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EL public order
News 27 Feb 2024

Gambling Enforcement: Contesting ‘Malta Bill 55’, fighting AML and a view from a regulator

The contentious ‘Malta Bill 55’, protecting Malta’s interest against international legal actions, was a primary focus during EL’s recent Public Order Seminar in Brussels.

Attorneys from countries arguably most affected by the Bill – Austria and Germany – joined the debate which examined the legality of the Bill. The attorneys have filed thousands of cases against Malta based online operators to claim back losses by players.

It was generally expected that Bill 55 would not hold in the end. The interconnected  case C-440/23, where Germany’s national gambling legislation is being challenged from abroad by Malta, was also discussed and although seen as a remarkable case, it remains to be seen what its effect will be.

International data showed further an increase in AML (anti-money laundering) related fines and regulatory debates worldwide. In house best practices on AML regulations were discussed, pointing at the need to understand the activities as well as to have a structured internal process to recognise and flag money laundering.


Top: Joe Ewens, Vixio Gambling Compliance. Bottom: Tineke Ockhorst, Nederlandse Loterij & Marta Saiz Diaz, SELAE

Atle Hamar

Atle Hamar, Director General of the Norwegian Gaming & Foundation Authority Board Member of GREF

Mr Atle Hamar, Director General of the Norwegian Gaming and Foundation Authority Board Member of the Gaming Regulators European Forum (GREF), provided an insightful European perspective on gambling regulation but also reflected on Norway being “the last man standing” in Europe with most of its gambling market organised as a state monopoly. Mr Hamar emphasised the need to have a balance between attractive games and social responsibility which also follows EU regulation.

The importance of enforcement was also approached by a series of experts in the field on topics ranging from a recent European Court ruling which found FIFA/UEFA to breach competition laws (SuperLeague case) to the phenomenon of Class actions with a preventive proposal developed by Israel’s National Lottery Mifal Hapais, and from the importance of the Macolin Convention to fight sport manipulation, to the ‘regulatory rainfall’ after the opening up of the online market in The Netherlands.

collage public order

Top: Philippe Vlaemminck, EL Legal Adviser, Dr Karim Weber, Attorney, Elena Marks, Attorney. Bottom: Geert Delrue, Former Detective Police Commissioner, Guy Goudesone, Former Judicial Police Commissioner, Gilles Maillet, President, ULIS

The EL Public Order seminar looked also beyond the borders of Europe regarding public order issues.


Samuel Awuku, Director General of the Ghana National Lottery Authority

Mr Samuel Awuku, Director General of the Ghana National Lottery Authority gave an insight overview on lottery regulation in Ghana and how to combat illegal gambling in this part of Africa. Some of the measures highlighted include, using security agencies with state of the art tech to zone in and arrest online scammers, working with the police to conduct nationwide arrests and disrupt illegal lottery activity, establish Lotto Courts nationwide, and raise awareness about responsible gaming through public campaigns.

To conclude, it is clear that the landscape of gambling regulation is complex, with swift and intricate changes. Operators find themselves facing more enforcement actions than ever before, with the fines issued defining public perception of the sector. With increasing scrutiny, operators must ensure compliance with rules and regulations.

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