MRS MENDA STOYANOVA
CHAIRMAN OF
THE COMMISSION ON
BUDGET AND FINANCE
TO THE NATIONAL ASSEMBLY
ABOUT: ZID of the Law on Gambling, No. 854-01-40, submitted by n.p. Christian Mitev and
group of people's representatives on 11.05.2018
DEAR MRS STOYANOVA,
In addition to the publicly expressed position of the Confederation of Employers and Industrialists in Bulgaria regarding the contributions on 11.05.2018. bill to amend and supplement the Law on Gambling by MP Hristiyan Mitev and a group of MPs, please consider our following opinion:
- The bill introduces prohibitions and restrictions that represent an extremely inappropriate and harmful intervention of the state in the market economy. The proposed prohibitions and regulations violate the provisions established in Art. 19, paragraphs 1 and 2 of the Constitution, the principle of free economic initiative. The changes increase the administrative burden on entrepreneurs and limit competition.
- The draft law creates prerequisites for unnecessary limitation of the administrative burden, as well as for taking on new costs by the entrepreneurs (for licensing of objects) and the state (for servicing the licensing process).
- The draft law, which aims to limit gambling, will have the effect of a significant reduction of revenues in the state budget from direct taxes and fees under Art. 30, para. 3 of the 2017X (which for 138 are BGN 315), and from VAT on the cost of advertising and from corporate tax on the profit of the enterprises that produce, publish or broadcast advertising.
- The envisaged changes in gambling advertising significantly limit the right of citizens to seek and receive information, guaranteed in Art. 41, paragraph 1 of the Constitution, as well as the freedom of speech, established in Art. 39, paragraph 1 of the Constitution.
- The draft law takes away the possibility of self-regulation, currently provided for in Article 10, paragraph 6 XNUMXX, which in itself is a violation of the principles of functioning of civil society.
The reasons for the bill contain false statements and contradictory logical conclusions:
1. The statement that the distribution of lottery tickets and the payment of winnings from games in unlicensed establishments creates a risk of fraud and parallel accounting is false. The same shows ignorance of the legislation governing gambling and the business processes involved in organizing gambling games.
The Gambling Act currently in force contains numerous obligations of the organizers of gambling games, as well as significant powers of the State Gambling Commission in relation to the control of games, and in particular the reporting of revenues from them. In addition to the Act, numerous by-laws create safeguards against the misuse of the printing and distribution of lottery tickets, slips and gambling coupons.
With the currently effective Ordinance on the conditions and procedures for printing and control over securities (Adopted by PMS No. 289 of 30.11.1994, promulgated, SG No. 101 of 9.12.1994, amended and supplemented, no. 38 of 25.04.1995/73/26.06.1998, amended, No. 26.06.1998 of 8/26.01.2001/54, in force since 13.06.2008/22/18.03.2011, No. 18.03.2011 of 60/7.08.2015/10, amended and supplemented, No. 31 from 2, No. 21 from 29, in force from 34, No. XNUMX from XNUMX) strict control of the Ministry of Finance on lottery tickets was introduced even before printing them Pursuant to Art. XNUMX of the said Ordinance, the Ministry of Finance receives comprehensive information on the total number, series and nominal value of tickets, slips, coupons and other identification signs for participation in gambling games and issues permission for their printing based on it. Also, the Ministry of Finance allows the receipt of the already printed tickets and other identification marks after carrying out a physical check on the spot (Art. XNUMX, para. XNUMX) and after paying the "Control" fee according to Art. XNUMX of the regulation. And Article XNUMX obliges the Ministry of Finance to notify in writing and electronically the competent territorial directorates of the revenue administration and the State Commission on Gambling about the tickets and other credentials received by the organizers of the games. Pursuant to Art. XNUMX, tickets, slips, vouchers and other identification signs for participation in gambling games within the meaning of the Law on Gambling shall be destroyed in the presence of the control authorities.
