Gambling Regulatory Deadlines to Watch in September

Each month, we leverage data from our gambling regulatory updates to bring you a glimpse of the key response deadlines and legislation effective dates coming up, so you can plan and take action around some of the most important regulatory developments unfolding right now.

In September, there are 7 regulatory deadlines on the horizon — with 4 key consultation periods coming to an end and requiring a response, and 3 actionable deadlines to be aware of coming into effect.

What are the regulatory deadlines to watch in September?

Curaçao

On May 21, 2024, the Curaçao Gaming Control Board published enhanced anti-money laundering (AML) regulations for land-based and online casinos, which supplement the existing AML framework. 

The regulations require a robust AML compliance programme, which must address a system of internal policies and controls, assign a designated compliance officer with day-to-day oversight of the programme, and utilise an independent audit function to test the programme, among other requirements.

Additionally, the regulations require, at a minimum, enhanced customer due diligence and on-going monitoring of identity and transactions, enhanced and simplified due diligence checks based on the risks identified, and unusual transaction reporting obligations. The regulations took effect May 15, 2024; however, all land-based and online casinos are required to comply with the regulations as of September 1, 2024, at the latest.

U.S.

On June 28, 2024, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced a proposed rule to strengthen and modernize financial institutions’ anti-money laundering and counter-terrorism financing (AML/CTF) programs.

Under Title 31 of the United States Code, a casino is considered a “financial institution”. According to the proposed rule, financial institutions would be required to establish, implement and maintain effective, risk-based and reasonably designed anti-money laundering/counter-terrorism financing (AML/CTF) programs with certain minimum components, including a mandatory risk assessment process. Additionally, financial institutions would be required to review government-wide AML/CTF priorities and incorporate them, as appropriate, into risk-based programs, as well as provide for certain technical changes to program requirements. Lastly, the rule is designed to promote clarity and consistency across FinCEN’s program rules for different types of financial institutions. 

The deadline to submit comments to FinCEN regarding the proposed rule is September 3, 2024.‍

Massachusetts‍

On August 2, 2024, the Massachusetts State Lottery Commission (MSLC) issued a request for response (RFR) seeking consultant services related to an online lottery system. According to the RFR, the MSLC intends to contract for consulting services including:

• Research and reporting of current full-service online lottery platforms
• Evaluating options for the MSLC’s online lottery platform
• Identifying options for prospective RFRs
• Developing and issuing agreed-upon RFRs
• Evaluating responses to issued RFRs
• Contracting, assistance during development, configuration, installation and implementation of selected platform
• Assistance in testing and certification of the resulting platform, as well as other miscellaneous tasks as needed

Additionally, the successful respondent will assist the MSLC in writing an RFR for a full-service online lottery platform provider. Responses to the RFR are due by 10am on September 6, 2024. On July 29, Massachusetts Governor Maura Healey signed the fiscal year 2025 state budget that includes language legalizing online lottery sales. Shortly after, the MSLC stated the lottery will be conducting an RFR to procure services for the operation of an online lottery.‍

Belgium

‍On March 1, 2024, the bill amending the Gaming Law was published in the official gazette following the King’s ratification. The bill, adopted by the Belgian parliament on January 25, 2024, aims to improve player protection. The following measures are included in the new law:

• A ban on “3.3 machines” outside of casinos and slot machine arcades, unless they are of an automatic nature.
• A player may be entitled to winnings when their age has not been verified by the operator, and/or they do not reach the minimum age requirements, at the discretion of the Belgian Gaming Commission.
• The accumulation of online licences will be prohibited.
• The minimum gambling age will now be 21 years across all gaming establishments and all games of chance.
• The restriction on promotional offers is now applicable to all licence holders.
• A definition of gambling advertising has now been provided. 

The law becomes effective as of September 1, 2024.

Australian Capital Territory

On July 29, 2024, the Australian Capital Territory (ACT) government launched a consultation on gambling advertising restrictions. The public consultation aims to explore options for restricting gambling advertising, with a specific focus on protecting children and young people. The consultation will specifically explore two options:

• Option 1: Restricting gambling advertising from being placed on radio between 6:00am and 8:30am and TV between 4.00pm and 7.30pm, Monday to Friday (inclusive), except on dedicated sports channels.
  

• Option 2: Restricting gambling advertising in the ACT from being placed on radio between 6:00am and 8:30 am Monday to Friday (inclusive), on TV between 4.00pm to 8.30pm (or later) Monday to Friday (inclusive), and on TV between 6:00am and 8:30pm Saturday and Sunday, except on dedicated sports channels.
  

The government has also said that it is open to hearing about other potential restrictions, including those targeting subscription television and online platforms. The consultation period will end on September 6, 2024, and Canberra residents are encouraged to share their thoughts and experiences on the YourSay website.

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We’ve only shown you a snapshot of September’s deadlines.

Want to see them all? Book a demo with a member of our team, who can show you the full Regulatory Deadlines Calendar for this month.