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Gaming Law 2021

Last Updated November 25, 2021

Law and Practice

Authors

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Kalff Katz & Franssen is the only law firm in the Netherlands with a dedicated practice that specifically focuses on the national and international gaming and gambling sector, and related areas. The gaming and gambling practice group adopts a multidisciplinary approach to advise clients on a range of subjects, such as licensing, compliance, litigation, contracts, public affairs, and privacy and data protections. Kalff Katz & Franssen’s clients include listed B2C and B2B operators, software developers, inspection bodies, financial institutions, payment service providers, Rood Wit Blauw 7 Slot Machine Review, private equity investors, media companies, hosting companies and public authorities. The gaming and gambling practice group consists of nine members. Various members are affiliated with the International Masters of Gaming Law (IMGL) and the International Association of Gaming Advisors (IAGA). Furthermore, the practice group often provides speakers and moderators for conferences and events around the world, as well as regularly writing for sector-specific publications.

Rood Wit Blauw 7 Slot Machine Review 1. Introduction

1.1 Current Outlook

Market Vision

In January 2021, the national regulatory authority for gambling, the Netherlands Gambling Authority (NGA), published the definitive version of its so-called Market Vision on Games of Chance (Marktvisie kansspelen. Marktordening en markttoezicht vanuit de publieke belangen, or "Market Vision").

In its Market Vision, the NGA notes that new operators might need to be offered the opportunity to create attractive gambling offers. Furthermore, the NGA states it is obvious that (state-run) monopolies in some land-based sectors will need to be abolished eventually. This includes monopolies such as lotteries (including scratch cards), sports betting, horse and harness race betting, and casino. Although such changes would require amendments to existing legislation, the Market Vision might very well signal an increased likelihood of future developments within these areas.

Enforcement Approach

On 1 April 2021, the long-awaited regulatory framework for remote gambling entered into force. With the first operators going live in early October 2021, and others trickling in, an important question for 2022 (and today) is how the NGA will approach those that are not licensed.

In September 2021, the NGA published its new approach towards locally unlicensed operators, Rood Wit Blauw 7 Slot Machine Review, which consists of amendments to the NGA’s fining policy and demonstrates a shift away from the established prioritisation criteria-based policy. In this regard, the following principles apply.

• The NGA will no longer focus solely on illegal operators themselves but will also investigate the entire chain of companies involved in the organisation of illegal online offerings. Payment service providers and software providers are mentioned. Previously, only affiliates had been targeted alongside operators.
• As the enforcement capacity of the NGA is not unlimited, the NGA will still set priorities. When setting priorities, the NGA will consider, among other things, the number of Dutch players at unlicensed operators.
• Additionally, the NGA will take into account public policy objectives when deciding where to use its enforcement capacity. These public objectives are consumer protection, prevention of gambling addiction and combating illegality and crime, and the protection of the licensed market.

1.2 Recent Changes

Opening of the Remote Gambling Market

Without a doubt, the most important change of 2021 was the opening of the Dutch remote gambling market on October 1st. There were a few other developments.

• In September 2021, the Minister for Legal Protection (the "Minister") fairly abruptly called upon the NGA to change its enforcement approach just a week before the opening of the remote gambling market. Subsequently, numerous major operators pulled out of the Rood Wit Blauw 7 Slot Machine Review market ahead of submitting their remote gambling licence applications.
• Information on the practical implementation of regulatory requirements is becoming more readily available. In 2020, there was a lack of detailed information, especially regarding the remote gambling process. Over the past year, the NGA has published more detailed policy rules; for example, regarding advertising requirements and reporting obligations. From the first round of applications, it is also becoming apparent where the focus of the NGA lies during its review of submissions.

2. Jurisdictional Overview

2.1 Online

Remote gambling offers without a Dutch licence are prohibited. This prohibition applies to all locally unlicensed offers, regardless of the licence an operator may have in another (EU/EEA) jurisdiction. Licensed operators are permitted to offer various forms of remote gambling, as per the four categories explained in 4.3 Types of Licences. This current section addresses how the regulatory regime shapes gambling offers pursuant to different product verticals.

Betting (in General)

Licensed operators are allowed to offer bets on the outcome of horse racing and harness racing, on the outcome of sporting contests, or events occurring during sporting contests, Rood Wit Blauw 7 Slot Machine Review. However, bets on negative events or events that can be easily manipulated (for example, yellow/red cards) are prohibited.

Bingo

Short-odds, high-tempo bingo games are licensable as casino games.

Casinos

Operators are also allowed to offer:

• casino games in which the players play against the licence holder (eg, blackjack), including live casino games; and
• casino games in which the players play against one another, including live casino games (poker games fall under this category).

Fantasy Sports, Esports and Virtual Sports

Esports betting is allowed, in principle. However, this is subject to the condition that the underlying sporting contest is organised under the auspices of a recognised (inter)national sports organisation, Rood Wit Blauw 7 Slot Machine Review. Until such a time that esports governance reaches this stage, licensed operators will have to refrain from offering bets on such competitions.

Fantasy sports betting is considered as sports betting and is thus permitted. At the same time, fantasy sports betting is only allowed in so far as it is based on (elements from) sporting contests that fit the definition of a sporting contest. Furthermore, the underlying sporting contests must be organised in accordance with the safeguards against match fixing.

Bets on virtual sports are allowed when the outcome is determined by a random number generator. These bets are regulated as casino games.

Lotteries

Holders of a remote gambling licence are not permitted to offer lotteries remotely. Charity lotteries may already be offered online, without having an offline offer, but they are not regulated as remote gambling.

Social Gaming

Social games that do not include prizes or premiums, but only offer the opportunity to play longer, fall outside the scope of the Betting and Gambling Act (BGA).

2.2 Land-Based

The land-based gambling market in the Netherlands consists Rood Wit Blauw 7 Slot Machine Review a mix of state-owned incumbents and private entities, and a multitude of licensing requirements. This section provides a general overview of licensable land-based games of chance. The individual licensing systems are explained further Cashzuma Slots Machine 4.3 Types of Licences.

Readily Available Licences

An unlimited number of licences are available for slot machines. Slot machines can be located in a slot-machine arcade, and in cafes or restaurants targeted towards persons over 18 years of age. Municipalities determine whether slot machines are permitted within their area, and, if so, which other restrictions apply (eg, zoning, maximum number and opening times).

Also, an unlimited number of licences are available for charity lotteries, Rood Wit Blauw 7 Slot Machine Review, but these licences are subject to conditions, including a prohibition on generating private profits. Furthermore, all such offers must be for the public good, with 40% of revenue going to good causes.

Semi-permanent Licences

Single licences exist in the field of horse race betting, sports betting, the instant lottery and the Lotto. The Lotto is a game in which participants can predict a given number of symbols from a predefined range. Subsequently, a Twin Spin Deluxe Online Slot Game is made. The instant lottery is offered in the form of scratch cards (krasloten), whereby prizes are allocated to tickets before sales commence.

Licences for these sectors are referred to as semi-permanent since they are valid for a period of five years and have been reallocated to incumbent licence holders.

Permanent Monopolies

Casino gambling (including poker) is offered by the state-owned Holland Casino, which enjoys a permanent monopoly. Furthermore, the state lottery licence was granted to the Staatsloterij B.V. in 2017 for an indefinite period. The latter essentially perpetuates the permanent monopoly that has long been enjoyed for offering what is essentially “the national lottery”.

Games that Are Exempt from the Licence Requirements

Several forms of gambling are exempt from the "prohibited unless licensed" approach, including small-scale gambling and promotional games of chance. Land-based bingo games can only be offered when they fall within one of these categories.

Small-scale gambling must adhere to a number of requirements. Most importantly:

• the offer has to be notified to the municipality 14 days in advance;
• the prizes (monetary or in-kind) may not exceed the amount of EUR400 per series (or set); and
• the total amount of the prizes may not exceed EUR1,550 per gathering.

Promotional games of chance syndicate casino be organised in accordance with the Code of Conduct on Promotional Games of Chance (Gedragscode promotionele kansspelen), Rood Wit Blauw 7 Slot Machine Review. Important requirements include:

• that prizes cannot amount to more than EUR100,000 per year; and
• a prohibition on charging participants any costs for participation or a stake (excluding the costs for communication up to EUR0.45).