Ticket sellers are subject to the same strict accountability under tax and accounting laws as all other businesses. Moreover, in accordance with Art. 39a of Ordinance No. H-18 of December 13, 2006 on registration and reporting of sales in commercial establishments through fiscal devices (Official Gazette No. 106 of December 27, 2006, amended, SG No. .7 of January 23, 2007, amended SG No. 79 of October 2, 2007, amended SG No. 77 of September 29, 2009, amended SG No. 49 of June 29, 2010, amended SG No. 48 of June 24, 2011, amended SG No. 64 of August 19, 2011, amended SG No. 7 of January 24, 2012, amended and supplemented SG No. 27 of April 3, 2012 ., amended and supplemented by SG No. 54 of July 17, 2012, amended by SG No. 78 of October 12, 2012, amended and supplemented by SG No. 102 of December 21, 2012, amended and supplement SG No. 40 of April 30, 2013, amended SG No. 93 of October 25, 2013, amend and supplement SG No. 111 of December 27, 2013, supplement SG No. 14 of February 20, 2015, amended by SG No. 44 of June 16, 2015, amended and supplemented by SG No. 49 of June 30, 2015, amended by SG No. 54 of July 17, 2015, amended by SG No. 66 of August 28, 2015, amended and supplemented SG No. 83 of October 27, 2015, supplemented SG No. 84 of October 30, 2015, amended. and add. DV. No. 44 of June 2, 2017, amended and add. DV. No. 76 of September 19, 2017) persons selling tickets and other vouchers for participation in gambling games are required to keep a book (register) for daily sales. The book (register) contains the type and number of sold tickets, coupons and other identification marks, as well as the starting and ending number of the corresponding type, by denomination and total turnover for the day.
With the existing regulation and the foreseen preliminary, current and subsequent control by the Ministry of Finance and the State Gambling Commission, the argument about the risk of parallel accounting and fraud is untenable.
The proposed changes in Article 9, Paragraph 2 of the Law on Gambling are aimed at limiting the free distribution of lottery tickets and other identification signs for participation in gambling games. It is proposed that the licensing regime cover another, new, group of persons, namely the owners of commercial establishments where tickets and coupons are distributed. In this way, instead of limiting the licensing and administrative burden, and hence the intervention of the state in the economic activity, the opposite is obtained - another licensing regime is introduced, and it is for small businesses, which are predominantly involved in the activity of selling tickets and coupons .
This licensing is unnecessary. The introduction of licensing of commercial establishments selling tickets and other authentication signs for participation in gambling games implies the activity of collecting and providing documents, including from other administrations, their submission to the DKH, time for processing and ruling on the request by a state body. In other words, a new, time-consuming administrative procedure is created, affecting many commercial establishments and affecting small businesses. Serving so many persons and objects requires a new, additional administrative resource - human, informational and material, which will be a new, considerable expense for the state budget, and the subject of new public procurement procedures.
The proposal to change Article 9, paragraph 2 of the 5000X and its part concerning the licensing of the places for the payment of winnings from gambling games is also unfounded. Under the current rules of the Gambling Act, winnings over BGN 5000 must be paid by bank transfer. With regard to winnings below BGN 100, the organizers of lotto and lottery games have imposed the practice of winnings between BGN 5000 and 100 to be paid at the office of a licensed payment institution. It is known that payment institutions are subject to a special and strict licensing regime and state supervision. In this sense, it is unnecessary for these institutions to be licensed by the DKH for the payment of winnings from gambling games. Licensing the places for paying out profits under BGN 100 is also unnecessary - these are relatively small profits, the payment of which on the spot does not contain risks for the payer, the recipient and the tax office, nor for the public interest. Regarding the profits below BGN XNUMX - they are paid out in objects managed by small businesses, which in turn, in most cases, have limited material and human resources. Licensing the activity of these sites for payment of profits will lead to the performance of unreasonable activities and costs for collecting documents, paying fees, and fulfilling administrative procedures, requirements, which will slow down their owners and in no way ensure in a more to a large extent the public interest and fiscal.
The introduction of a licensing regime for all establishments that sell tickets, vouchers, receipts and other identification signs for participation in gambling places in a more favorable position the establishments that are already licensed as points of collection of bets, gaming halls and casinos . Only those already-licensed sites will, over a period of time, be legally compliant to distribute the tickets and other signs, which will put them in a near dominant or monopoly position in the market. Licensing sites will be forced to fight for market share again, which will be preceded by incurring administrative costs. It is socially unjustified to draw an equal sign between sites offering high-stakes gambling (such as casino games, slot machines) and with a higher probability of addiction and losses, and those where the bets made there are limited to a few BGN . All this is unfair and damages competition, which is protected by the Constitution and the law.
The comparative legal analysis of the regulation of gambling activity in Europe requires the finding that the Member States have not introduced restrictions on the places where lottery tickets can be sold, as well as slips and coupons from other gambling games. European legislation also does not contain norms with restrictions in this direction. In this sense, the proposed bill is contrary to good European practices and the principles of European law.
