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Interview with Cosmina Simion NNDKP (EEGReport Magazine – Issue 1 – October 2015 – January 2016)



EEGReport Magazine: Since you are one of the many lawyers that was involved in the creation of the current online gambling framework in Romania, we would like to get as opinions as possible to get a glimpse into where this law will go and what it’s purpose is to the Romanian market.

Firstly we would like to get you opinion about why there is such small number of licenses that have been issued during this summer after the licenses were made available for the temporary period. Are operators waiting to see what happens at the next review of the framework?

Cosmina Simion - NNDKP

Cosmina Simion(NNDKP): The Romanian gambling legislation, as last amended by Law 124/2015 which entered into force on 12 June 2015 provides for the possibility to apply for both a full gambling license as well as an interim right to operate gambling activities in Romania. While the full license is granted for a 10 years period, the conditions that need to be met are substantial in nature especially in terms of the technical requirements which are also yet to be set under the secondary legislation expected to be enacted any day now, but also by the technical order to be issued under a decision of the President of the National Office for Gambling (“NOG”). Throughout the summer the NOG has carried consultative discussions with industry representatives related to these  technical requirements, which ultimately resulted in a draft technical order that was notified to the European Commission and is now subject to a stand-still period to expire on 26 November 2015.

It follows that the process for applying for full licenses is yet to be opened.

On the other hand, applications for the interim right to operate online gambling activities in Romania can be submitted until 31 December 2015.  Hence operators are still in time to apply for this interim right.

However, the online gambling operators who performed gambling activities in Romania prior to the entering into force of Law 124/2015 had a 90 days period calculated from the moment the law entered into force (i.e. expired on 10th of September) to benefit from a fiscal and criminal amnesty upon presenting a financial audit (showing both stakes, winnings and operator’s GGR)covering past performance starting with 24 December 2010, followed by the payment of a 20% authorisation tax on GGR, as well asthe fixed license fees for past performance.  As such, the operators who have not cleared their past in the indicated timeframe have or will be blacklisted.  The conditions for being removed from the black list are yet to be decided upon by the Supervisory Committee of the NOG and by the Order of the President of the NOG.

The list of operators who have already been granted with the interim right to operate, as well as the list of operators who have already been black-listed, can be found on NOG’s website, but note should be taken that neither of them is up to date currently.

EEGReport Magazine: What can be the cause that will determine the NOG(ONJN) not issue a a full license for certain operators?

Cosmina Simion(NNDKP): As long as the conditions laid down by the gambling legislation are complied with, the NOG will have no reasons not to issue a full license to the applicants.

EEGReport Magazine: Back-tax, back-tax, back-tax…..In your point of view and we ask your expert opinion, is this a good way to attract operators? We all know that many large operators who were really popular among the Romanian betting crowd are awaiting their trusted brands to get licensed, but they will have to wait, since there is this back-tax that nobody want to pay.

Cosmina Simion(NNDKP): The NOG made significant efforts to deliver a new and modern legislation, where the significant changes targeted the introduction of a possibility to clear the past by way of paying tax for past performance at a level that the Romanian state authorities considered to be both fair and commercially viable for the operators.  By reviewing the list of operators who were already granted the interim right to operate, one can find big names of global operators, as well as names of operators of a smaller scale.  Also, a few selected others that have been present on the Romanian market at different times in the past, but who do not intend to continue their operations here in the (near) future will have submitted the documents and paid the fees in order to clear the past and benefit from the amnesty provisions.

EEGReport Magazine: How about the affiliate side, the current legislation doesn’t allow the advertising of licensed casino, sportsbetting operators and their bonuses by affiliates who could just simply join an affiliate program and start advertising their favourite brand who maybe just entered the market. We know that this current framework is just temporary, but are there any chances that the € 6,000 license fee to be abrogated and maybe replaced by an income tax? It’s kind of funny to pay that huge license fee and maybe earn less than that in a year from revenues generated by referring players.

Cosmina Simion(NNDKP): The current legislation provides that all suppliers to the gambling market (i.e. providing management and hosting facilities, payment processors, manufacturers and distributors of software, affiliates, certifiers and auditors) need to obtain a second class license and pay an annual fee of € 6000.  While we do not believe this to change in the near future, we understand that NOG will license commercial agreements under which several suppliers function under the same umbrella where one assumes the liability.  We may have more clarity over this issue once the secondary legislation is enacted.

