducks in a row”, and laying down the groundwork will take time and intricate planning.

Starting the process early is important. When it comes to international expansion, regulation is a huge aspect that cannot be rushed. It can be all the difference in business success, and business failure. It requires rigorous due diligence to ensure all requirements are met, and all licensing documentation is ready.

By meticulously crafting and executing a regulation-first international expansion strategy, businesses can put themselves in the best possible footing for growth globally. Regulations are important across all sectors, but in the iGaming world where adhering to tight regulation is imperative, operators must make it the foundation of all business. The path to international expansion may be complex, but with the right approach, operators can capitalise on the exciting opportunities in new markets and drive remarkable growth.

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Compliance Updates




Reading Time: 3 minutes

GCB Portal Re-Opening

The Curacao Gaming Control Board (GCB) is pleased to announce the reopening of the GCB Portal on July 15th 2024 at 00.01 Curacao time. The portal will once again be accepting applications and processing them under the current NOOGH legislation. B2C, B2B2C and B2B operators may all make applications.

Please be aware that we will continue to prioritise applications submitted on or before the April 30th deadline. While we accept new applications, our primary focus remains on processing those received within the original stipulated timeframe.

Portal and procedure changes

All applicants are referred to the Application Submission Guidelines published in March 2024 on the GCB website and the application manual published on the GCB portal as the general rule with three notes:

1. An account is opened on the portal by an Official Representative of the Curacao entity who becomes the “Portal Admininistrator” and has the authority to assign other individuals “Portal User” or “Licensee Account” roles, each with their own permissions. The Portal User or Licensee Account roles can be held by any person(s) of the entity’s choosing including, for example, internal licensing departments of the operator, CSPs or authorised agents. Either the Portal User or the Licensee Account is permitted to submit the application. The Official Representative should appear in the Curacao Chamber of Commerce excerpt of the company.

An Authorisation Letter is no longer required, however the GCB retains the right to conduct due diligence on the Portal User or Licensee Account.

2. Applicants are advised that the registration of “Qualifying Persons” on the portal has been updated. Additional information must be submitted in order for the Personal Account Number (“PAN”) to be issued.

3. Applications on the portal contain real-time checklists which clarifiy the outstanding documentation of information required by the GCB to progress or complete the licensing process. Operators are advised to check the portal on a regular basis, and for expediency should upload documents on the relevant section of the portal, rather than submit them by email or messaging system.

Depending on the nature of the issue, the GCB may either proceed with the application while addressing the matter or pause it until a satisfactory resolution is received. In certain cases, these issues may result in specific licensing conditions.

Master License Expiry.

The GCB wants to remind users that none of the the Master Licenses will be renewed after their expiration dates. The first expiration date is in August 2024, and the last is in January 2025. If the LOK is enacted before any of these expiration dates, the Master License will automatically end on the enactment date.

Certificate of Operation

Sublicensees that have applications in progress but have not yet been granted a direct license at a time that their associated Master License expires will be offered a “Certificate of Operation” as a temporary measure to facilitate continuation of operations.

Certification of Operations will not be provided to current sublicensees whose Master License expires but do not have fully completed applications registered on the portal.

The GCB is diligently processing all licenses as quickly as possible to optimise the timing of direct license issuance in line with the order of Master License expiration. If operators have not yet received a direct license direct license at that time, the domain token will direct to the Certificate of Operation and Orange Digital Seal rather than the Green Digital Seal.

The Green Digital Seal will be issued once a direct license has been granted.

Domain management

The User Manual on the home page of the portal explains in detail how to add, remove and transfer domains. Please consult this manual as to the actions that must be taken.

Domains are accepted with proof of domain ownership from a registry and any sale/transfer documentation if applicable.

Once a domain is added, the GCB is notified automatically and a manual verification is performed. The domain verification processwill take some days to be completed, after which the Digital Seal may be added to the domain.

Domains that are associated with an application company, but not under the governance of the Master License(s) listed on the application may be added to that application (Orange Digital Seal) but do not fall under the responsibility of the Master Licensor.

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