violation of regulation and not for financial sanctions. NN: Carl, Malta is the principal hub for online gaming within the European Union therefore, I know that you will have maybe a slightly different perspective. You obviously have to regulate your industry and increasingly be seen to do so in a way which is respected for a variety of reasons. But you also have a sensitivity as to the challenges that your regulated entities face in trying to navigate restrictions in other member states. So when you hear of a Maltese business being fined in say, the UK or the Netherlands, what is your perspective as a domestic regulator? Do you then go and visit them? Do you speak to them about it? And if yes, what does that conversation involve? CB: Normally the chat starts from them. They will inform us before we get to know publicly. So our operators will normally be proactive and inform us. We will obviously look into the breaches with regards to potential illegal gambling, for example, illegal in terms of that jurisdiction, we have a license condition for all our licensees that they need to have a justifiable reason for operating in a particular market. We might not always agree with certain jurisdictions as to whether the justifiable reason exists or not. But we will look into that. When it comes to normal administrative breaches say, RG, for example, which is of common interest to any regulator, we will look into the breach, we will look into how the breach happened. But then there is a very significant difference. First of all, between the various requirements in different jurisdictions, which is, I think, a problem for the EU in and of itself. Now, it’s convenient for me to say from a Maltese perspective, but I genuinely think it’s a problem. And in Europe, we rarely mention the need for these regulated entities to make money, but they are businesses. And the more diverse and the more strict the requirements are, and the more you have to navigate differences between jurisdictions, I think the more difficult it is to make money in a sustainable way and focus your efforts where they have to be. Parking that for a moment, there is a difference between a breach of a very specific requirement. Then we’ll see whether that requirement also exists under our legislation or not. And whether the breach is more systemic, whether it is attitude based, for example, is there no compliance attitude when it comes to responsible gaming, and then that is where it will feed into our own prudential supervision as well. So if we see something which is concerning, we have externally conducted audits, we have responsible gaming audits, AML CFT, examinations, the whole spectrum. So, depending on the nature and severity of the breach, we will act accordingly. NN: Since we’re touching on enforcement, the controversial Bill 55 is a hot topic and I think it’s helpful maybe if you could just briefly discuss what Bill 55 seeks to achieve and whether or not it’s directly relevant to what we’re discussing today. CB: Yes there are some common misconceptions around Bill 55. It does not apply to administrative penalties. It is purely a player-operator or operator-player issue. And I think it’s been blown a bit out of proportion, even by misinterpretations in the media as to what it does, that it’s an invincible shield. I mean, we’re in the Star Wars themed panel, but I think we’re over exaggerating. Essentially, there are a number of requirements that have to be met for enforcement to be denied in a civil or commercial judgment that has been issued in another member state. It is an interpretation of an already existing part of the regulation itself, just Brussels one request, which is public order. The legislator simply took the opportunity to clarify what the public policy and public order of the country is for this particular sector. But given the timing of it, naturally it was blown out of proportion, but the timing was necessary, because there are a number of cases that are being pursued and it is the first time that the courts were faced with this issue of what the public or the public policy of the country has in this particular sector. So the legislator felt the need to clarify it within legislation. That’s about all it does. NN: Okay, so it isn’t an existential challenge to the supremacy of European law, generally. CB: Well. I am not going to comment on the judges’ interpretation. The judges will give their own interpretation to the various laws. But if one reads the parliamentary debates, it’s very clear that that is not the intention behind the law. NN: Does anybody have any questions from the audience?
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