EEGReport Magazine: How do you see the Romanian online gambling market in the next 5 years? Will there be a significant growth in the Economy and will there be more jobs created?

Cosmina Simion(NNDKP): The state budget has probably become richer already by several tens of millions Euros. And the authorities are finally having (or at least should have) the satisfaction of reaching the goals that have been pursued by all Governments in the past 7 years- they have obtained money from online gambling while also turning a black market into a white one.

Going further, once the premises have been laid down for this stream of revenues, the Romanian Government will continue to raise taxes while it is certain that this business will generate more work on the market to a certain extent, especially on the supply side.

EEGReport Magazine: Why do you think operators, software developers and payment processors should come and open new business in Romania?

Cosmina Simion(NNDKP): The new and modern legislation has definitely put Romania on the map, a country with appetite for gambling and a population of 18 million inhabitans.   As lawyers, we cannot proclaim to have visibility on the commercial process that leads to the decision to enter or exit a market, but fFrom where we standremarkable progress has been made and Romania can definitely cannot be ignored when you are a remote gambling operator.


Cosmina Simion(NNDKP) – Bio:

Partner Cosmina Simion has over 16 years of experience as a Romanian law qualified lawyer, with previous coordination roles in global law firms, combining this expertise with a specific approach built during her in-house role at a US group, leader in the regional media sector.  She is well-versed in dealing with all matters pertaining to the organisation and operation of gambling activities, being involved in the review of the gaming legal framework, including representing clients during negotiations with the Romanian National Gambling Office. \

A member of the Bucharest Bar, Cosmina regularly authors articles in the field and contributes in domestic working groups seeking to improve the business and regulatory approaches in the gaming sector.



Vahe Baloulian Interview – (EEGReport Magazine – Issue 1 – October 2015 – January 2016)



EEGReport Magazine: Since Armenia, a Transcaucasian state is included in definitions of Eastern Europe or histories of Eastern Europe, we would like to know more about the developments of the online gambling in the country and neighbouring countries. What is in your opinion the way these countries need to consider issuing online gambling licenses for foreign operators?(if you could answer per country it would be great).

Vahe Baloulian:Although our largest development and service center is located in Yerevan, the capital of Armenia, BetConstruct is not involved in a licensable activities in Armenia or neighboring countries. However, we do have partners who operate in Armenia. As an operator in Armenia, you have to register a local company and get licensed by the government. It is quite an expensive exercise. Casino and poker license is different from the betting license. Armenia is one of the so-called grey markets where some foreign companies, even publicly traded ones, illegally operate without obtaining a license. Online gaming is quite popular with sports betting prevalence as it is legal to operate betting shops in the capital, while land-based casinos, with one exception, are relegated to four resort areas.

EEGReport Magazine: As we know, you are from the USA and your first contact with the igaming world happened back in 1999. How much has the igaming industry evolved in the recent 15 years around the world, but especially have you seen significant growth in Eastern and Central Europe recently?

Vahe Baloulian:– The iGaming industry during the last 15-20 years has changed dramatically in positive and negative sense. It is more regulated, which is beneficial if regulation is focused on guaranteeing safe and fair environment for the players. If regulation is simply about creating a new revenue source for the governments, the players are rarely protected.
The entrepreneurial spirit of the early years, the can-do attitude of the pioneers is replaced with corporate politics of public companies.
As to Eastern and Central Europe, it is now experiencing the growth with the benefit of knowing what has been done right and wrong by those who lead the way. Those who are capable of learning from the mistakes and achievements of others will be a lot more successful than those who think they know everything and don’t need the lessons of the past.

EEGReport Magazine: How big is the impact of having gaming software providers being present in Eastern Europe? Do operators feel “at home” by knowing they are entering markets where certain igaming software providers have offices?

Vahe Baloulian:– Suppliers should be responsive and reachable regardless of them having an office in the operator’s market. Of course, having your supplier nearby gives you comfort but it is not a recipe for success. When picking suppliers, aside from the quality of their technology and services, it would be very important for me to know if they, regardless of the physical presence in the area, are willing to understand my market, speak my language, know what my customers want, visit me to learn how they can help me reach and go beyond my goals and invite me to their offices to meet their people and see how they operate. If I was an operator, this is how I would want a supplier to make me feel at home.