Rood Wit Blauw 7 Slot Machine Review 3. Legislative Framework

3.1 Key Legislation

The Betting and Gambling Act and the Betting and Gambling Tax Act (BGTA) are the primary laws regulating gambling in the Netherlands. The BGA incorporates a prohibited unless licensed approach, whereby it is prohibited to offer games of chance without a licence.

Furthermore, the BGA was amended on 1 April 2021 so as to introduce the remote gambling licensing regime.

3.2 Definition of Gambling

According to the BGA, "games of chance" consist of two elements:

• an opportunity to compete for prizes or premiums; and
• the designation of winners by a means over which the participants are generally unable to exercise a dominant influence.

A prize or premium is defined broadly. The definition includes monetary prizes as well as in-kind prizes. Payment of a stake is not required for a game to be considered a game of chance under the BGA, which increases the prospect of individual games being found to constitute gambling in the Netherlands in contrast to other jurisdictions.

3.3 Definition of Land-Based Gambling

Land-based gambling is not defined separately in legislation. The BGA only mentions those games of chance for which one or more licences can be awarded.

3.4 Definition of Online Gambling

Remote games of chance are defined by reference to the general definition of "game of chance", as provided in 3.2 Definition of Gambling. Additionally, according to the BGA, the following two elements must be present:

• the game of chance is offered remotely, using electronic means; and
• a person can participate without any physical contact with the operator.

3.5 Key Offences

Under the BGA, it is prohibited:

• to offer unlicensed games of chance;
• to promote/facilitate unlicensed games of chance; and
• to knowingly participate in unlicensed games of chance.

Enforcement of these prohibitions takes place primarily by administrative measures, although there are no known cases of players being subject to enforcement measures for having participated in unlicensed offers. There is an option to turn to enforcement via criminal law under specific circumstances, as detailed in the enforcement protocol between the NGA and the public prosecutor.

Following the entry into force of the amended BGA, the scope of the prohibition on promoting games of chance has expanded so as to cover the facilitation of such unlicensed offers. This amendment brought payment service providers into the scope of the prohibition; in December 2017, the Dutch Council of State held that payment providers fall outside the scope of the prohibition in its existing form. The expanded scope applies to providers of other intermediary services, too.

3.6 Penalties for Unlawful Gambling

Breaches of the prohibitions against offering or facilitating unlicensed games of chance (as discussed in 3.5 Key Offences) can be sanctioned by an administrative fine, or a cease and desist order that is subject to a penalty for non-compliance. The maximum administrative fine currently stands at EUR870,000, or 10% of the turnover during the previous year if this exceeds EUR870,000, Rood Wit Blauw 7 Slot Machine Review.

Administrative fines are awarded in accordance with the NGA’s fining policy. The recently amended fining policy rule includes a base fine of EUR600,000.

Criminal sanctions can consist of a fine (up to EUR870,000 for legal entities), imprisonment and community service. Please note that, as indicated, administrative law is the primary enforcement route.

Whilst the NGA generally awards administrative fines to unlicensed operators, it is expected that the NGA may (in first instance) turn to other measures against intermediaries (ie, B2B suppliers). This is described in 11. Enforcement.

3.7 Pending Legislation

At the time of writing (November 2021), Rood Wit Blauw 7 Slot Machine Review amendments to the gambling-specific regulatory framework have been made public. However, an expected development is the permission of e-ID instruments, so as to avoid players having to upload their identity document. At the Rood Wit Blauw 7 Slot Machine Review, e-ID instruments are permitted, but a licence holder always has to obtain a (copy of the) player’s identity document (see 8.2 AML Requirements). A bill, currently before the Dutch Senate (the Digital Government Act), will allow operators to solely rely on an effective ID instrument, so-called eIDAS instruments. It is currently expected that the Digital Government Act will enter into force on 1 July 2022 at the earliest.

4. Licensing and Regulatory Framework

4.1 Regulatory Authority

The independent NGA is the regulatory authority concerned with the supervision and enforcement of the BGA. The NGA is also tasked with the award of gambling licences.

For slot machines, a licence is also required from the local municipality.

4.2 Regulatory Approach Tropical Fish Slots Machine

As stated in 3.3 Definition of Land-Based Gambling, the BGA embodies a prohibited unless licensed approach. This means that all locally unlicensed gambling offers, other than those forms that are exempt from the requirement to be licensed (as referred to in 2.2 Land-Based), are unlawful.

Prioritisation

In performing its enforcement duties, the NGA has discretion with regard to the moment at which it launches enforcement investigations. Therefore, enforcement action by the NGA against locally unlicensed remote gambling offers revolves around a non-exhaustive list of triggers, or questions. The answer to these questions determines the priority of an investigation into a possible violation of the BGA.

The questions are as follows.

• How many Dutch players make use of the illegal offer?
• How harmful is the illegal offer to the public objectives of the NGA?
• Are there any illegal offers or other circumstances that could draw players away from the legal market?
• To what extent does the illegal offer target Dutch consumers?

This enforcement approach entered into effect on 1 November 2021. As mentioned in 1.1 Current Outlook, this new approach had its effect on some major operators that were (passively) available on the Dutch market. Under the old enforcement approach, some operators sought to remain passively available on the Dutch market (eg, without targeting Dutch customers; for example, via advertising), Rood Wit Blauw 7 Slot Machine Review, up until the point that they obtained their Dutch licence. As of 1 November 2021, Rood Wit Blauw 7 Slot Machine Review, these old, so-called prioritisation criteria no longer applied, while any fines that would be levied would likely be far higher than previously was the case. Through reliance on the new prioritisation questions, Rood Wit Blauw 7 Slot Machine Review, the NGA merely seeks to prioritise its enforcement efforts, Rood Wit Blauw 7 Slot Machine Review. It is important to note that locally unlicensed offers that are not prioritised on the black oak casino resort of these questions remain in breach of the law, even though the risk of enforcement might be mitigated.

Enforcement against Intermediaries

As of 1 April 2021, intermediaries such as payment service providers and software providers clearly fall within the scope of the prohibition on promoting/facilitating unlicensed games of chance (see 3.5 Key Offences). The Dutch legislator foresees the use of enforcement measures against intermediaries as an effective weapon in driving unlicensed B2C operators from the market. At the same time, the legislative history underpinning the remote gambling reforms of 2021 suggests that administrative fines will not be the first port of call against an intermediary. Nevertheless, the NGA will decide which enforcement measure it deems most appropriate. The measures available to the NGA are described in 11. Enforcement.

4.3 Types of Licences

Land-Based Gambling

The licensing systems for land-based gambling services are set out in 2.2 Land-Based. Given the nature of the semi-permanent and permanent licensing regimes, only slot machines and charity lotteries are explained further in this section.

Firstly, slot-machine operators can only operate machines for which a valid type approval has been granted. Secondly, operators must possess an exploitation licence from the NGA. Thirdly, slot-machine operators must obtain a licence from the relevant local municipality in relation to the premises in which the slot machines are to be located (premises licence).

Charity lottery licences can be divided into two categories: non-incidental and incidental. Non-incidental lotteries are awarded for a period of more than six months and a maximum of five years. Incidental lotteries are awarded for a period of six months and are allowed a maximum of 13 draws within that period.

For both incidental and non-incidental charity lotteries, 40% of revenue must go to good causes, and operators are prohibited from generating private profit, Rood Wit Blauw 7 Slot Machine Review. Licences issued by the NGA are intended for lotteries with prizes amounting to a Menu Mania Slots Machine of more than EUR4,500. Licences for lotteries with prizes totalling an amount of EUR4,500 or less are awarded by local municipalities.

Remote Gambling

In accordance with the BGA, an applicant can apply for four categories:

• casino games in which the players play against the licence holder (eg, blackjack);
• casino games in which the players play against one another (eg, poker);
• bets on events occurring during a sporting contest or on the outcome of a sporting contest; and
• bets on the outcome of horse racing and harness racing.

The permitted remote gambling services outlined in 2.1 Online fall in one of the above categories.

4.4 Availability of Licences

Land-Based Gambling

As explained in 2. Jurisdictional Overview, there is no cap on licences for charity lotteries and slot machines and in reality these are the only licences that can be considered as being “readily available” in the land-based sphere. However, in terms of slot machines, practice will be determined by the policies of local municipalities.

Remote Gambling

The number of future remote gambling licences is unlimited, but applicants will have to fulfil strict requirements on subjects such as:

• the reliability of the applicant;
• separation of player funds;
• addiction prevention;
• consumer protection; and
• payment transactions.

