AGSI's Guitto seeks clarity on wallet withdrawals at dual-mandate PVRs

Antonio Guitto, vice-president of AGSI, has asked how ADM's ban on paying withdrawals from gaming accounts at PVRs applies to shops that also provide payment services under a mandate from an intermediary. The question follows ADM's directive on traceable payment instruments, according to the report.

ADM's direttorial determination no. 675265/RU of 22 October 2026 requires sums withdrawn from a gaming account to be credited, after the concessionaire's checks, to an account or payment instrument held in the player's name. It also prohibits the concessionaire from allowing withdrawal by payment at PVRs or other gaming outlets, including those in its own network.

The case raised by Guitto concerns the step after crediting: the money is already available on the customer's personal wallet and the customer asks to withdraw it through a service of the intermediary. Guitto asked why, if he holds a mandate from a financial operator to market payment services in addition to being a PVR, he cannot meet a withdrawal request.

According to the report, the focus is on the services that actually allow cash withdrawal, within the limits of the intermediary's authorisations and the activities entrusted to the shop. The presence of an ATM inside a PVR also requires distinguishing the place where the withdrawal occurs from the party providing the service, since a customer using an automatic teller in the shop deals with the circuit that manages the withdrawal.

The report states that a dual mandate does not by itself constitute an exception to the ADM prohibition. It adds that assessing a service offered directly by the shop on behalf of an intermediary requires examining the mandate, the characteristics of the instrument and how the operation is actually carried out.

The report also notes an operational aspect: the shop may not know the origin of the sums on the customer's instrument, since a balance can come from different credits and a cash request alone does not identify its source. This does not remove the control obligations for the service, but shows the difficulty of tracing every withdrawal made in the shop to a withdrawal from a gaming account.

According to the report, the determination does not expressly address this specific combination of activities, and the question is how to distinguish payment of sums requested from the concessionaire from a subsequent withdrawal service authorised by the intermediary and carried out on the customer's personal instrument.