Speakers today
Pedro López – Attorney at MartinAndino
Andrew Rosewarne – Director NMi Gaming
Willem van Oort – Gran Via Online (moderator)
Hosted by

 Gran Via Online: Business
Consultancy for the iGaming
Industry
 Founder: Willem van Oort. 14 year
Spanish Resident
 Community: 2600 members
GAMING IN SPAIN, leading industry resource and events
 Member of International Masters of
Gaming Law and
 International Association of Gaming
Advisors

1. Business Plan: Validation and adaptation to the Spanish market
2. Product: Optimize your product strategy, based on market and competitive parameters
3. Route to Market
1. How to achieve the goals from your business plans
2. Implementation, marketing and distribution strategy
3. Partnerships

• Licensing: All types of games, now also including Slots
• Ongoing Compliance: day-to-day fulfilment with the regulator DGOJ
• Introduction and institutional relationships with DGOJ
• AML Compliance: Anti money laundering procedures
• Local contracting with business partners, marketing and publicity
• General advisory: corporate, tax, e-money regulation

35 years experience in Gaming
ISO17025 accredited Testing Laboratory iGaming and Land Based capabilities
First iGaming Laboratory approved in Spain
Approved in all major iGaming jurisdictions
Full Security, Auditing and Change Management service
Laboratories in Netherlands, UK, Italy and Canada
Certification body for multiple industries

Online Market in GGR
2013 279 m€ (6.5% of total market)
2014 311 m€ 6,8%
2015 399 m€
2016 462m€
6.6%
6.8%
Channelized to Regulated market
2013 51%
2014 53%
2015 69%
2016 76%
Data: H2 Gambling Capital November 2014

On October 31st the Spanish Gambling Commission will start a new licensing process which will last until December 9th at 13.00 CET.
Under the new licensing process, operators will be able to apply for:
1. A General Licence, for all types of online games.
2. A Singular Licence for online slots (not permitted until now).
 Review of applications will take a maximum of 6 months. All approved new licence holders will receive their licence on the same date.
 An initial technical certification will allow operators to launch their service.
The complete technical certification should take place within 4 months from the licence issue date.

Approx. Go-
Live date
1 st November







9 th December 2014
Phase 1:
30 day licensing window for submitting applications.
April / May 2015 approx.
Phase 2: DGOJ to examine all applications. This includes requests for additional information, amendments, and obtaining reports from other official bodies. Once approved, licences are granted under a “provisional” status and operators may go-live.
September 2015 approx.
Phase 3: Operators have a 4 month deadline to obtain final technical certifications. Once approved by the
DGOJ, “provisional” licences become
“definitive”.
All dates included are approximate and subject to change due to several factors.
During Phase 1 new entrants will have the opportunity to apply for all general / singular licences available in the Spanish market. Once the licensing window is closed it will not be possible to apply for new general licences.
During Phase 2 there is a maximum 6 month term for the DGOJ to examine and resolve all applications. This term may be extended for various reasons, however considering that the number of applicants in the new licensing window is expected to be substantially lower than in the previous round (November 2011), it is not anticipated that this phase will take longer than six months.
As part of the technical information required, applicants will have to prepare a technical project which must be certified by a testing laboratory.
Essentially, the technical project must provide a detailed description of all hardware and software elements used by the operator to offer its games and must be drafted in accordance with the structure and content provided by the DGOJ.
The testing laboratory will also have to provide a limited certification of some key elements in the Internal Control System (ICS). The ICS is the technical system in charge of registering and storing all gaming transactions, to guarantee the control of the DGOJ on such information.
Just as in the previous round, all licence applications submitted during the licensing window will be resolved (approved or denied) at the same time for all applicants. Successful applicants will be granted a “provisional” license.
Once granted, operators will have an additional four month period in which to obtain a final certification of its technical systems (ie. a full certification about the compliance of all the operator’s technical systems with the applicable regulations). Upon validation of such certification by the DGOJ, the licence status will be changed to “definitive”.