EEGReport Magazine: Do you see an opportunity for young software developers, which are at a rather high number in Eastern Europe, to start new companies and maybe innovate the already known platforms?

Vahe Baloulian:– BetConstruct has two development centers in Eastern Europe – in Armenia and Ukraine, where we work with many young developers. Also, our Game Store gives young independent developers an opportunity to see their games in action, distributed through our platform.  Young software developers, especially from the up and coming regions such Eastern Europe, have an enormous role to play in the development of iGaming. They will succeed and drive us all forward as long as they figure out how to learn, without blindly following, from those who came before them and how to believe in their own ability to create better things while avoiding the trap of arrogance.

EEGReport Magazine: In your opinion, which are the most popular ways of online gambling in the Eastern and Central European region? Casino, sportbetting, online poker or maybe bingo?

Vahe Baloulian:– While Eastern and Central Europe is not a monotonous region where players have the same interests, sportsbetting and casino remain the most popular. However, the online sector is much smaller than the land-based one and represents a huge opportunity in every vertical.

EEGReport Magazine: We have seen an increased activity in the Russian region that may indicate moving towards a regulated market. Do you think that this is something to likely happen in the next 2 years?

Vahe Baloulian:– Russia is struggling and the government is looking for new revenue sources, however insignificant. As recent media reports suggest, the return of legislated online poker in Russia could be eminent. The proceeds will be used to fund the Russian National Chess team and other sports. At one point poker was considered a sport in Russia, so if this u-turn is successful, I hope and expect the other forms of online gaming to get Mr.Putin’s nod as well.

EEGReport Magazine: Which are the countries operators should look forward to welcome foreign companies to get licensed in online gambling?

Vahe Baloulian:– The prediction game is never been one of my favorites, especially when it comes to such unpredictable and illogical entities as governments are. For example, it never made sense to me that the Eastern European countries, which are so well positioned geographically and politically, didn’t go the route of Malta, when it came to online gaming. They missed such a great opportunity to create jobs and become a hub of new technologies.



Vahe Baloulian is an award-winning industry veteran with over 16 years of experience in the online gaming sphere.
Prior to joining BetConstruct as its Chief Executive Officer, Vahe has worked as a Director of Gaming and Industry Relations for 888, COO of LVFH, Managing Partner of eEgaming Partners and executive consultant to BetConstruct.

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Tim Heath – INTERVIEW about BitCoin – (EEGReport Magazine – Issue 1 – October 2015 – January 2016)



EEGReport Magazine: Experts believe that in the coming years Bitcoin will develop at about the same speed as not so long ago Internet did. Do you also adhere to this theory?

Tim Heath: If we look at the speed of disruptive technologies, such as the Internet (http protocol) and Email (smtp), it takes time for such advances to propagate throughout society, specifically the time between the early adopter group and the masses.  However the movement from early adopter to regular user is most certainly more rapid than other such innovate / disruptive technologies we have seen in the past.


At the moment, Bitcoin is simply to complicated for the average user, but conceptually it’s an easy concept to understand (once explained). I think this is because users know how to use  bittorrent, or how skype works from their everyday use cases, but most often don’t understand (nor want to) the underlying technology. Skype (and VOIP) is an amazing technology, but I really do wonder how many average consumers understand the technology and the rails & protocols it runs on.  Skype have made a very simple user interface to point and click, to call or video to someone on the other side of the world, for free.  Therefore, perhaps we should not view Bitcoin technology as the “ultimate” goal for adoption, but rather simply the “rails” on which a trusted transaction is made and the end user simply uses a nice user interface to click “send money to a friend from my contact list”.

Perhaps to this end, the end goal (or killer Bitcoin app), is that someone can buy $20 of Bitcoins from a friend and in the background, that amount is hedged immediately, to ensure there is no volatility in the Bitcoin price which may effect their whole experience. This money could then be sent to a merchant, gaming site or used as remittance to another country. The transaction would still take place over the blockchain, but in the end user’s eyes, they see the non-technical transaction (which one would say looks and feels like any paypal transaction), just that it happens over a decentralized network with no fees to “send the money” safely and securely.

EEGReport Magazine: Full anonymity of Bitcoin transactions – is it advantage of disadvantage?

Tim Heath: Bitcoin is Pseudonymous not anonymous.