Furthermore, applicants with an unlicensed presence in the Netherlands will have to consider their compliance with the cooling-off criteria as explained in 4.6 Application Requirements. This will certainly have an impact on the licensing prospects of an applicant.

4.5 Duration of Licences

The offer of slot machines requires three separate documents, with different durations. Firstly, the slot-machine-type approval will, in principle, remain valid unless the model has to undergo changes. Secondly, the exploitation licence is awarded by the NGA for a period of, Rood Wit Blauw 7 Slot Machine Review, in principle, ten years. Finally, the premises licence is awarded by the relevant local municipality. For cafes and restaurants that are targeted towards those over Rood Wit Blauw 7 Slot Machine Review, these licences are usually valid for between one and five years. Different premises licensing regimes (with licensing periods between one and 15 years) apply for gaming arcades.

As mentioned in 4.3 Types of Licences, charity lotteries are awarded for a period of six months, or a longer period (in practice, five years).

Remote gambling licences are awarded for a period of five years.

4.6 Application Requirements

Given that licences are effectively only available for charity lotteries, slot machines and remote gambling, attention only focuses upon these forms here.

Reliability Assessment for Remote Gambling Applicants

One of the key requirements for remote gambling licence applicants is the reliability assessment.

This reliability assessment consists of a two-step approach: a reliability test and probity screening.

Reliability test

The first step in the overall reliability assessment is the reliability test as based on the BGA and secondary legislation. The NGA hollywood casino columbus ohio investigate whether the reliability of the applicant is “beyond any doubt”.

The reliability test includes relevant legal and natural persons, such as shareholders, directors, subsidiaries and ancillary entities to the applicant. The Dutch legislator takes the position that acts and omissions of persons involved in, or surrounding, the applicant entity can affect the reliability of the applicant itself.

Practice shows that the scope of the reliability test is broader than most applicants expect. In itself, this broad scope does not have to be problematic for an applicant’s chances of success. Nevertheless, in the preparation for a licence application it can take some time to identify every person and entity that is considered relevant by the NGA, Rood Wit Blauw 7 Slot Machine Review.

Locally unlicensed presence

An important element of the reliability test is the (previous) presence of the applicant on the Dutch market. If the applicant has, or had, a locally unlicensed presence, the NGA will consider whether it has targeted the Netherlands. For those applications submitted before 1 April 2022, an unlicensed presence on the Dutch market will, in and of itself, not render an applicant as lacking a sufficient degree of reliability. This is an exception to the “default” position surrounding unlicensed offers and the NGA’s assessment of an applicant’s reliability. In order to benefit from this exception, the applicant will have to provide evidence demonstrating compliance with the Rings & Roses slot free demo game cooling-off criteria for the 33 months prior to the date of the application.

A licence applicant will not be deemed to have complied with the cooling-off criteria if, in the 33 months preceding its application:

• the offer was entirely or partially made via a website with a .nl URL extension;
• the website was entirely or partially available in the Dutch language;
• the offer or the operator in question was advertised on television, radio or printed media directed towards the Dutch market (the NGA has explicitly stated that affiliate marketing also violates the cooling-off period);
• domain names with references to things closely associated with the Netherlands in combination with references to gambling – eg, klompenbingo ("clog bingo") or rood-wit-blauw-casino (red-white-blue-casino) – were used for the offer;

• the websites on which the offer was available contained one or more characteristics from which it can be concluded that the offer was targeted at the Netherlands; and/or
• for the purpose of the offered games of chance, payment methods that are solely or primarily used by Dutch residents could be used (iDEAL is specifically referred to in the draft policy rule).

Furthermore, and although this does not reflect whether an offer has targeted the Netherlands, as of 1 January 2020, operators must also have been verifying the age of players before completing the registration process.

Operators with an unlicensed presence that submit their licence application after 31 March 2022 cannot make use of this exception to the default position. As such, the applications Rood Wit Blauw 7 Slot Machine Review operators with a (previous) presence on the Dutch market, submitted after 31 March 2022, will, Rood Wit Blauw 7 Slot Machine Review, in principle, be rejected. The reliability of these operators will not be considered to be “beyond any doubt”.

The NGA will also take into account the unlicensed presence of persons and entities surrounding the licence applicant. Whether an unlicensed presence of these persons will lead to rejection is something that cannot be answered in general terms. In its assessment, the NGA will take into account various circumstances, such as the relationship between the offender and the licence applicant. Furthermore, it is likely that the NGA will consider the offender’s compliance with the cooling-off criteria.

Probity screening

The second step consists of a test based on the Public Administration (Probity Screening) Act (Wet bibob). This test allows the NGA to assess:

• whether there is a danger that the licence will be used to utilise monetary benefits obtained or obtainable from criminal acts; and
• whether a criminal act has been committed in order to obtain the licence.

If the NGA deems it necessary, and in specific situations, it will ask for advice from the Bibob Agency (Landelijk bureau Bibob), which is specialised in integrity assessments and providing advice to government authorities.

Reliability Assessment for Land-Based Slot-Machine and Charity Lottery Licences

The reliability assessment as described above for remote gambling applicants does not apply to land-based slot-machine (exploitation) licence applications and charity lottery licence applications. Moreover, no policy equivalent to the cooling-off criteria prevails. However, applicants for these licences will have to fulfil requirements regarding integrity and reliability. The NGA’s investigation Rood Wit Blauw 7 Slot Machine Review include an assessment of:

• the financials of the applicant;
• its antecedents;
• its organisational structure; and
• business relationships with other natural or legal persons.

Furthermore, applicants for land-based slot-machine and charity lottery licences could also be subjected to a test based on the Public Administration (Probity Screening) Act.

4.7 Application Timing

The NGA has six months to assess a remote gambling licence application. This period can be extended by another six months. Internally, the NGA divided the licensing process in two phases:

• information gathering; and
• decision-making.

During the first phase, the NGA allows a licence applicant to amend and improve application documentation in light of feedback and critique that it provides. After the application dossier is considered complete, the NGA will move to the second phase. In this phase, the applicant is not permitted to change any application documentation, except for specific circumstances, and a decision is taken on the application.

Licence applications for slot machines, incidental lotteries and charity lotteries have to be completed within eight weeks. This period can be extended depending on (additional) information required from Rood Wit Blauw 7 Slot Machine Review applicant.

4.8 Application Fees

Fees for slot machines consist of the fees for both premises and exploitation licences. According to the information provided by the NGA, premises licences are set by individual municipalities with a maximum of EUR22, plus EUR34 per slot machine. The exploitation licence awarded by the NGA is subject to a one-off fee of EUR1,815.12, and a yearly fee per player seat (in 2021, this average yearly fee was EUR113.50 per player seat).

Fees for incidental charity lottery licences depend on the total amount of the prizes that can be won:

• prizes totalling an amount above EUR4,500 and up to EUR50,000 are subject to a fee of EUR500;
• prizes totalling an amount above EUR50,000 and up to EUR500,000 are subject to a fee of EUR4,100; and
• prizes totalling an amount above EUR500,000 are subject to a fee of EUR24,000.

The fee for non-incidental charity lottery licences, with prizes totalling more than EUR4,500, sits at EUR28,000.

Remote gambling licences are subject to a non-refundable licence application fee of EUR48,000.

4.9 Ongoing Annual Fees

As described in 4.8 Application Fees, the exploitation licence for slot machines is subject to an annual fee of EUR453.78.

Although not an annual fee as such, remote gambling licence holders will be required to pay a levy of 1.95% of gross gaming revenue (GGR), which will cover two things: 1.7% of GGR designated to cover the annual costs associated with the NGA’s performance of its tasks, whilst the other 0.25% covers costs associated with the addiction prevention fund.

A similar levy applies to lotteries (both incidental and non-incidental) with GGR above EUR1 million. The levy is applied progressively, in four brackets, on the basis of the lottery’s GGR.

5. Land-Based Gambling

5.1 Premises Licensing gold coast casino

As explained in 4.3 Types of Licences, a premises licence is required for slot-machine operators. These licences can be awarded by local municipalities. Specific requirements including opening hours, location and number of slot machines are determined by the relevant municipality in which the operator has its premises.

The existing 14 casinos within the Netherlands are all operated by the state-owned Holland Casino. Other venues calling themselves casinos are not actual casinos; they are not allowed to offer games that are supervised by human dealers but only machine-based gambling.