Limiting the sale of tickets to certain points where gambling is organized also carries its own risks. The free distribution of lottery tickets in numerous points of sale does not focus the attention of consumers on gambling games - they are one of the many goods and services offered in the relevant commercial outlet. Thus, gambling is not limited to people who habitually participate in it or are addicted to it. While the identification of certain places for the sale of lottery tickets and lottopoints will focus attention on them and the persons who visit them will not have a choice of other goods and services than gambling. Such special places will become a regular place to visit for those who have a tendency to participate in gambling games and will help them spend more money on bets at that place once they enter it.
2. The petitioners' reasons for restricting the advertising of gambling games are unsustainable and legally untenable. Essentially, the proposed changes introduce a complete ban on gambling advertising.
First of all, the argument that the gambling advertising regime should be aligned with the advertising of alcoholic beverages, tobacco products and narcotic substances is untenable. Equating gambling with substances harmful to the human body is groundless - there are no scientifically proven and indisputable facts that gambling damages human health in the same or similar way as alcohol, cigarettes and drugs.
Next, it is illogical to ban the advertising of a permitted, regulated, and also performed by the state (in the form of the BST) activity such as gambling. Provided that the state has an interest in increasing the income from gambling activity with a view to financing sports and culture, and this is established in the currently active Gambling Act, the desire of the importers in the opposite direction is puzzling. The ban on gambling, and hence the targeted drop in the state's income from gambling, does not resolve the question of how sports and culture will be financed.
The current regulation of gambling advertising is quite restrictive. Direct advertising is prohibited. Point 23 of §1 of the DR of the XNUMXX quite widely and multi-layeredly limits the forms and content of gambling advertising. It should be noted that gambling advertising is subject to both the restrictions of the Gambling Act and the provisions of the Competition Protection Act, the Consumer Protection Act and the Radio and Television Act, as well as the Ethical Rules for Advertising and commercial communication adopted by the National Self-Regulatory Council. Does advertising need to be further restricted and what benefits will this bring to society and the state? The draft law and the reasons for it do not provide a convincing answer.
The current legal restrictions in ХХ regarding the advertising of gambling are in sync with the regulation of this activity in the other member countries of the European Union. When comparing the legislation treating gambling advertising in the individual member countries, it is established that the same is allowed (with the exception of Latvia), both in countries with a larger population than Bulgaria and with a higher standard of living (France, Great Britain, Spain, Italy) and in smaller countries that are close in area and population with ours (Hungary, Austria, Belgium, Netherlands, Denmark).
The proposed legal changes are internally contradictory. The definition and prohibition of so-called "indirect advertising" aims to prohibit gambling advertising altogether. With the revision of Art. 10, para. 1 of the 23X prohibiting direct and indirect advertising, a rule is introduced, which in its legal essence is a ban on advertising gambling games in general. With the adoption of new item 1a of §10, what is indirect advertising is defined, with the definition de facto covering almost all hypotheses of publication, announcement and broadcasting of informational, advertising and commercial messages existing in practice. At the same time, with the revision of Article 2, paragraph 10, it is possible to announce circumstances and data about the games. It can be seen that with the norm of Art. 2, para. 10 an attempt is made to introduce an exception to the prohibition. By its essence and practical applicability, however, the norm of Art. 2, Para. 10 constitutes a permit for indirect advertising. There is a lack of clear criteria, disputing the announcement of information under Article 2, paragraph 23 and indirect advertising under Item 1a of §10. Even the importers themselves equate the announcement of the information under Article 2, Paragraph XNUMX to advertising - it is clear from the reasons that they use the expression "in order not to reach a complete ban on permissible advertising". The relationship between the rule and the exceptions to it is unclear and creates an unconditional need for interpretation. Such vague and confusing norms are a prerequisite for wrong and selective administrative practice, and hence for nurturing a double standard, administrative pressure, and corruption. Why is it necessary to introduce norms with unclear normative content, for which analysis and interpretation will be required, and which create prerequisites for incorrect and duplicate law enforcement? This is in violation of the requirements of the Law on normative acts.
The proposed restrictions on advertising and vague exceptions to the rule, in themselves, constitute state censorship of free speech. The State Commission on Gambling will be transformed into a special body which, through its sanctioning activity, within the framework of subsequent control, will set the criteria for what and how it should be advertised in gambling. In this way, a state body will be given the unwritten right to supplement the law through administrative practice. This is unacceptable in the rule of law.
