Admiral Pay representative questions traceability of cash gambling deposits

Raffaele Gnazzi of Admiral Pay raised concerns about the rules governing payments in online gambling at a panel at SiGMA World 2026 in Rome. He focused on the use of cash, the traceability of top-ups and the risks tied to applying anti-money-laundering rules. The session was titled "Innovation in payments against illegality and money laundering" in its Italian original.

Gnazzi said that, after years of waiting, a uniform framework for cash use in the digital channel had been expected. He said some limits had been introduced, mainly on withdrawals, but that traceability had been partly lost along the way.

Gnazzi said the €100 limit on cash top-ups at retail sales and recharge points (PVR), which the Council of State had upheld, risked being undermined by provisions in the determination of the Agenzia delle Dogane e dei Monopoli (ADM). He said the Council of State had supported the principle in relation to traceability and also to the prevention of problem gambling. According to Gnazzi, the determination refers to limited-spend instruments without introducing any amount limits. He said that those who know these instruments technically understand that they have very little to do with traceability.

Gnazzi said traceability should allow the whole path of the money to be reconstructed, not just the recording of a transaction. He described this as a risk for gambling operators too, who might believe they could issue these instruments themselves without turning to authorised and adequately structured entities. He said checks in this area would not be limited to ADM but would also involve the Guardia di Finanza, the Bank of Italy and the Financial Intelligence Unit (UIF). Gnazzi warned that operators could later be sanctioned for anti-money-laundering breaches, since complying with the rules on limited-spend instruments does not automatically mean complying with the traceability principle.

Gnazzi said Admiral Pay has long been developing cashless technology, for online gambling and for gaming halls. He noted that the ban on using POS terminals remains in place in gaming halls.

On suspicious transaction reports to the UIF, Gnazzi said that in physical gambling the report is essentially made after the event. He said that in online gambling operations can be blocked in advance, a function exercised by the payment service provider rather than directly by the gambling operator. Gnazzi argued that, if the legislator's aim was to trace money flows, the system should not move away from that direction by reopening the use of untraced instruments.