Approx. Go-
Live date
1 st November 2014






9 th December 2014
Phase 1:
30 day licensing window for submitting applications
April / May 2015 approx.
Phase 2: DGOJ to examine all applications. This includes requests for additional info, amendments, and obtaining reports from other official bodies. Once approved, licences are granted under a “provisional” status and operators may go-live.
September 2015 approx.
Phase 3: Operators have a 4 month deadline to obtain final technical certifications. Once approved by the
DGOJ, “provisional” licences become
“definitive”
Essentially the schedule for existing operators is the same as for new entrants. Again, all dates are approximate and subject to change due to several factors.
The main interest for existing operators will be the possibility of applying for the slots singular licence (the exchange betting singular licence will also be available).
It is important to note that operators holding the “other games” general licence will be able to apply for the “slots” singular licence at any time, even after the closing of the licensing window. This will also apply to operators holding the “betting” general licence with regard to the “exchange betting” singular licence.
It will also be possible for existing operators to apply for a general licence that is not already in their portfolio. For example, an operator with the “betting” general licence will have the opportunity to apply for the “other games” general licence. It will not be possible to apply for new general licences once the licensing window expires.
Even if the applicants are already providing their services under the current regulatory framework, they will also be subject to provide all technical and certification documents. It is not possible to simply refer to documents previously submitted in the first licensing window.
Again, the new licences granted to existing operators will be awarded a “provisional” status. The status will be updated to “definitive” providing that the final technical certifications are submitted within a four month period following the granting of the licence.

 Applicants must be EU domiciled companies under the legal form of a Spanish Sociedad
Anónima, or the equivalent corporate form in other countries (which must be proven), and with a minimum share capital of 60,000 fully disbursed.
 The 2 million € guarantee (please see next slide for further details) may be constituted in cash or through a bank or insurance company guarantee, provided by a financial institution duly authorized to provide its services in Spain. A mortgage on a real estate asset based on Spanish soil may be admitted as well.
 There is an applicable amount of public fees which must also be settled to the DGOJ in order to apply: 5K for initial and definitive registration fees, 38K for the evaluation of the operator’s technical systems, and 10K for each general / singular licence for which the operator applies.
 It is also important to note that if new applicants have been actively targeting Spanish players in the past without a licence, this contingency should be carefully studied and analysed. It may result in exclusion from the process or the obligation to settle back-taxes.
 A PDF document with the full checklist of documents and information will be available after the webinar

For existing licensees - you do not need to change lab. There are 2 audits due in 2015, the scope of which are yet to be specified by the DGOJ, which cannot be carried out by the original certifying lab. Other than that it is business as usual.
Pre-certification, to accompany the licence application:
 Certification of technical project (Functionality and Security)
 A system and game design document
 The document must detail how your system complies with each requirement
 Per game requirement
 Certification to cover section c) only
 ICS Test - New licensees only
 User registration: RUD, RUT
 Gaming account: CJD, CJT

Due within 4 months of the granting of the provisional licence
Includes testing and certification of the following:
 General Licence – new licensees only
 Information System Security Certification – new licensees only
 Singular Licence
 Betting – Fixed Odds, Pool, etc and now Exchange
 Other games - Roulette, Blackjack, Bingo etc – and now Slots
 Full ICS test
 Operator questionnaire
 Live data test – 30 to 60 days after full licence is awarded

Specific Analysis
 Identity Checks
Integration Testing – on an environment identical to the live system
 User registration, receipts, payments, deposit limits, .es domain, ICS
Full ICS Test
 Verification of XSD schema, correctness of data, time stamps
Security
 Fraud, money laundering, critical components, change management, business continuity, data loss

Specific Analysis
 RNG, RTP games, game logic
Integration Testing – on an environment identical to the live system
 Game Offer, economic limits, error handling, ICS data
Full ICS Test
 Verification of XSD schema, correctness of data, time stamps

6 months from the 1st of April 2015 to adapt to the format of XSD version 2
Exchange betting and slots should use the new version of the data model immediately
Records in different versions can coexist, as long as the following is always taken in to account:
 Once a type of record has been reported under version 2 you can’t go back to version 1
 You can correct version 1 records using version 1 before migration, or version 2
 The following records should be migrated together:
 User registration: RUD, RUT, RUG, RUR
 Gaming account: CJD, CJT
 Operator account: OPT, ORT, BOT
 Game information: JUD, JUT, CEV, JUA - can be migrated for each game type

Q and A

Pedro López: pedrolopez@martinandino.com
Andrew Rosewarne: andrew@nmi-gaming.com
Willem van Oort Willem@Vanoort.com
Thank you 