SBC News

As Finland continues to iron out finer details of its gambling framework ahead of a 2026 launch, stakeholders remain fearful over the current direction being taken when it comes to affiliates and digital marketing.

The cogs of the new legislation will turn throughout the year ahead of the commercial market going live in July 2027. Sports betting and online casino licences will be issued from March, but Lotto, Eurojackpot and physical slot machines will remain under the control of the state-owned operator Veikkaus.

Final decisions will be made on several different components of legislation before the market launches, but alarm bells have been raised that the current direction of the marketing framework will have a major impact on the prosperity of smaller operators.

Digital direction

Jari Vähänen, Co-Founder & Partner at The Finnish Gambling Consultants, believes marketing regulation is unclear at the moment and that it should be leaning more towards the digital scope.

“The legislation approved in December remains imprecise regarding marketing, so it isn’t easy to assess the marketing opportunities in the future license-based market for now,” noted Vähänen.

“According to my interpretation, large operators with sufficient funds to participate in ‘brand advertising competitions’ in mass media will have good business opportunities. On the other hand, the upcoming restrictions on digital marketing will pose challenges for smaller operators. Therefore, there is a risk that several companies will continue to operate in the black market.

“I would have liked to allow licensed companies to compete with modern digital marketing tools and would have preferred to limit mass media marketing, because it targets everyone, not just customers interested in gambling.”

Hippos ATG Chief Compliance Officer, Antti Koivula, is in agreement with Vähänen that limitations in digital marketing could create significant issues in the newly regulated Finnish commercial market.

“My concern is that the new rules are fairly permissive for traditional mass media and sponsorships, but very strict for digital marketing. This creates two big problems.

“First, it pushes more marketing into mass media that people cannot really avoid, including minors and vulnerable groups. If the goal is to reduce harmful exposure, the logic should be the other way around: stricter limits on mass media, and a controlled but workable space for targeted, age-gated digital marketing.

“Second, digital marketing will not go away by prohibiting it. Affiliates, influencers, social media and other digital marketing channels will still exist. If licensed operators cannot use these channels, unlicensed operators will.

“Expecting these channels to stop targeting Finland is unrealistic unless enforcement becomes very strong, including across borders. And right now, that does not look likely. If legal operators cannot compete where people actually discover brands, channelisation will drop, and all the negative effects will follow.

“Overall, I am extremely worried that the current choices will do the opposite of what the reform is meant to achieve: they will help the black market, increase harm, and reduce channelisation.”

Marketing must be responsible

Last month, the country’s gambling bill achieved a bipartisan 158-9 vote to move away from a monopoly of Veikkaus to a regulated, licensed market. Only the President’s signature is required for the bill to become law.

Finland’s National Police Board will make licensing decisions before the Licensing and Supervision Agency takes over regulatory responsibilities in June this year. The process for B2B licences will begin in July next, with a licence becoming a requirement for the market by July 2028.

Koivula urged Finland to change lanes completely in terms of the marketing direction that the country is currently travelling in.

“The starting point is simple: licensed operators must be allowed to market enough so people can find them, compare them and choose them,” stated Koivula.

“If legal operators cannot be seen, demand will not disappear. It will move to the black market. That means less consumer protection, more harm and less tax income for the state.

“At the same time, marketing must be responsible. Finland should not repeat the trend we have already seen under the monopoly system, where gambling harms have grown rapidly. Minors and other vulnerable people must be protected. That requires clear and consistent rules that push marketing into places where exposure can be limited and checked.”

Affiliates may continue to operate with black market

Vähänen also believes that, despite the ban on affiliate marketing, promotions could still occur with black market operators.

“I believe the Finnish media will not accept advertising from black-market operators. At least this has been the case so far. Instead, I am terrified that affiliates will continue to operate, and black market operators will be their only customers, because licensed companies are not allowed to use affiliates.

“The success of the entire gambling system will depend on how the new regulator is able to prevent the business of companies operating without a Finnish license. Unfortunately, I am sceptical about this, but I hope I am wrong.”