The motives of the petitioners are internally contradictory. On the one hand, with the changes they want to minimize the risks of fraud in gambling and increase publicity and transparency. On the other hand, they want to remove the legal mechanisms that ensure publicity of games and winnings. With the proposal to cancel item 3 of paragraph 2 of article 10 of the XNUMXX, the petitioners insist that the results of the games and the winnings won't be announced. At the same time, they do not propose other adequate measures, ensuring the publicity and transparency they seek.
Given that gambling is an activity permitted in the country, the desire of the importers to cancel the provision of Article 2, Paragraph 5, Item 5 of the Tax Act is puzzling. In this way, the state will semi-legally limit the possibility of organizing gambling games permitted by it.
Worrying for the development of civil society is the idea of importers to drop the self-regulation rules established in the current law. With the repeal of paragraph 6 of Article 10, the state-sanctioned Ethical rules for advertising and commercial communication of gambling games, adopted by the National Council for Self-Regulation, will not have a mandatory nature. This is deeply wrong and shows ignorance of the matter. With these ethical rules, business representatives have independently formulated and enforced regulations to deter them from unethical or dishonest advertising and communication. It is undisputed that these rules are significantly restrictive as far as gambling advertising is concerned, and they themselves introduce numerous prohibitions and restrictions. In this regard, it is surprising that the importers want this to be changed.
3. The preliminary assessment of the draft law's impact on the interested parties, public and state interest, administrative and financial relations presented by the petitioners is absolutely formal and superficial.
Above are arguments regarding the emergence of a new, additional licensing regime, new regulation of economic activity, licensing costs, putting small businesses at a disadvantage, increasing the administrative burden, the risks of enforcing unclear and imprecise legal norms, and others shortcomings of the proposed bill.
The bill will introduce a licensing regime affecting over 15 points of sale operating freely at the moment.
The proposed changes will affect not only gambling organizers and media service providers, but also other businesses that provide goods and services to gambling operators in connection with the organization of games, their advertising, the payment of monetary winnings and the provision of such .
The bill aims to limit the revenue of gambling promoters. However, this will have a negative impact not only on the revenues in the state budget from the taxation of gambling, but also on the revenues of the enterprises that deal with the sale of tickets, slips and coupons for gambling games, manufacturers of advertising materials, advertising agencies, production companies, printers , distribution companies, courier services, travel agencies, and car importers.
The listed economic entities are mainly representatives of small and medium-sized businesses. Reflecting on their income, the draft law will indirectly affect the taxes that these entities contribute to the budget as a result of their gambling service activity. Gambling operators do not make taxable supplies, so they are not entitled to a tax credit for the supplies they receive. Accordingly, their small and medium business suppliers charge and pay VAT to the budget as a result of taxing all supplies to gambling organizers. Therefore, the organizers are the final payer of VAT for the supplies received by them and do not benefit from the right to deduct VAT.
The changes in the law on small and medium-sized businesses will cause revenue losses of BGN 100.
The negative direct effect on the state budget as a result of the new restrictions will be expressed in a decrease in revenues from fees under Article 30, Paragraphs 3 and 4 of the Tax Code, namely by BGN 60 less, and from VAT by BGN 000 000 20 BGN less. Apart from that, the fall in revenue from taxing the activities of the gambling operators' suppliers should also be taken into account.
4. In conclusion, we believe that the bill will have a completely negative effect on public relations and is unable to protect the public interest.
The current regulation of gambling advertising protects the public interest. The state has placed significant restrictions on advertising, prohibiting direct advertising that directly solicits participation in gambling, creates the impression that through gambling participants will solve personal or financial problems, or that they will achieve financial well-being, or promises huge profits . In this way, the public is protected from unscrupulous messages linking participation in gambling games to get-rich-quick or aimed at children, as well as from addictive participation. Along with this, the state has granted a public organization in the person of the National Self-Regulation Council to define additional rules for advertising and commercial communication of gambling and has obliged the organizers of the games to comply with them. The same public organization has the right to ascertain and announce violations of the ethical rules established by it. Serious administrative and criminal liability is foreseen in case of violation of the established rules for advertising.
It is life- and legally illogical to prohibit or strictly limit the indirect advertising of an activity that is permitted and legally regulated by the state, and is carried out by it through the Bulgarian sports totalizer. Even more so when gambling brings serious revenues to the state, which are proportional to the revenues of the organizers of the games, and provided that the public interest is secured by legal norms and ethical rules sanctioned by law.