Our primary KYC resolves around a player’s digital footprint, rather than traditional (and as some would agree, forgeable) utility bills. That said, players are happy to be KYCed in traditional ways due to o gaming license requirements.  This is because we have found that player’s prefer that their Bitcoin gambling transactions are “not obvious” to family / friends.  Therefore when depositing to a Bitcoin casino, there are no deposits from a joint bank accounts or credit card statement.  Most importantly however, is that there is no gambling transactions on their bank statements which may harm future loan or mortgage applications (through traditional banks).

EEGReport Magazine: Absence of clear scheme for Bitcoin regulation and for its taxation disaffect – is it a key issue for investors?

Tim Heath: Regulation is needed is the onramp / offramp of fiat currency to Bitcoins and vice versa.  This is where governments should have sensible regulations in place; that Bitcoin exchanges should know their customers and understand the sources or destinations of incoming or outgoing funds.  In regard to taxation – this is a situation for the jurisdiction where the company is based, to know and pay their respective corporate taxes.  Taxation is based on the annual reports filed in the relevant jurisdictions and have nothing to do with a Bitcoin transaction.

These issues don’t seem to be slowing down Venture capital investment into Bitcoin or blockchain related companies.  In Q1 2015 there was a record breaking amount of venture capital invested in Bitcoin startups, over $229 million (a total of $676 million so far).

EEGReport Magazine: What are the benefits received by casino if shifting to Bitcoin payment system?

Tim Heath: Bitcoin is perfect money for the Internet:

  • You can send or receive $0.01 or $10 million+ instantly anywhere in the world
  • It is irreversible
  • There is no chargebacks or fraud
  • There are no payment processing costs
  • There are no 3rd parties “holding the money”
  • All transactions are peer 2 peer and auditable on the blockchain
  • Escrow services exist in the blockchain code.


Therefore when a casino utilizes Bitcoin as a payment method / gaming unit, all deposits and withdrawals are instant.  We are seeing a huge increase in localized options for conversion between fiat and Bitcoin and vice versa, which is rapidly growing Bitcoin’s accessibility.  It’s also very clear and logical, then the faster withdrawals are processed by a casino, the greater confidence a player has (in the casino) and the faster they will re-deposit.


Of course any business would love to have 0% merchant processing fees and to completely remove fraud and Chargebacks from their profit / loss statements…


Tim Heath has been involved in the gaming industry for over 12 years, working predominately in the Poker segment as a land based operator, B2B software provider and online operator.  Since 2013, his main focus has been on the Bitcoin gambling niche, with clear aim to innovate and disrupt existing norms and take casino and sportsbetting solutions to non traditional markets.

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The Rise of Daily Fantasy Sports in Europe – Can Daily Fantasy Sports Overshadow Sports Betting? – (EEGReport Magazine – Issue 1 – October 2015 – January 2016)



Daily Fantasy Sports (DFS) is a relatively new phenomenon. Sometimes labelled as ”the next big thing” after the arrival of poker 10 years ago, this trendy iGaming product is taking North America by storm and slowly knocking on Europe’s doors.


The way it works is simple: sports lovers select a team of real-world athletes like football stars Lionel Messi and Wayne Rooney, who then score fantasy points during their real football matches, according to set scoring rules. Fantasy sports games are more diversified and require a higher level of skill than the more established and wide-spread sports betting. Participants do not place a wager on the outcome of different matches or play against bookmakers. Instead, they put money on their own team and compete against other fantasy teams’ owners with the hope of winning their money (similar to the poker websites’ business model).


In countries like the USA, Canada, and, to a lesser extent, the UK, fantasy sports has been a cultural activity for decades, but has become extremely popular in the last few years with the transformation of a season-long fantasy format into a more dynamic and high-frequency daily model. We are talking about a multi-billion business here: this year alone (2015) ‒ according to the Fantasy Sports Trade Association ‒ 56.8 million people are playing fantasy sports in the USA and Canada, with each of them spending on average $465 (€413) per year. Two operators, FanDuel and DraftKings, have mastered the industry, allowing them to control the vast majority of the daily fantasy sports action. Yet, we should not forget that sports betting is illegal throughout most of the United States.


In many countries, the regulation of gaming is based on whether the predominance for the outcome of the game lies in skill or chance. Presently, in most US states, fantasy sports (including DFS) is generally considered a game of skill and therefore not legally considered as gambling (where there is an element of both luck and, obviously, chance). At a US federal level, fantasy sports is defined and exempted by the Unlawful Internet Gambling Enforcement Act of 2006 (UIGEA). The Act included an explicit provision noting that the law would not apply to fantasy sports games.


