Norway Gambling — Payments and banking: Can we move player money?

The Gaming Act and the Gaming Regulation, combined with other regulations, in particular related to anti-money laundering, put forth extensive requirements regarding the processing of payments of licensed operators in Norway which is primarily relevant for the exclusive rights operators. The Gaming Act Section 4 prohibits offering gambling in Norway without a license, and Section 5 separately prohibits intermediating payments for such unlicensed gambling. That Payment Blocking Measure is implemented through Chapter 17 of the Gaming Regulation. Under section 96 of the Regulation, undertakings providing payment services in Norway must stop any payment transaction they know to constitute a deposit into, or a payout from, gambling that is not licensed in Norway, whether the transaction runs to the gambling company itself or to another undertaking intermediating payments on its behalf. Section 97 allows the NGA to issue an individual decision ordering a payment provider to reject transactions identified by a specific account number or by the name of the unlicensed operator or its payment intermediary. Section 98 requires payment providers to investigate transactions connected to operators the NGA has flagged, and to disclose account numbers, merchant category codes and transaction volumes on request, though not personal data about individual transactions. The NGA may also impose an administrative fine on a non-compliant payment provider of up to ten percent of its Norwegian turnover, or up to one "G" for a private individual. Taken together, these provisions place payment-service providers under a standing obligation to block the financial channel to unlicensed gambling, give the NGA targeted enforcement tools to close gaps in that self-policing, and backstop the whole system with a turnover-based fine for providers that fail to comply.