A comparison of the norms governing the advertising of gambling games in the member states of the European Union shows that the regulation of gambling advertising in Bulgaria is one of the most restrictive.
Nowhere in the Member States is there a limit on the places where lottery tickets can be sold. This is also the case in the large European countries - Great Britain, France, Spain, Italy, and also in the countries of the former Eastern bloc.
The bill introduces prohibitions and restrictions that represent an extremely inappropriate and harmful intervention of the state in the market economy.
A new licensing regime and administrative burden is created.
The income of small and medium-sized businesses that supply goods and services to gambling organizers will be drastically reduced.
The bill will lead to a decrease in revenues in the state budget.
The Confederation of Employers and Industrialists in Bulgaria is attached to present to your attention a draft of the ZID of the Gambling Act, which reflects our views on changes in the law.
Please take into account the considerations presented by us on the submitted draft law, as well as familiarize yourself with the proposed draft of the ZIDZHH with reasons. We hope they will be recognized by you.
ATTACHMENT:
PROJECT
of the Law on Amendments and Supplements to the Law on Gambling
In the Law on Gambling (Off., SG No. 26 of 30.03.2012, in force from 1.07.2012, supplement, No. 54 of 17.07.2012, in force from 1.07.2012 , No. 82 of 26.10.2012, No. 94 of 30.11.2012, in force from 30.11.2012, amended, No. 68 of 2.08.2013, in force from 2.08.2013 ., amended and supplemented, No. 1 dated 3.01.2014, effective from 1.01.2014, No. 105 from 19.12.2014, effective from 1.01.2015, add., no. 61 dated 11.08.2015, in force from 1.11.2015, amended, No. 79 from 13.10.2015, in force from 1.08.2016, No. 74 from 20.09.2016, in force from 1.01.2018, amended and supplemented, No. 98 from 9.12.2016, in force from 1.01.2017, supplemented, No. 103 from 28.12.2017, in force from 1.01.2018) the following amendments and additions are made:
§1. In Article 10, new paragraphs 7, 8 and 9 are created with the following content:
"(7) Advertising messages relating to gambling must contain a warning about the risk of gambling addiction and losses. This does not apply in cases where only the name of the games, the organizer or its trademarks is displayed or published.'
"(8) Advertising messages relating to gambling games must contain information that only able-bodied adults can participate in gambling games and that incapacitated persons can receive tickets or vouchers for participation in lotteries, lotto and lotto games, and raffles only by donation. The information can also be by displaying an "18+" symbol or another appropriate way according to the circumstances. These rules do not apply in cases where only the name of the games, the organizer or its trademarks are displayed or published.'
"(9) Advertising messages relating to gambling shall not contain messages that encourage minors to participate in gambling or show minors participating in gambling."
§2. In Article 13, a new paragraph 4 is created with the following content:
"(4) The organizers of gambling games in a gaming casino, of games with gaming machines, and of gambling games online must not allow persons who are entered in the National Register of Gambling Addicts, maintained by the Commission, to participate in the games. These organizers are obliged to check the presence of the relevant person in the register before allowing him to participate in the games in a gaming casino, respectively with gaming machines, respectively before his registration for online games. The organizers of other types of gambling games, who receive proper information about the inclusion of a person in the register, are obliged to deny him participation in them after making a check in the register about this circumstance."
§3. In para. 1 of Article 22, the following changes are made:
- Point 15 is amended and acquires the following content: "15. Creates and maintains a National Register for gambling addicts. The Commission, after consultation with the Ministry of Health, the Ministry of Labor and Social Policy and the Commission for the Protection of Personal Data, adopts Rules for keeping, storing and accessing the National Register for gambling addicts."
- Creates a new point 16 with the following content: “16. It organizes and maintains a XNUMX-hour telephone line for help against falling into gambling addiction, referred to in law as the "hotline". The commission, after prior agreement with the Ministry of Health, the Ministry of Labor and Social Policy, adopts Rules for providing assistance to persons who have sought help through the hotline. The commission notifies the organizers of gambling games of discoveries and supported by a hotline number.
- Creates a new point 17 with the following content: "17. exercise other powers expressly provided by law."
§4. The following changes are made in Article 43:
- Paragraph 1 is created with the content of the previous text of Article 43.