5.2 Recent or Forthcoming Changes

Land-Based Gambling Monopolies

The land-based licensing systems were introduced based on the premise of a restrictive legal offer. The rationale was that open licensing systems should only be introduced in the sectors where it was necessary. In 2011, Rood Wit Blauw 7 Slot Machine Review, the State Secretary for Justice & Security stated that there should be more room for an attractive gambling offer. However, most land-based licences (such as the State Lottery, the Lotto, the instant lottery, horse race betting and sports betting) are still awarded to a single operator – on a permanent or semi-permanent basis. To date, legislative reform only altered the regulatory landscape in terms of remote gambling.

On 21 January 2021, the NGA published the final version of its Market Vision on games of chance in the Netherlands. The NGA called for the abolition of land-based gambling monopolies, Rood Wit Blauw 7 Slot Machine Review, although any change of this degree will require amendments to primary legislation.

State Monopoly on Land-Based Casinos

An expected, key reform was the end of the state monopoly on land-based casinos in 2019. Plans to privatise Holland Casino and to remove its monopoly on land-based casinos eventually failed on 17 May 2019. The bill that was supposed to arrange the privatisation of Holland Casino and the removal of the monopoly was under consideration at the same time as the bill on remote gambling. During the Senate debates in February 2019, Rood Wit Blauw 7 Slot Machine Review, several parties expressed their doubts regarding the simultaneous liberalisation of both the remote gambling sector and the land-based casino sectors following the adoption of both bills.

As the Minister did not expect to find a majority on the privatisation of Holland Casino, he asked the Senate not to vote on the bill. Eventually, the Minister withdrew the bill on privatisation completely on 17 May 2019. In his letter of 17 May 2019, the Minister stated that privatisation was still preferred by the Cabinet. At the time of writing (November 2021), there are no indications as to when a bill will be (re-)introduced to this end.

6. Online Gambling

6.1 B2C Licences Rood Wit Blauw 7 Slot Machine Review

As indicated in 2.1 Online, the remote gambling licensing regime allows the offer of most gambling verticals. Subjects that are addressed during the licensing process include:

• the reliability of the applicant (including shareholders and directors);
• financial continuity;
• the separation of player funds;
• addiction prevention;
• consumer protection;
• anti-money laundering and countering the financing of terrorism;
• integrity; and
• outsourcing.

An important restriction on the use of remote gambling licences is the prohibition on anonymous payment instruments. Payment instruments can, in principle, be used if those instruments have been issued by a bank or payment institution that is licensed in accordance with EU regulations.

Furthermore, operators are not permitted to offer lottery services remotely on the basis of a remote gambling licence.

Licence holders are permitted to operate multiple brands and/or domain names under one licence. At the same time, this option is somewhat restrictive given the obligation that the licence holder can only have a single player account per person, per licence.

Position towards Foreign Jurisdictions

The remote gambling licensing regime is aimed at players in the Netherlands. Remote gambling services licensed in the Netherlands are not to be exported to other jurisdictions on the basis of the operator’s Dutch licence.

Remote gambling licences obtained overseas are not, and will not Rood Wit Blauw 7 Slot Machine Review, recognised in the Netherlands. Locally unlicensed gambling offers available to Dutch customers remain illegal even if the operator in question is licensed abroad. The Dutch Supreme Court, in its 2005 Ladbrokes decision, adopted a very low threshold for a gambling offer to be considered “available in the Netherlands”. There is no requirement in terms of specifically "targeting" the Dutch market, nor is it necessary for one or more Dutch residents to have actually participated in a particular offer.

6.2 B2B Licences (Suppliers, Software, Etc)

The BGA does not include a licensing system for B2B service providers. Service providers such as software suppliers and affiliates are, in principle, free to provide their services to locally licensed remote gambling operators. Licensed operators will be responsible for ensuring that all suppliers comply with regulatory requirements flowing from the Dutch regulatory regime.

As such, B2C operators are subject to requirements regarding outsourcing. Licence applicants are required to submit their outsourcing policy to the NGA, Rood Wit Blauw 7 Slot Machine Review, which will assess this policy during the application Rood Wit Blauw 7 Slot Machine Review and will investigate the risks associated with the outsourcing of certain activities to third parties. The NGA will specifically assess safeguards within an applicant’s policy and relevant contracts to ensure that all relevant regulatory requirements will be upheld, and standards met, despite the fact that the applicant intends to rely on third parties for particular elements of their operation. Furthermore, Rood Wit Blauw 7 Slot Machine Review, during application, and thereafter, B2C operators must notify the NGA of certain tasks and activities that are outsourced.

Ultimately, licence holders will remain responsible for advertising activities performed by affiliates.

6.3 Affiliates

Prior to the opening of the market, the NGA performed periodic investigations into affiliate marketing for locally unlicensed gambling offers, and affiliates have been subjected to cease and desist orders on the basis of Article 1(1)(b) of the BGA (the prohibition on promoting/facilitating unlicensed games of chance). Practice demonstrates that the NGA allows affiliates 48 hours, one week or two weeks to discontinue all advertising activities for unlicensed operators. The cease Wild Witches Short Game Guide desist orders in question were subject to a penalty of EUR1,500 for every day the affiliate failed to comply with the order, with a maximum penalty of EUR21,000.

Affiliate marketing for licensed offers is allowed. Affiliates servicing these operators are required to comply with advertising requirements under the BGA, and under secondary legislation, via the licensed operator. In light of the legislative requirements, the NGA published a Policy Rule on Responsible Gambling that also applies to affiliate marketing activities aimed at the Netherlands, Rood Wit Blauw 7 Slot Machine Review. The Policy Rule on Responsible Gambling replaced the existing Guidelines for Gambling Advertising 2016 (Leidraad reclame voor kansspelen), which also covers unlicensed offers and those with a role in the advertising of games of chance (eg, affiliates).

6.4 White Labels

Neither the regulatory regime, nor the NGA, provides explicit guidance on the use of white labels. However, the requirements that are in place provide some information on white-label solutions that can or cannot be offered under the Dutch gambling regime.

Whilst licence holders are permitted to operate multiple brands and/or domain names under one licence, some white-label solutions are restricted by the "one player account" rule (see 6.1 B2C Licences); ie, Rood Wit Blauw 7 Slot Machine Review, a licence holder can only offer one player account to any individual player. Consequently, various actions (including responsible gambling measures) would, Rood Wit Blauw 7 Slot Machine Review, when set in relation to one brand, apply to all brands being supplied on the basis of the same single licence. In this situation, the brands operating under the white-label licence will be unable to compete with each other.

The "one player account" rule, combined with the lack of a B2B licensing regime, makes life difficult for white-label providers that would ordinarily obtain a licence and offer turnkey solutions to other parties. The regulatory requirements basically entail that such a white-label provider would have to obtain a licence for each competing brand.

6.5 Recent or Forthcoming Changes

As indicated in 3.7 Pending Legislation, 2022 may see the passing of the Digital Government Act, which permits the use of eIDAS instruments, so as to avoid players having to upload their identity document.

Furthermore, it is expected that 2022 will see minor amendments to a number of secondary pieces of legislation. An important development is expected to be an amendment that will allow payment instruments issued by electronic money institutions to be used for payments between players and operators.

Additionally, (some) remote gambling licence holders have worked on an advertising code for remote gambling. The code is based on a self-regulatory document already in place for the land-based gambling sector. Eventually, the advertising code for remote gambling should be a practical implementation of key advertising requirements (see 9. Advertising). At the time of writing, a timeline on this topic is not available.

6.6 Technical Measures

In terms of locally unlicensed offers, the NGA takes the position that operators are in breach of the BGA by being available to Dutch customers, even when such offers are only passively available. This means that operators that do not use geo-blocking instruments, and that do not prevent the registration of Dutch customers, are at a greater risk of enforcement measures being taken. However, the lack of geo-blocking measures has never, in practice, been a standalone trigger for enforcement measures by the NGA. Furthermore, the use of geo-blocking measures is not required to be compliant with the cooling-off criteria (concerning licensing prospects), as explained in 4.6 TurboVegas Casino No Deposit Bonus Codes Requirements, Rood Wit Blauw 7 Slot Machine Review.

The NGA has the ability to issue binding instructions to intermediaries, such as affiliates and payment service providers, to hinder the ability of a B2C operator to reach consumers in the Netherlands. However, the NGA is not allowed to use a binding instruction so as to force Triple Dragon Fortune Slot Review blackout of a certain website (for example, via an IP or domain name system (DNS) block).

In relation to. nl domains, the NGA can contact the entity managing the registration of .nl domain names to ensure that unlicensed gambling content is no longer available in the Netherlands.