Vähänen added that casino operators will be impacted by the ban on affiliate marketing, stating that 50% to 90% of customers are acquired through that channel. Other restrictions will affect operations as well.

“A considerable means is the use of welcome bonuses, which will also be prohibited under the new Finnish system. I assume that the current affiliates that attract Finnish customers will continue their operations and, in particular, direct Finnish casino customers to black market operators.

“This will probably not be as big a problem in the betting business. Influencers are a subcategory of affiliates. I myself would have been ready to ban influencers, but I would have liked to allow, for example, betting and, why not, casino comparison sites.”

The year ahead

Outstanding components that still need to be fine-tuned and clarified include secondary legislation, where game characteristics (e.g. autoplay, bonus buys), maximum stake levels, and game speed will be determined; technical regulations; as well as further guidance on certain key interpretative issues, particularly in areas such as marketing.

How these developments will be issued remains to be seen beyond the dates listed above, as Finland’s parliament will not reconvene until next month, with the election of the President and Vice-Presidents on 3 February, the opening of the 2026 parliament the following day and an oral question and answer session taking place on 5 February.

With 2026 set to be a big year for Finland’s gambling future, what kind of marketing direction should be set out for the European market when commercial operators go live in July 2027?

Turkey’s Financial Crimes Investigation Board MASAK has been granted expanded authority to verify financial transactions to “prevent the proceeds of crime”.

The new powers were confirmed by the Ministry of Treasury and Finance in the latest issue of Turkey’s Official Gazette. It formally notifies public authorities and businesses of new compliance obligations that MASAK will begin to enforce from 1 February 2026.

Under the amended General Communiqué, MASAK is authorised to supervise and mandate identity-verification processes for online transactions, with the directive stating that obligations are being strengthened “within the scope of preventing money laundering and terrorist financing”.

The reforms align with the governing AKP government’s unified strategy against illegal gambling, unlicensed betting and online crime. The policy follows a direct pledge made by President Recep Tayyip Erdoğan, who has instructed state institutions to intensify action against illegal gambling networks ahead of Turkey’s next general election.

MASAK’s authority now extends across multiple digital-facing sectors, including gambling and betting activities, e-commerce services, fintech and payment providers, as well as insurance and pension operators. The communiqué notes that obligated entities must ensure customer identification procedures are applied “before the establishment of a business relationship or execution of a transaction”.

Specific provisions apply to gambling and betting transactions, under which banks are required to verify that payments originate from a bank account that “matches the identity information of the customer”. MASAK states that customer acceptance and transaction processing must not take place until verification is completed in accordance with the new rules.

The framework is designed to ensure that, once verified, gambling-related transactions can only be processed through Turkey’s state-authorised operators, including İddaa (sports betting), Milli Piyango (lotteries) and Türkiye Jokey Kulübü (horse racing). The directive emphasises that these controls are intended to “prevent misuse of financial systems” and to “reinforce lawful fiscal channels to Turkish state enterprises”.

All financial institutions facilitating payments will be required to adopt enhanced customer onboarding procedures to ensure accounts are not falsified, misrepresented or connected to prior criminal activity.

The new powers granted to MASAK are specifically designed to prevent crime syndicates from accessing Turkish payment rails and to disrupt mule accounts and falsified identities within Turkey’s economic system.

The communiqué makes clear that accounts opened under the new framework “shall not be used until identity verification is completed”, effectively embedding banks and payment service providers into Turkey’s digital identity-verification architecture.

Full State Control

Following President Erdoğan’s pledge, Turkish authorities have been instructed to ramp up monitoring and enforcement against illegal online gambling across all state institutions.

MASAK has been charged with leading the government’s wider “Action Plan” to eradicate illicit gambling, coordinating actions with the Ministry of Justice. As part of this effort, Justice Minister Yılmaz Tunç introduced reforms under the 11th Judicial Package, granting prosecutors enhanced powers to seize, suspend and prosecute assets and bank accounts linked to illegal betting operations.

