ADM sets traceability rules for top-up point payments

Italy's ADM has published a director's determination setting the payment instruments that may be used for top-ups and withdrawals from online gaming accounts at top-up points (Punti vendita ricariche, Pvr). The measure aims to ensure traceability of financial flows, strengthen checks on player identity and ensure compliance with anti-money-laundering rules, according to the report. It also sets requirements for instruments other than traditional bank payment methods and a transitional regime for instruments concessionaires already use.

Concessionaires must use only instruments that allow the payer and payee to be identified and that record the date, amount and purpose of the transaction. Bank transfers, direct debits, payment cards and prepaid cards are permitted under the requirements of the decree. The determination 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 operation. The text provides that the instrument may be rechargeable only by its identified holder, through a 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 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 report must be submitted by 31 March 2027, and new instruments may still be introduced after that date.

Operations at Pvr, including cash top-ups, 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 bank or ordinary 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.

To withdraw sums held on a gaming account, the 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 Pvr or other gaming points of sale, including those in 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 sums 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.