7. Responsible Gambling (RG)

7.1 RG Requirements

All licensed operators are subject to an “active duty of care” to prevent gambling addiction. Furthermore, Rood Wit Blauw 7 Slot Machine Review, land-based casinos, land-based slot-machine operators and remote gambling licence holders are required to have at least one addiction prevention representative for the Dutch market. According to the Remote Gambling Decree (RGD), the representative does not need to be a resident of, or be established in, the Netherlands. Instead, the representative has to be sufficiently present in the Netherlands to carry casino go their duties. Further details are included in the Policy Rule on Responsible Gambling.

Furthermore, the recently amended BGA introduces several important new tools to combat gambling addiction. One of these tools is Rood Wit Blauw 7 Slot Machine Review CRUKS system (Centraal Register Uitsluiting Kansspelen). Land-based casinos, land-based slot-machine arcade operators and remote gambling operators must check whether a player is registered in CRUKS, before admitting the player. Players who are registered in CRUKS, regardless of whether registration was voluntary or involuntary, must not be granted access to these games of chance.

There are other requirements designed to protect players from engaging in excessive participation. Remote gambling licence holders, for example, may not personalise bonuses to the behaviour of an individual player. This includes the offering of a bonus as well as tailoring the amount of the bonus to the player’s behaviour. An example is offering a bonus when the player has incurred a significant loss or leaves the game. Furthermore, licence holders will not be able to offer an individual player a bonus for a certain period of time after a responsible gambling intervention measure has been taken. The Jumping Beans Slot Machine Review severe the intervention measure, the greater the period of time for which no Feng Kuang Ma Jiang Slots Machine can be offered.

7.2 Gambling Management Tools

Knowledge of, and insight into, the current addiction prevention policy and the risk factors of specific games of chance are compulsory for managers and persons in key positions within the remote gambling licence holder's company. An operator’s addiction prevention policy must also be developed, applied and maintained in co-operation with addiction care experts. The addiction prevention policy must include a description of how the licence holder co-operates with addiction care experts, and a description of how information on addiction is provided to players.

Another key requirement for remote gambling is the option for players to set limits for their gaming behaviour. These limits can refer to:

• the maximum duration of access to the player interface;
• the maximum monetary amount in deposits; and
• the maximum credit in the player account.

8. Anti-money Laundering (AML)

8.1 AML Legislation

On 21 May 2020, the Netherlands implemented the Fifth AML Directive (EU-2018/843). Currently, casinos and all remote gambling licensees fall within the scope of the revised Dutch AML Act (Wwft). The NGA issued a non-binding guidance document on the AML Act for remote gambling licence holders and land-based casinos.

8.2 AML Requirements

Relevant gambling operators will have to follow a risk-based approach with regard to drafting and implementing their AML policy.

An important consequence of AML obligations is the requirement for licence holders to obtain a (copy of the) player’s identity document during the registration process. In time, operators may implement eIDAS instruments, so as to avoid players from having to upload their identity document (see 3.7 Pending Legislation).

Furthermore, operators must demonstrate that they constantly monitor their business relationship with the customer and money transactions, by means of customer due diligence (CDD) checks. CDD data on higher-risk players must be updated more frequently; this concerns, for example, players from Catsino Online Slot Game areas.

Unusual transactions, conducted or intended, must be reported to the Financial Intelligence Unit (FIU Nederland). Whether a transaction is unusual must be assessed on the basis of objective (ie, transactions reported to the police) and subjective (ie, reason to assume a connection to money laundering) indicators.

9. Advertising

9.1 Regulatory/Supervisory Agency Rood Wit Blauw 7 Slot Machine Review

The NGA is also the regulatory authority concerning advertisements for gambling offers. As noted in 6.3 Affiliates, the NGA has taken action against advertisements for unlicensed gambling offers on the basis of the BGA.

The Advertising Code Committee (Stichting Reclame Code) is responsible for enforcement on the basis of the self-regulatory Dutch Advertising Code (Nederlandse Reclame Code). Currently, the Code only applies to incumbents. The Code is currently under review and the scope of the Code is being discussed between some remote gambling licence holders (see 6.5 Recent or Forthcoming Changes).

9.2 Definition of Advertising Cash Flow Slots Machine

The BGA prohibits the “promotion” of unlicensed games of chance. This definition, Rood Wit Blauw 7 Slot Machine Review, according to parliamentary history and jurisprudence, captures a broad array of advertising activities, such as:

• the placement of advertisements in newspapers;
• the distribution of flyers; and
• having advertisement materials in stock.

Since the Council of State decision on 22 January 2020 (Content Publishing Limited), it is clear that promotional texts on affiliate websites fall within the scope of the prohibition. Hyperlinks to an unlicensed operator’s website and the use of banners also fall within the scope of the prohibition.

9.3 Key Legal, Regulatory and Licensing Provisions

According to the BGA, secondary legislation and the Policy Rule on Responsible Gambling, advertisements for games of chance may not be misleading regarding factors such as:

• the characteristics of the game of chance on offer;
• the chances of winning; or
• the commitment of the participants.

Furthermore, advertisements should improve responsible participation in gambling offers.

Currently, land-based operators are permitted to carry out sponsorship activities in accordance with the provisions of the Dutch Advertising Code. Under the secondary legislation, remote gambling operators are permitted to sponsor teams and individual athletes in return for the neutral mention or display of their name, trade mark, figurative mark, or any other distinctive sign.

9.4 Restrictions on Advertising

Currently, Rood Wit Blauw 7 Slot Machine Review, all (linear) television and radio gambling advertisements are prohibited from 9am to 7pm, except for neutral messages concerning the sponsorship of a television programme. For all readily available licences, thus including remote, and the instant lottery, the watershed for gambling advertisements on television is extended to the period between 6am and 9pm.

Furthermore, Rood Wit Blauw 7 Slot Machine Review, advertising activities may not be aimed at minors, nor may these activities include the use of role models younger than 25 or role models with a substantial younger audience. This prohibition includes the use of sportspersons, sports teams and influencers with an audience on social media platforms. The use of retired sportspersons is allowed.

Advertisement activities during sporting contests for (live) bets on those specific contests are prohibited, except for advertisements on the licensee’s website.

As explained in 3.5 Key Offences, Rood Wit Blauw 7 Slot Machine Review activities for locally unlicensed gambling offers fall within the prohibition on promoting unlicensed games of chance (Article 1(1)(b), BGA).

9.5 Sanctions/Penalties

In January 2015, the Dutch Supreme Court decided that the advertisements by the State Lottery in the period 2000–07, and once in 2008, were misleading. Statements from the State Lottery in advertising campaigns regarding the winning odds, the number of prizes won and the prize money were incorrect.

As such, the Rood Wit Blauw 7 Slot Machine Review Court found it plausible that most consumers would not have bought the lottery tickets if the State Lottery’s advertisements had been accurate. Following this decision, in 2020, the Court of Appeal in ‘s-Hertogenbosch decided that the State Lottery had to pay approximately EUR8,000 to one participant who bought lottery tickets between 2000 and 2008.

Under the regime as it existed prior to 1 April 2021, the NGA issued cease and desist orders for the advertisement of locally unlicensed remote gambling offers. The responsible entities were granted a period of 48 hours to comply with the order. Failure to comply will result in a penalty of EUR1,500 for every day they remain non-compliant, with a maximum penalty of EUR21,000. Sanction decisions are also published on the NGA’s website.

In 2021, the NGA collected a penalty of EUR10,000 for non-compliance with a cease and desist order. The offender was an incumbent that was sanctioned for violating the prohibition on targeting minors with gambling advertisements. Advertisements of the incumbent were visible on a website with an audience largely consisting of minors. This cease and desist order included a maximum penalty of EUR100,000.

eldorado casino Elf and Safety Slots Machine 10. Acquisitions and Changes of Control

10.1 Disclosure Requirements

All licence holders (both land-based licensees and future remote gambling licensees) must inform the NGA without delay of any relevant changes in the organisational structure of the company, and any relevant changes to the information provided in the context of the licence application.

10.2 Change of Corporate Control Triggers

The BGA, secondary legislation and the applicable licence award decision identify several changes that must be notified by the relevant land-based or remote gambling licence holder to the NGA. These triggers include:

• changes in shareholders and ultimate beneficial owners;
• the granting of suspension payments;
• changes in management positions;
• changes in the legal form of the licence holder;
• the transfer of its seat; and
• corporate acquisitions.