- A new paragraph 2 is created with the following content: "(2) In the places where gambling games are held and in the establishments where tickets, receipts, vouchers and other authentication signs for participation in gambling games are sold, a conspicuous place is placed and a sign appropriate to the circumstances, written legibly, conspicuously and clearly, containing an indication that games of chance are conducted on the premises, that the same are prohibited to minors, that incapacitated persons may receive tickets or vouchers for participation in lotteries, lotto and lotto games, and donation-only raffles, as well as a gambling addiction hotline number and warning.'
- A new subsection 2 is created with the following content: "(2) The representatives of the organizers in the places where gambling games are held and in the establishments where tickets, receipts, vouchers and other authentication signs for participation in gambling games are sold, before admission of a person to participate in the games, respectively before the sale of the tokens, may ask him to verify his age by presenting an identity document. Identification badges are not sold to persons who do not prove they are of legal age, and are therefore not allowed to participate in the games.
MOTIVES
to a project of
Gambling Law Amendment Act
- Grounds for the proposal for a legislative initiative
In recent months, the question of the impact of gambling advertising on citizens has been raised in the public domain, with particular emphasis on its impact on children and adolescents. Along with this, the issue of easy accessibility of lottery tickets and other lotto and toto games by consumers is also touched upon. An extreme restriction of gambling advertising, which goes as far as an absolute ban, is proposed by political entities. It also calls for the introduction of licensing of places where tickets, vouchers, slips and other credentials for participation in gambling can be sold. It seeks to unify the regime of so-called light gambling (lotteries, lotto and lotto games) with that of gambling games, which are initially subject to heavy regulation, such as games in gaming casinos and games with slot machines in gaming halls. The aim is to present gambling as a business that robs society. However, most proposals for changes in the regulation show ignorance of the current legislation in the field of gambling, as well as of the business processes in this field and the participants in them.
The proposed draft Law on Amendments and Supplements to the Law on Gambling aims to establish new rules that further develop the current regulation and create even stronger guarantees against unfair advertising and commercial communication of gambling games. The project contains norms aimed at protecting the interests of children and preventing the impact of gambling advertising on them and their development. The project complements and expands the regulation of gambling advertising by introducing requirements for each advertisement:
- contain a warning about the risk of gambling addiction and losses;
- to contain information that only able-bodied persons of legal age can participate in the gambling games;
- not contain messages that encourage minors to participate in gambling.
The project takes into account the concerns of certain members of society in relation to the dangers of gambling addiction by persons in a particular personal or financial situation. In this sense, the project proposes to create and maintain a National Register for gambling addicts. An obligation is created for the organizers of gambling games not to allow persons who are entered in this register as addicts to participate in the games.
The project also introduces a hotline for help against falling into gambling addiction. In this way, measures are created for the state to assist persons who are addicted to gambling to overcome this addiction.
The project takes into account the concerns expressed by the mass distribution of lottery tickets and other gambling games from the category of so-called soft gambling. Measures have been proposed to inform consumers that gambling is taking place in the commercial establishment, and accordingly about the dangers of addiction. An obligation has been introduced in a visible place in the facilities to place an appropriate inscription, written legibly, visibly and clearly, containing an indication that gambling games are held in the facility, that the same are prohibited for minors, as well as the hotline number and an addiction warning to gambling.
In relation to concerns about the distribution of tickets among children and adolescents, an obligation has been introduced to establish the user's age before selling a ticket or coupon, or before allowing him to participate in the games.
The proposed measures are complex and interrelated.
- Preliminary impact assessment
The project introduces obligations for the State Commission on Gambling, for the organizers of gambling games, as well as for the persons owning establishments where tickets, coupons and receipts are distributed.
The project does not impose licensing regimes and new administrative procedures. The DKH should develop and adopt rules in connection with the National Register for Gambling Addictions, as well as rules for the operation of the "hot" telephone line.
The acceptance of the proposals under §4 of the project will have the effect of incurring costs by the organizers of gambling games, as well as by the persons owning objects in which tickets, coupons and receipts are distributed, for the production and placement of the inscriptions warning of the implementation of gambling in commercial establishments.
On the expenditure part of the state budget, costs will be imposed for keeping and maintaining the National Registry for gambling addicts, as well as a hotline for help against falling into gambling addiction. These costs are clearly not large, they are necessary in the public interest, and their benefits greatly exceed their amount.
Amendments to other legal acts are not required.
With respect,
Eugene Ivanov
Ex. Director and member of the Management Board
http://www.turbulence.tech