Edited by Joseph Malvisini

These days, the gaming sector is once again being called into question. On the one hand, there have been renewed proposals for tax increases to "finance" the world of football, and on the other, new investigations have led the Milan Department of Anti-Mafia Investigation and the Reggio Calabria Public Prosecutor's Office to seize several companies with a turnover of €15 million.

A seizure order involving a person residing in the Como area, linked to eight IT companies operating in the gambling sector, with registered offices in Milan, Rome, and Switzerland. A complex investigation uncovered how a hidden partner with a criminal record and affiliation with 'Ndrangheta clans operated behind these companies.

A striking title, intended to once again highlight the close connection between crime and gambling. But let's move on and delve into the actual reading of the article.

We discover that this is the result of a long and complex investigation, where the authorities' financial reconstruction revealed a dense network of personal, family, and business connections, enabling the identification of all associated companies. These companies, intended for the reinvestment of illicit proceeds, also operated in the gaming industry, "among other activities." Given the existence of particularly serious grounds, the Court of Reggio Calabria also ordered the man to be temporarily subject to the restrictions set forth in the Anti-Mafia Code: he will be barred from obtaining police and commercial licenses or authorizations.

Reading further, we see how the investigation was born from numerous reports of suspicious financial transactions.

We can therefore see how, upon closer inspection, the portrayal of the facts is different and can be placed along a different logical line than the sensationalism of the title.

First of all, it can be emphasized that the prevention system is thorough, including that of the gaming industry and the reporting of numerous suspicious financial transactions. I would also venture to assume that the system also involved gaming operators, in a spirit of active participation (subject to the reporting party's duty of confidentiality). Furthermore, building the affiliate network is so complex that it took the authorities themselves years. Therefore, they did their complex job well. On the other hand, this cannot be highlighted by the Concessionaires, given their operations are linked to different sectors. Last but not least, the application of the Anti-Mafia Code is a consequence only of the current seizure of assets.

Reading it in logical opposition: until now, police authorities could potentially have granted a Public Security License with the related authorization for gaming and betting activities. But this is not the case. This is because, in order to issue a TULPS License, the authorities also verify relationships of "mere acquaintance" between the individuals, and given the individual's prior history, the aforementioned authorization would not have been issued. Furthermore, in this case too, there is a preventive reputational analysis that gaming operators (most, if not all) conduct during the onboarding phase of a new point of sale manager. This analysis extends to the entire corporate structure, aimed precisely at identifying (remember, within the limits of a private entity's access to open sources) potential reputational damage involving these individuals, or based on explicit requests for criminal records and pending charges. However, it should be remembered that this approach is in addition to, and not a replacement for, the much more thorough checks that police authorities conduct before issuing the 88 TULPS.

All this just to give, by playing on words, a different interpretation to what is read based on how it is written.

However, the situation is different, with an explicit invitation to the industry to initiate and/or strengthen KWTP (Know Your Third Party) activities in the selection of their commercial partners. This is an important component, which, beyond those related to the reinvestment of dirty money through companies, takes on an explicit role in "protecting" the reputation of individual gaming companies. This screening process, which includes reputational verification, financial reliability, and risk grading, must be considered within the more general fulfillment of licensing obligations as a "publicly licensed operator."