Most corporate control changes trigger a notification procedure but do not require the NGA’s pre-approval. However, Rood Wit Blauw 7 Slot Machine Review, the NGA will assess a notified change on the basis of the submitted documentation.

10.3 Passive Investors Requirements

As indicated in 4.6 Application Requirements, the remote gambling licence procedure contains a strict reliability assessment. In the event of mergers, splits or changes of control, the NGA must be able to assess the The Last King of Egypt Slots Machine of the new shareholders and persons with effective control over the licence holder. Similar requirements exist for other licences.

11. Enforcement

11.1 Powers

As indicated in 3.6 Penalties for Rood Wit Blauw 7 Slot Machine Review Gambling, enforcement takes place primarily via administrative law. Prior to regulatory changes on 1 April 2021, the NGA generally issued administrative fines against operators and cease and desist orders against affiliates. The authors are also aware of instances in which the NGA has attempted to take action via SIDN, the entity managing the registration of .nl domain names, Rood Wit Blauw 7 Slot Machine Review, to ensure that content relating to unlicensed remote gambling offers was no longer available in the Netherlands.

As noted in 3.5 Key Offences, the scope of the prohibition on promoting Rood Wit Blauw 7 Slot Machine Review of chance was expanded following the entry into force of the amended BGA. Currently, the NGA is able to use its enforcement capabilities against payment service providers and other intermediaries.

One of the new enforcement measures for the NGA is the binding instruction. Binding instructions allow the NGA to demand from entities that they cease certain activities, such as providing payment or advertising services to locally unlicensed operators. Following an amendment to the remote gambling bill in 2016, this binding instruction cannot be used against internet service providers.

Another instrument is the public warning, which essentially boils down to naming and shaming. As of 1 April 2021, the NGA will also be able to undertake mystery shopping exercises, which was previously not the case.

11.2 Sanctions

Sanctions can effectively be enforced against:

• legal entities based in the Netherlands;
• foreign legal entities with assets in the Netherlands; and
• employees or contractors carrying out work in the Netherlands.

Enforcement of administrative sanctions can take place without a court order. Enforcement against operators and persons established abroad, or persons passing through the Netherlands, is more difficult as no general international law instrument exists for the cross-border enforcement of administrative sanctions.

11.3 Financial Penalties

Financial penalties can be enforced by the NGA on the basis of administrative law, without a court order. As noted in 11.2 Sanctions, the cross-border enforcement of administrative sanctions (including financial penalties) is more difficult. If a foreign entity is unwilling to pay, the NGA will hand financial penalties over to a bailiff/debt collection agency in order to pressure operators to pay. The NGA will also publish the refusal to pay on its website.

12. Recent Trends

12.1 Social Gaming

According to the NGA’s Market Vision, social casino games that do not offer any prizes but only offer the opportunity to play longer fall outside the scope of the BGA.

12.2 Esports

Esports betting is only allowed when the underlying esports contest is organised by, or under the auspices of, the national sports organisations recognised by the Netherlands Olympic Committee (NOC*NSF) or by a comparable international sports organisation. At the time of writing, there are no esports competitions that fulfil these criteria. As such, licensed esports betting is currently unavailable on the Dutch market.

12.3 Fantasy Sports

Bets on fantasy sports may be offered but are subject to the same restrictions as esports betting.

12.4 Skill Gaming

Skill games do not qualify as a game of chance. Therefore, skill games fall outside the scope of the BGA and are thus unregulated.

12.5 Blockchain

Under the remote gambling regime, Rood Wit Blauw 7 Slot Machine Review, only payment transactions that have been issued by a credit institution or payment service provider – with a licence as referred to in Directive 2013/36/EU or Directive (EU) 2015/2366, respectively – are permitted. Furthermore, operators may only allow the use of those instruments that can be unambiguously traced to the individual player as a person. Therefore, it is the authors' understanding that payment instruments that use blockchain technology cannot be used by gambling operators.

12.6 Reform

As referred to in the above, the NGA’s Market Vision may signal the beginning of another approach towards land-based monopolies. However, significant changes are not expected very soon.

13, Rood Wit Blauw 7 Slot Machine Review. Tax

13.1 Tax Rate by Sector

Currently, licensed games of chance are taxed at a rate of 29%. It is the operator Flower Slots Machine is regarded as the tax subject under the BGTA, not the player.

Gambling tax is based upon GGR for land-based slot machines, land-based casino gambling, land-based sports betting and horse race betting, and all licensable remote gambling categories. For other licensed offers, prizes won constitutes the tax base. However, gambling tax is only due on prizes greater than EUR449.

All remote gambling licensees, and specific lotteries with a GGR above EUR1 million, pay an additional annual levy as referred to in 4.9 Ongoing Annual Fees.

Trends and Developments

Cashing Rainbows Slots Machine Author

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Kalff Katz & Franssen is the only law firm in the Netherlands with a dedicated practice that specifically focuses on the national and international gaming and gambling Rood Wit Blauw 7 Slot Machine Review, and related areas. The gaming and gambling practice group adopts a multidisciplinary approach to advise clients on a range of subjects, such as licensing, compliance, litigation, contracts, public affairs, and privacy and data protections. Kalff Katz & Franssen’s clients include listed B2C and B2B operators, Rood Wit Blauw 7 Slot Machine Review, software developers, inspection bodies, financial institutions, payment service providers, private equity investors, media companies, hosting companies and public authorities. The gaming and gambling practice group consists of nine members. Various members are affiliated with the International Masters of Gaming Law (IMGL) and the International Association of Gaming Advisors (IAGA). Furthermore, the practice group often provides speakers and moderators for conferences and events around the world, as well as regularly writing for sector-specific publications.

2021: the Remote Gambling Market Slowly Opens

After a protracted legislative process, on 1 April 2021 the Netherlands Gambling Authority (NGA) was able to open the much-awaited licensing process for remote games of chance. A total of 29 licence applications were submitted. The NGA had undertaken that those applicants that were able to apply in the first two weeks of April would be able to go live six months later, pending the successful outcome of their application, of course.

It was not until the very end of September that the successful applicants learnt who they were. In total, ten licences were awarded. Speculation was rife during the 2021 Gaming in Holland conference as to which parties would be able to commence their operations a few days later. Naturally, the NGA was tight-lipped during the conference but revealed that many of those that had floundered had failed to satisfy the tight standards around technical requirements.

Ten successful licensees does not mean that the remaining 19 were all unsuccessful; some will have gone into overtime to get their houses in order.

Previously, however, in June 2019, the NGA had announced that some 79 parties had expressed an interest in applying for a remote gambling licence. What is happened to the rest? Naturally, there will be some operators that are waiting to see how the market develops and seek Cbet Bonos De Casino enter based upon the experiences of the first-movers. Many operators are currently waiting in the wings, as timing is crucial.

Biding time, cooling off

Operators that have (had) a locally unlicensed market presence have to get the timing of their application right. Apply too soon, and they will be deemed to lack the necessary degree of reliability. The same fate will be met should they apply too late. For those that have had such a market presence, even if entirely passive in nature, it is necessary to demonstrate 33 months of compliance with the cooling-off period prior to submitting the licence application. This relates not only to the applicant entity itself, but also the broader corporate structure to which the applicant belongs. However, the licence application must reach the NGA before 1 April 2022. After this date, the NGA will no longer exercise any leniency towards those that have had an unlicensed offer, and recourse will be had to the default position. This entails that an unlicensed presence renders an applicant as unreliable. Therefore, there may very well be operators that cannot satisfy the 33-month requirement ahead of the 1 April 2022 cut-off.

The cooling-off criteria were heavily inspired by the prioritisation criteria by which the NGA determined, prior to a change in policy applicable as of 1 November 2021, whether or not an offer was targeting the Netherlands and ripe for enforcement measures. Therefore, compliance with the criteria entails that for a period of 33 months prior to the application, the remote gambling offer was:

• not made via a website with a .nl extension;
• not provided in the Dutch language;
• not subject to advertising that targeted the Dutch market (in terms of radio, TV Rood Wit Blauw 7 Slot Machine Review print-based media advertising);
• not made using domain names that refer to the Netherlands;
• not Rood Wit Blauw 7 Slot Machine Review using websites that contained characteristics that target the Netherlands (eg, clogs and windmills); and
• did not use payment methods that are typically used in the Netherlands (ie, iDEAL).