At the close of 2025, the Ministry of Justice also instructed Turkish banks to issue direct warnings to customers, stating that engaging in or facilitating illegal online gambling could result in criminal prosecution and conviction.

President Erdoğan and Minister Tunç have warned that the fight against illegal gambling operators will not be confined solely within Turkish borders. In 2026, MASAK has been instructed to prosecute and take down illegal operators that have knowingly targeted Turkish citizens with gambling offers from jurisdictions including Cyprus, Georgia, North Macedonia and Armenia.

Taking on its expanded powers, MASAK now sits at the centre of Turkey’s all-out enforcement regime under the government’s Action Plan. The strategy reflects the clear political direction set by President Erdoğan, who has stated his intention to eradicate illegal gambling activity that authorities believe has penetrated the Turkish state, its banking and payments infrastructure, the digital economy and professional football.

French audiences have been reminded of their rights to be removed from all gambling communications and promotions via voluntary self-exclusion.

On Monday 5 January, l’Autorité Nationale des Jeux (ANJ), the Gambling Authority of France, launched a new digital campaign to enhance public awareness of “Interdiction Volontaire” — the national self-exclusion register for gambling harms.

The campaign has been developed in partnership with French digital media outlet BRUT, with the aim of presenting audiences with “real testimonies” on gambling addiction, its risks and its consequences.

The series is led by the testimony of recovering addict Bilel, a former gambler reflecting on his addiction and his decision to protect himself through the voluntary gambling self-exclusion scheme offered by the ANJ.

Voluntary self-exclusion is described by the ANJ as a strictly personal and confidential process, allowing individuals to protect themselves from risks associated with excessive gambling, including financial harm, psychological distress linked to addiction and social isolation.

Last November, the ANJ announced the launch of France’s new self-exclusion register, which spans both online and land-based gambling, via interdictiondejeux.anj.fr. Players authenticate their identity, complete a dynamic selfie through IDnow and receive confirmation once the ban is activated.

The ANJ confirmed that + 88,000 citizens are currently registered on the FNIG, representing an increase of 25% over the past two years. January has been identified as the peak period for new registrations, coinciding with New Year resolutions and increased demand for protective measures.

The exclusion applies for a minimum period of three years and cannot be revoked during that time. The registration process is conducted online and is designed to be completed in just a few minutes through a secure digital procedure.

The ANJ monitors licensed gambling operators to ensure that self-exclusion measures are clearly promoted to consumers and that advertising does not portray gambling as risk-free, unrealistic, or as a means of generating income.

Kansspelautoriteit (KSA), the Gambling Authority of the Netherlands, has transitioned to a new governance structure to strengthen oversight of enforcements and player protections.

Effective from 1 January 2026, the KSA operates under a new board comprising one full-time chair supported by two part-time directors. The reform comes as KSA reforms its internal departments that will now function as “three principal directorates”.

Changes will help the KSA sharpen its mandate on improving player protection, digitalisation and data-driven supervision. The regulator said the new structure is intended to “respond to the increasing complexity of gambling oversight, driven by technological developments such as artificial intelligence, the growth of illegal gambling supply, and intensified international regulatory cooperation.”

Chairman Michel Groothuizen remains in charge of day-to-day operations, acting as the organisation’s primary leader both domestically and internationally. Groothuizen will be supported by two part-time board members, whose recruitment and appointment process is at an advanced stage.

The new directors’ are expected to provide strategic expertise and act as sparring partners in areas including governance, integrity and digital transformation.

The change in operational structure sees KSA transition to the three directorates: Player Protection & Management Advice, Permits & Supervision, and Digitalisation, Analysis & Business Operations. The new structure is intended to create “clearer lines of responsibility and enable faster decision-making, while allowing the board to focus more explicitly on strategy, framework-setting and oversight of statutory and societal objectives.”

The transition marks the departure of Vice-Chair Bernadette van Buchem, who has served on the KSA board since 2018. Van Buchem is concluding a 40-year career in public service, including senior roles at the Ministry of Economic Affairs and the Netherlands Authority for Consumers and Markets (ACM).

