ADM sets traceability rules for PVR top-ups and withdrawals

Italy's ADM has published a director's directive setting payment rules for top-ups and withdrawals at Punti vendita ricariche (PVR), the agency's notice states. The directive covers the payment instruments that may be used to top up and withdraw from online gaming accounts, with the stated aim of ensuring traceability of financial flows, strengthening checks on player identity and ensuring compliance with anti-money-laundering rules. It also sets requirements for instruments other than traditional bank payment methods and introduces transitional rules for those already used by concessionaires.

Under the directive, concessionaires must use only instruments that allow the payer and payee to be identified and that record the date, amount and reason for the transaction. Bank transfers, direct debits, payment cards and prepaid cards are permitted, subject to the requirements set out in the decree. The directive also allows top-up instruments offered by operators other than traditional payment service providers, provided they meet specific conditions: identification of the holder, exclusive use for topping up the holder's own gaming account, no possibility of transferring the payment to third parties and immutability of the transaction. The text provides that the instrument may be topped up only by its holder, specifically identified, via PIN or voucher or other methods that are in any case uniquely associated with the payment instrument.

Issuers must attest the requirements of alternative instruments through a technical report certified by a third party expert in banking and/or anti-money-laundering matters. The documentation is submitted to ADM through one or more concessionaires and forwarded by the agency to the Guardia di Finanza and the Bank of Italy for checks within their remit. Where requirements are missing or declarations are untrue, ADM may suspend the instrument and impose penalties on the concessionaire.

Instruments already used by concessionaires may continue to operate on a transitional basis if they comply with the requirements. The certified technical report must be submitted by 31 March 2027; new instruments may still be introduced after that date.

Operations carried out at PVRs, including cash transactions, must be recorded in the concessionaire's accounts, either directly or through transmission of the point of sale's accounting data. Records must distinguish top-ups made with ordinary bank or payment instruments, those made with alternative instruments and those made in cash. The separation also serves to verify compliance with the weekly limit on cash top-ups.

For withdrawals, the account holder must indicate an account or payment instrument in their own name. The concessionaire must verify ownership and may not credit the funds if the requirements are not met. Cash withdrawals at PVRs or other gaming points, including those belonging to the same concessionaire's land-based network, are prohibited.

Concessionaires may use one or more e-wallets, managed by authorised and supervised intermediaries, to move funds from dedicated current accounts and pay winnings. A communication to ADM is required, indicating the depositary or treasury bank where players' funds are physically held.

For topping up gaming accounts, the directive treats as instruments suitable for ensuring traceability all services and payment instruments offered by an Italian or EU-established payment service provider that allow funds to be transferred while uniquely identifying payer and payee and recording the date, amount and reason for the transaction. For operators offering alternative top-up systems, demonstrating compliance with the technical and anti-money-laundering requirements becomes central, according to the report.