In contrast, operators that have not had a Rood Wit Blauw 7 Slot Machine Review unlicensed presence are free to apply whenever they choose. Being unburdened by such a legacy, such operators were able to take advantage of the staggered approach for documentation, which applied for those applying during the first fortnight of April. Equally, such operators can apply at any time before, and after, Rood Wit Blauw 7 Slot Machine Review, 1 April 2022.

2022 – a busy year ahead

2022 will be a busy year for the licensing page of the NGA’s website. The tail end of 2021 will likely see several applications being submitted by those whose 33 months have come to an end. All those that must abide by the cooling-off criteria will, if their 33 months end before April 1st, have to get their applications in by this date. There will likely be a rush of submissions by those that are able to apply, in Q1 2022. Assuming that the NGA is able to reach a decision on the majority of these applications within the six-month period, which will not always Deuces Wild Poker 4 Hand Slots Machine the case, many new licences will be awarded in Q2 and Q3 2022. The occasional licence will be awarded to those that did not have to cool off. Successful licences, which went into overtime, will also trickle on to the NGA’s overview.

Only ten licences were awarded for 1 October 2021, and a month later, not all had gone live, thus the market will really start to take shape during 2022 as the bulk of new entrants make their way on to the scene. It Rood Wit Blauw 7 Slot Machine Review be interesting to see how the market, and the regulatory dynamics, develop.

Relationship between the NGA and the market also takes shape

Indeed, Rood Wit Blauw 7 Slot Machine Review, not only are market dynamics yet to start playing out at the time of writing (November 2021), the real workings of the NGA’s approach to supervision and enforcement of licence holders remains shrouded in the mists of the future. To date it has not released any detailed information as to how it intends to flex its supervisory muscle in relation to licensed operators. Many operators, and their suppliers, will have faced many Rood Wit Blauw 7 Slot Machine Review moment when preparing for a licence when they will have had to second-guess how the NGA will interpret a particular provision.

In a number of limited instances, during the licence application stage, it proved possible to get some insight into matters of interpretation from the NGA, but in the majority of instances where questions of interpretation were posed, the NGA’s response was muted. During the licence review process, the NGA took issue with some points in some applicants’ policies, but by and large, the feedback was relatively limited on this point, Rood Wit Blauw 7 Slot Machine Review.

Licensees should not rest on their laurels and assume that the mere fact they have been awarded a licence entails that their policies are fully compliant. The NGA stated that everything will come to rest on the implementation and application of policies, which is understandable given that the policies do not directly translate into behaviour on the market, Rood Wit Blauw 7 Slot Machine Review. It will be what operators do, not what they say they will do, that will count. Nevertheless, the regulations leave room for interpretation and this will undoubtedly filter through into future practices. Naturally, therefore, operators will also have taken differing approaches to some requirements; the question is whether each interpretation is compatible with regulatory provisions.

Such matters of uncertainty are part and parcel of a new regulatory regime settling in. Yet the overarching question is, should the NGA take a different view at some point in the future and how will it go about addressing it? There is a myriad of issues that could trigger discussions in the future. For example, will the NGA and operators be in agreement about the adequacy of measures implemented to ensure that player funds are separated from risk-bearing capital, and can funds be paid out to players should an operator not be in a position to do so? Will operators have correctly interpreted and apply requirements around responsible gambling and advertising? Will the NGA consider that sufficiently robust measures have been taken to prevent advertising on social media targeting young adults, between the ages of 18 and 24 years old. And, which questions will arise once the NGA starts to analyse data deposited in the control database?

Moreover, what will be the defining nature of the dialogue between operators and the NGA? It is not yet clear whether, Rood Wit Blauw 7 Slot Machine Review, and to what extent, Rood Wit Blauw 7 Slot Machine Review, the NGA will engage in informal discourse with operators, and seek an exchange of views, where the market and the NGA take a different view on matters. Or, will the NGA move fairly directly to taking formal enforcement measures? As such, the extent to which Rood Wit Blauw 7 Slot Machine Review NGA will engage in real dialogue remains to be seen. Existing answers to questions on matters of interpretation, prior to the first licences having been awarded, bear witness to the NGA generally taking a position that is most favourable to consumers. To what extent will the NGA be willing to listen and take matters of practicality into account? Whilst the NGA’s role is not to promote the business interests of its licensees, seeking impractical interpretations of requirements and keeping licensed operators out in the cold in terms of dialogue will not necessarily favour a regulatory regime that is conducive to reaching the legislator’s channelisation objectives. Indeed, when the legislative reforms were proposed, the objective was to channel 80% of the market into the locally licensed regime.

Hoping for balance

Too little consideration for what is feasible will only serve to deter some operators from making a market entry, or potentially encourage some to throw in the towel and withdraw their licensed presence. This will only feed the need for effective enforcement measures against unlicensed operators that attempt to profit at the expense of those that work within the constraints and costs of the regulated market. There will be a limit to what the regulated market can support in terms of such constraints and costs. Will the NGA undertake its tasks in such a way that the need for enforcement measures is not unnecessarily increased or magnified? Time will tell. A fair and balanced development is to be hoped for.

Law and Practice

Authors

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Kalff Katz & Franssen is the only law firm in the Netherlands with a dedicated practice that specifically focuses on the national and international gaming and gambling sector, and related areas. The gaming and gambling practice group adopts a multidisciplinary approach to advise clients on a range of subjects, such as licensing, compliance, litigation, contracts, public affairs, and privacy and data protections. Kalff Katz & Franssen’s clients include listed B2C and B2B operators, software developers, inspection bodies, financial institutions, payment service providers, private equity investors, media companies, hosting companies and public authorities. The gaming and gambling practice group consists of nine members. Various members are affiliated with the International Masters of Gaming Law (IMGL) and the International Association of Gaming Advisors (IAGA). Furthermore, the practice group often provides speakers and moderators for conferences and events around the world, as well as regularly writing for sector-specific publications.

Trends and Development

Author

---

Kalff Katz & Franssen is the only law firm in the Netherlands with a dedicated practice that specifically focuses on the national and international gaming and gambling sector, and related areas. The gaming and gambling practice group adopts a multidisciplinary approach to advise clients on a range of subjects, such as licensing, compliance, litigation, contracts, public affairs, and privacy and data protections, Rood Wit Blauw 7 Slot Machine Review. Kalff Katz & Franssen’s clients include listed B2C and B2B operators, software developers, Rood Wit Blauw 7 Slot Machine Review, inspection bodies, financial institutions, payment service providers, private equity investors, media companies, hosting companies and public authorities. The gaming and gambling practice group consists of nine members. Various members are affiliated with the International Masters of Gaming Law (IMGL) and the International Association of Gaming Advisors (IAGA). Furthermore, the practice group often provides speakers and moderators for conferences and events around the world, as well as regularly writing for sector-specific publications.

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Wat is de levertijd van de iPhone 12 Pro?

Dat hangt af van het model. Sinds het begin van de verkoop (op 23 oktober 2020) zien we zeer wisselende levertijden. Sommige uitvoeringen van de iPhone 12 Pro zijn heel moeilijk te verkrijgen en worden soms pas weken na bestelling geleverd, Rood Wit Blauw 7 Slot Machine Review. Andere modellen hebben juist helemaal geen levertijd.

De levertijd van de iPhone 12 Pro hangt van meerdere factoren af. De ene kleur is bijvoorbeeld meer in trek dan de andere uitvoering. Ook de hoeveelheid opslagcapaciteit, provider en of je het toestel los of in combinatie met een abonnement maken een verschil in hoe snel je ‘m binnenkrijgt.

→Check de actuele iPhone 12 Pro-levertijd per webwinkel en provider

Wat is de prijs van de iPhone 12 Pro?

De prijzen van de iPhone 12 Pro zijn ongeveer gelijk aan die van de iPhone 11 Pro van 2019. Het instapmodel heeft een adviesprijs van 1162,10 euro en 128GB opslag. Deze vreemde adviesprijs komt door de per 1 januari 2021 verhoogde thuiskopieheffing. Uiteraard kun je de iPhone 12 Pro bij providers en webwinkels inmiddels voor onder de adviesprijs krijgen.

iPhone 12 Pro met 128GB voor 1162,10 euro
iPhone 12 Pro met 256GB voor 1182,10 euro
iPhone 12 Pro met 512GB voor 1512,10 euro

Wat is het design van de iPhone 12 Pro?