The governance changes come at a pivotal moment for Dutch gambling, as the Netherlands prepares for a broader legislative overhaul in 2026. The Kamer maintains its pledge to repeal and replace the Remote Gambling Act (KOA), the framework which launched the regulated online gambling market in 2020.

Progress on reform was paused following the collapse of the Dutch conservative coalition government leading to the Netherlands Snap Election in Novemer 2025.

As stands Kamer responsibilities for gambling policy are maintained by Arco Rutte, who was as State Secretary for Legal Protection. However changes are due as a new governing coalition has yet to be formed. Negotiations are currently underway as Rob Jetten, leader of the social-liberal Democrats 66 (D66) bargains with four parties to establish a centrist government.

Despite the political uncertainty, a broad consensus has emerged within the Kamer that the overhaul of KOA should prioritise harm reduction, with specific protections for young consumers under the age of 24.

Lawmakers have also confirmed that the reform process will not include a review of gambling taxation, with the planned increase in online gambling taxes to 38% of gross gaming revenue (GGR) by 2027 remaining in place.

KSA Chairman Michel Groothuizen has acknowledged the scale of the regulatory challenge, stating that future gambling policy must explicitly account for the most severe gambling-related risks, including suicide and minimising financial harms.

KOA licenses have broadly supported the inbound legislative reforms, however the forthcoming government has been urgently warned to fix regulatory discrepancies and product restrictions that have severely weakened channelisation. Latest audits saw channelisation rates fall below 50% of gambling revenues, as the Netherlands had become an active market for black market encroachment since its regulation in 2020.

The government of Georgia has finalised a comprehensive sweep of individuals excluded from participating in gambling activities.

In 2025, Georgia enacted new executive orders amending the Georgian Law on the “Organisation of Lotteries, Gambling and Games of Chance”, as demanded by former Prime Minister Irakli Garibashvili.

The changes saw Georgia’s Revenue Service tasked with the “surveillance of gambling licences”, including responsibility for managing the ‘exclusion registry‘ of Georgian citizens.

In 2024, enforcement measures authorised by PM Garibashvili ordered the government to raise Georgia’s legal gambling age to 25 — the highest threshold in Eastern Europe.

Furthermore, the Revenue Service was instructed by the DREAMS government to register all public-sector employees and citizens with criminal records under the national exclusion register.

Garibashvili was replaced in office in 2025 by PM Irakli Kobakhidze, though regulatory continuity has been maintained under the ruling DREAM government, particularly in relation to tightening controls on gambling and limiting its engagement with citizens.

Following a full sweep completed in 2025, the Revenue Service announced that it had registered 1,577,247 individuals in the exclusion registry as of December 2025.

As reported by SBC Eurasia, this figure includes approximately 36,000 citizens who have voluntarily self-excluded after identifying themselves as vulnerable to gambling-related harms.

The Revenue Service also noted that 62 individuals were added to the registry under direct court orders, while the majority of exclusions were processed via the Revenue Service’s website or its online registration platform, Videocall.rs.ge.

The total number of excluded citizens means the Revenue Service has met the target set by former PM Garibashvili of excluding around 1.5 million citizens from gambling — amounting to a prohibition affecting more than 50% of Georgia’s population.

Further enforcement measures introduced in 2025 require Georgian gambling venues to implement biometric user identification and conduct centralised age verification using government databases.

In addition, Georgia introduced a new tax regime in 2025 under which gambling licences are subject to a 15% levy on GGR, while withdrawals by Georgian citizens are taxed at 5% personal income tax for foreign players’ charges are exempt.

Under the mandate of the ruling DREAM government, gambling continues to be positioned as a legitimate component of Georgia’s economy, primarily oriented toward tourists and foreign visitors rather than domestic participation.

The DREAM government has made clear that gambling must not encroach upon Georgian society or citizens lives, welfare, or financial security at risk. The principle is upheld by PM Irakli Kobakhidze, who continues to underpin Georgia’s increasingly restrictive approach to gambling regulation, enforcement, and citizen protection.