“The Swedish government wanted to open the gambling market, but at the same time take back control of the market,” Associate at Nordic Gambling Ario Mansoori

“The Swedish government wanted to open the gambling market, but at the same time take back control of the market,” Associate at Nordic Gambling Ario Mansoori

How does Sweden verify compliance with responsible gambling standards? What challenges do operators face when they license the gambling business? Associate at Nordic Gambling Ario Mansoori answered these and other questions in the interview for Kyiv iGaming Affiliate Conference.

Ario is a Swedish lawyer with 5 years of experience. He specializes in legal support of the gambling business, anti-money laundering, as well as verification of compliance with advertising and responsible gambling standards by operators.

Interviewer: Kyiv iGaming Affiliate Conference (KiAC)

Respondent: Ario Mansoori (А. М.)

KiAC: How did you start your legal practice and when did you decide to focus on gambling law?

А. М.: I have a Master of Laws from Stockholm University, 2014, and have worked with private practice and as an in-house legal and compliance manager since then.

When the first State Public Reports were issued back in March 2017, I immediately followed the political discussions and the regulatory developments in Sweden. I wanted to be one of the first in Sweden who worked with the new Swedish Gambling Act and therefore was keen to join Nordic Gambling 18 months ago.

KiAC: What is the specific nature of your law firm? Tell us about your work at Nordic Gambling.

А. М.: Nordic Gambling is the only legal firm that specializes in gambling-related law and thereto related matters for the Swedish and Danish market. We have an office in Stockholm, Sweden and Copenhagen, Denmark.

I have been mainly working with Swedish license applications and compliance matters.

KiAC: What do you primarily take into account when inspecting operators for compliance with the responsible gambling state standards?

А. М.: In general, I usually verify that I primarily take into account all the provisions regarding responsible gambling requirements included in the Gambling Act (2018:1138), Gambling Ordinance (2018:1475), the Regulations and General Guidance on Responsible Gambling (LIFS 2018:2) and the Regulations and General Guidance on Commercial Online Gambling and Betting (LIFS 2018:5).

A couple of examples include verification that the responsible gambling logos (e.g. self-test, self-restriction on deposit limits and self-exclusion logos) are shown on the websites, checking where the Responsible Gambling logos are located on the websites and ensuring that the Responsible Gambling section is easily accessible for the consumer.

The action plan required to be implemented and put in writing by license holders is also of major interest when reviewing an operator’s responsible gambling standards.

KiAC: What about checking for advertising standards compliance?

А. М.: I normally check if the information provided in the advert is in clear and plain language, if the key conditions are outlined and/or just “one-click” away from the advert, if a link to an organization that helps problem gambling, as well as if the 18+ logo is provided on the websites. As marketing should always be made in moderation, I also review the wording and design of marketing in the light of case law and guidance given by the Consumer Agency.

KiAC: What challenges do you face most frequently, assisting operators in license acquisition?

А. М.: The biggest issue with regards to license acquisition is the vast number of due diligence documents that are needed in order to receive a license and the amount of time it takes to obtain them.

There is generally a skepticism at the SGA against operators with licenses in Curacao and unfortunately, the combination of having operations in Eastern Europe has rendered several questions and additional checks by the SGA.

License acquisition surely was our initially work, but since the Gambling Act entered into force since 1 January 2019, it has been mainly gambling compliance related to AML, responsible gambling, and marketing in Sweden.

KiAC: How has the new Swedish Gambling Act affected the country’s gambling market?

А. М.: The new act represents a complete overhaul of the market. Previously, Sweden had a monopoly system but as per today’s date and since January 1, 2019, there are in total 93 operators who have a license for commercial online gambling and betting. The Swedish government wanted to open the market, but at the same time take back control of the market. Before the reregulation, there were over 200 websites operating in the grey market and targeting Swedish consumers.

KiAC: Did Nordic Gambling partners participate in the development of these regulations?

А. М.: Morten Ronde, Managing Director of Nordic Gambling, has a vast experience with the Danish gambling market and more recently as a Chief Legal Adviser at the Danish Gambling Authority. In his work for the Danish Gambling Authority, he was involved in drafting legislation, issuing gambling licenses and advising the government on gambling policy issues. The Swedish Gambling Act is, in many cases, very similar to the Danish Gambling Act and/or has been derived from the Danish Gambling Act.

Maria McDonald has been advising operators in public consultancies regarding the new Gambling Act and secondary legislation issued pursuant to the Act. In some cases, she has also provided advice and input to the Swedish Trade Associations (BOS and SPER).

Henrik Norsk Hoffmann is a Danish attorney at law and he specializes in gaming law, corporate and commercial law and international commercial and arbitration law. He offers legal advice in regard to gaming law issues in Denmark. He has worked with gaming law since 2002 and has handled some of the most important court cases regarding gambling and in particular poker.

KiAC: Tell us about the activities of the Swedish gambling regulator – Spelinspektionen. How do you cooperate with it in your practice?

А. М.: As soon as an Applicant has paid its license application fee, the Swedish Gambling Authority allocates a case handler to each Applicant, which first then the Applicant may freely contact the case handler if any questions arise during the license application. In this way, the Applicant may build a relationship with the Gambling Authority. Furthermore, the Gambling Authority provides on a regular basis information meetings with the licensees where the licensees may discuss challenges on the market.

Even though we have managed to build a good working relationship with the Gambling Authority and we by now are well familiar with the different case handlers, it should be underlined that the Swedish Gambling Authority does not want to engage in advice or directly cooperate with the industry and that includes any advisor assisting the operators too.

KiAC: What can you say about the player identification system in Swedish gambling venues?

А. М.: As for online gambling, the situation is the following. All Swedish residents, both permanent and temporary, have a personal identification number tightly knotted to each resident as well as a registered home address. This has later been digitalized when a number of large Swedish banks have developed an application called “BankID”, similar to the Danish equivalent “NemID”.

BankID is an electronic identification solution in Sweden, an electronic ID document that is comparable to passports, driver’s licenses and other physical identification documents in Sweden, which allows companies, banks, and government agencies to authenticate and conclude agreements with individuals over the Internet, which is legally binding.

Of a population of approximately 10 million, 8 million use BankID on a regular basis for a wide variety of private and public services. This means that almost everyone over the age of 18 uses BankID in Sweden, which is quite astonishing.

For those that have a license to provide gambling services on venues in accordance with Chapter 9 of the Gambling Act. Personnel at gambling venues for casino games and slot machines must be aware of relevant parts of the Gambling Act (2018: 1138), the Gambling Ordinance (2018: 1475), executive orders, general advice and conditions that apply to the current game, as well as the licensee's internal procedures and guidelines that are relevant to the gambling venue.

This means that the personnel has to know that the minimum age for a player to participate is 18 years, ban on credit, as well as relevant information related to responsible gambling.

KiAC: What will you talk about at Kyiv iGaming Affiliate Conference?

А. М.: I will be discussing player identification in Sweden, both land-based and online, control of payouts, and what challenges may occur.

On December 18, Ario will make a presentation titled “Player identification: why it is essential and what challenges may occur” at KiAC.

You can read more about his report in our announcement.

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