Een belangrijke verbetering van de iPhone 12 Pro ten opzichte van zijn voorganger heeft te maken met het design. Apple gooit het ontwerp iets op de schop en heeft de 12 Pro een nieuwe, hoekigere behuizing gegeven, Rood Wit Blauw 7 Slot Machine Review. Het frame is van metaal en het scherm is ‘plat’. Hierdoor doet de iPhone 12 Pro een beetje denken aan de iPad Pro. Door het laagje Ceramid Shield is de iPhone beter beschermd tegen vallen.

De achterkant is van glas en daardoor is draadloos opladen weer van de partij. De iPhone 12 Pro ondersteunt ook MagSafe, dat via magneetjes ervoor zorgt dat je de telefoon ‘draadloos’ kan opladen. Natuurlijk moet je de MagSafe-opladers alsnog met een kabeltje van stroom voorzien.

Wat voor scherm heeft de iPhone 12 Pro?

Het scherm is bovendien groter geworden: 6,1 inch in plaats van 5,8 inch. Toch is de 12 Pro niet per se groter dan zijn voorganger, omdat de randen iets dunner zijn. Het zogeheten Super Retina XDR-display heeft een hoge resolutie van 2532 bij 1170 pixels, een oled-paneel voor mooie kleuren en diepe zwarttinten en hdr-ondersteuning.

In het scherm steeds nog steeds een notch, die plaats biedt voor de Face ID-sensoren die geavanceerde gezichtsherkenning mogelijk maken. Er wordt dus een hapje uit het scherm genomen en daar is niet iedereen fan van.

Wat voor camera heeft de iPhone 12 Pro?

Vorig jaar kreeg de iPhone 11 Pro een grote camera-upgrade met de introductie van een derde cameralens en de Nachtmodus. Dit jaar gebruikt Apple ongeveer hetzelfde camerasysteem, maar wel aangevuld met een LiDAR-sensor.

Deze kennen we van de iPad Pro 2020 en zorgt ervoor dat de camera de afstand tussen het toestel en een object (of persoon) kan meten. Daardoor kan de diepte heel nauwkeurig worden ingeschat, wat de kwaliteit van de Portretmodus en augmented reality-apps (AR) ten goede komt. De IKEA-app maakt bijvoorbeeld gebruik van AR om de dimensies in jouw woonkamer te schatten.

Op de achterkant van de Pro-iPhone zitten drie camera’s. Het gaat om een normale camera, Rood Wit Blauw 7 Slot Machine Review, groothoeklens voor extra wijde foto’s en telelens om in te zoomen, Rood Wit Blauw 7 Slot Machine Review. De camera’s zijn verbeterd en werken nu bijvoorbeeld allemaal met de Nachtmodus, zodat je altijd een scherp plaatje maakt als er even wat minder licht is.

Daarnaast kun je video’s maken in 4K-resolutie en met 60 frames per seconde en is het mogelijk om 10 bit-hdr-filmpjes te maken. Deze functie is meer bedoeld voor gebruikers die video’s maken serieus nemen. De autofocus is verbeterd en de door de vernieuwde optische beeldstabilisatie maak je ook scherpe foto’s als je handen trillen.

Wat zit er in de verpakking van de iPhone 12 Pro?

Apple en ophef gaan hand in hand. De afgelopen jaren haalde het bedrijf uit Cupertino regelmatig op een negatieve manier de voorpagina’s. Denk maar aan de iPhone X uit 2017, die toentertijd werd gehekeld vanwege de inkeping in het scherm, of de AirPods-oordopjes, die belachelijk werden gemaakt vanwege hun design.

Dit jaar gaat de ophef om de accessoires van de iPhone 12. Apple levert alle iPhone 12-telefoons namelijk zonder oplader en oordopjes (EarPods) in de doos. Apple heeft meerdere redenen voor dit controversiële besluit.

Ten eerste wordt het milieu zo gespaard. Jarenlange iPhone-gebruikers hebben waarschijnlijk al een oplader en/of oordopjes in huis, en zitten niet per se op nieuwe exemplaren te wachten. Daarbij scheelt het niet-meeleveren van de accessoires simpelweg geld. Apple kan op die manier onder meer besparen op de productiekosten, verpakking en vervoer.

Ondersteunt de iPhone 12 Pro 5G?

Langzaam maar zeker activeren Nederlandse providers hun 5G-netwerken. Of de nieuwe iPhones met de opvolger van 4G aan de slag kunnen, Rood Wit Blauw 7 Slot Machine Review, was lange tijd onduidelijk. Tijdens de keynote maakte Apple echter meteen duidelijk dat de nieuwe iPhones – en dus ook de iPhone 12 Pro – geschikt zijn voor 5G.

Door de 5G-ondersteuning streamen iPhones sneller films en series, heb je beter bereik in drukke omgevingen en minder latency, wat van pas komt bij bijvoorbeeld online games.

5G is momenteel al beschikbaar in Nederland en rolt de komende jaren breder uit. Vanaf 2022 wordt het netwerk hier pas écht snel, want dan gaat het belangrijkste onderdeel onder de hamer: de 3,5GHz-frequentieband. Op dit moment zijn de snelheidsverbeteringen nog klein.

Welke processor en software heeft de iPhone 12 Pro?

Voor de officiële aankondiging stonden al vast welke processor en softwareversie de iPhone 12 Pro zou krijgen. Het toestel wordt aangedreven door de nieuwe A14 Bionic-chip, die ook in de nieuwe iPad Air 2020 zit. De processor is krachtiger dan zijn voorganger, maar ook zuiniger én is bovendien geschikt voor 5G. Daarmee is het toestel helemaal klaar voor de toekomst.

Verder draait de beste iPhone 12 bij uitkomst op iOS 14, de grote software-update die Apple in 2020 uitbracht. Bovendien kun je rekenen op jarenlang updates, zodat je een hele poos met je nieuwe iPhone kan doen. Meer weten over de nieuwste iOS-versie? Neem dan een kijkje in onze uitgebreide iOS 14 review.

iPhone 12 vs iPhone 12 Pro: wat zijn de verschillen?

Er zijn meerdere verschillen tussen het instapmodel en de Pro-versie. Een belangrijke zijn camera’s. Beide Pro-modellen hebben dankzij de toevoeging van een telelens drie cameralenzen op de achterkant. Een telelens wordt ook wel zoomlens genoemd, omdat je hiermee beelden dichterbij kunt halen.

Verder huizen de Pro-modellen in een behuizing van roestvrij staal, terwijl de 12 (mini) van plastic is en hebben de duurste toestellen meer opslag en werkgeheugen. Ze kunnen hierdoor meer apps tegelijkertijd draaien zonder dat het sloom aanvoelt.

De Pro-iPhones zijn gericht op een professionele doelgroep en komen daarom in zakelijke kleuren: goud, grafiet, oceaanblauw en zilver. De iPhone 12 komt in vijf kleurrijkere varianten: donkerblauw, mintgroen, rood, wit en zwart. Tot slot is de prijs natuurlijk verschillend. De iPhone 12 Pro kost honderden euro’s meer dan het basismodel.

→ Lees verder: iPhone 12 vs iPhone 12 Pro: dit zijn de 5 belangrijkste verschillen

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Wil je de iPhone 12 Pro kopen? Dat kan! Een losse iPhone 12 Pro is vanaf 1162,10 euro verkrijgbaar. Bij een iPhone 12 Pro met abonnement betaal je dit bedrag in maandelijkse termijnen af. Het toestel is bij alle providers verkrijgbaar en ook webshops bieden ‘m aan. Gebruik onze prijsvergelijker om actuele deals met elkaar te vergelijken.

iPhone 13 is gearriveerd

De opvolger van de iPhone 12 Pro staat alweer voor de deur. De iPhone 13 Pro verscheen in september 2021 en heeft een flink verbeterd scherm, toegankelijkere camera en meer opslag. Ook is het toestel uitgerust met een nieuwe A15 Bionic chip voor nóg betere prestaties en zelfs een langere accuduur. Daarnaast kwam ook de nieuwe iPhone 13, de iPhone 13 mini en de iPhone 13 Pro Max uit. In de toestelvergelijker hieronder zie je direct de belangrijkste verschillen tussen de iPhone 12 Pro en de 13 Pro.

→Alles over de iPhone 13 Pro, de beste nieuwe iPhone van 2021

Rood Wit Blauw 7 Slot Machine Review De iPhone 11 Pro, 12 Pro en 13 Pro naast elkaar

Lees verder na de advertentie.

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Steun iPhoned

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