Europe is a late adopter of technological innovations, so the DFS landscape looks a bit different there. ”Talking about the legal issues of DFS in Europe is not easy,” says Valery Bollier, CEO of OulalaGames, the company that stands behind fantasy football game Oulala. ”Each country has a different vision of what iGaming/moneytainment is, as well as what a skill and luck game is. Some countries are not aware of DFS yet, and their legislator have therefore no opinion on that subject for the moment. Therefore we have to take different approaches to target different markets.”


Most countries allowing fantasy sports have already included fantasy sports in their traditional iGaming licences. The most obvious example is the UK, the leading EU market for fantasy sports, where DFS falls in the same category as sports betting and horse racing. Therefore, operators need to acquire an operating ”pool betting” licence from the Gambling Commission to target UK customers.


Legally speaking, Hungary is facing a very similar situation. ”As I understand, you have to pay a fee of €300,000 – €400,000 to obtain a gambling licence, so I believe that any DFS game would be considered as gambling because of that,” explains Tamás Varga, who has helped to create the official, season-long fantasy game of the Hungarian top-tier league Nemzeti Bajnokság.


Hungary is just one among many European countries where DFS has not really taken off, and most sports lovers are not well acquainted with the concept. ”Daily fantasy games are not in the public mind,” explains Varga.


Romania and Bulgaria represent another two emerging markets. In Romania, fantasy sports is not yet expressly regulated. ”In my view, fantasy sports are covered by the new gambling legislation,” says Cristian Tuca, a gaming law specialist. The law defines DFS as ”other gambling activities”, and if the characteristics of the game meet all the required conditions then it is to be considered a type of gambling activity (the deposit and the prize are set in real money).


Tuca, who does not know of any big gambling operator which have started offering fantasy sports in his country, points out an interesting legal fact: ”Players that are gambling on platforms of unlicensed operators (in Romania) are committing a misdemeanour and may be sanctioned with a fine of up to RON10,000 (approx. €2,300). However, this aspect should not be applicable to fantasy sports, as the law provides that the fine is applicable to those participants that play online games, while fantasy games would fall under ”other gambling activities”.


Romania’s neighbouring country, Bulgaria, has a slightly different set of rules. The Gambling Act expressly exempts from the definition of gambling ”games of sports or entertaining nature, which require the participants to manifest deftness, knowledge and skills and which are not predominately based on chance.” The main problem is that entry fees have to be entirely allocated among participants, which means that operators cannot take any commission. If they do, the game is regarded as gambling/game of luck.


In Germany, on the contrary, the law defines DFS as a game of skill. In its judgement of 16 October 2013, the Federal Administrative Court decided that a so-called Bundesliga manager game is not to be classified as a game of chance under the Inter-State Treaty on Gambling (GlüStV). This led to chances for media companies and sports associations to offer similar fantasy sports games without causing conflict with gaming law regulations. Indeed, one can find quite a few games, but the market potential is still huge. German people love sports, numbers, gaming and betting, so it is no wonder that the total betting market volume alone is held to be more than 7 billion Euros per annum.


Another potentially big market for DFS is Poland. Interestingly enough, DFS does not fall under gambling, but it is also not regulated separately. Legally speaking, it is just like any competition, such as the quiz where people receive prizes if they win. ”The companies that are offering DFS do not need to acquire any licence for it,” says betting insider Michal Kopec. According to Kopec, fantasy football competitions should be reported to the Ministry of Finance if the prize pool is more than around €500 and winners should pay 10% win tax.


It is obvious that DFS has not really picked up as yet in Europe. The main questions is: are DFS and traditional sports betting complementary products or is DFS a dangerous substitution product for sports betting? Without a doubt, DFS games provide richer (real-time second screen) experiences than what is being offered at the moment by well-established betting operators. However, a lot of effort will be required to evangelise people about this niche in the fantasy sports industry with DFS lovers putting hope in DraftKings, who – backed with millions to be spent on advertising – has been granted a licence to operate in the UK.



Jure Rejec is Content Writer for, Europe’s most advanced daily fantasy football game. Oulala offers its clients the chance to join different leagues, create and manage (in real time) their virtual teams with footballers from the top four European leagues. The leagues’ winners are awarded daily cash prizes.

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