The online environment still is a challenge for the Romanian tax legislation: Case study on income from gambling
By Alexandru Manucu, Tax Manager of Țuca Zbârcea & Asociații Tax
Starting March 23rd, 2018, for revenues earned by individuals from online gambling activities, the tax due is computed and withheld for each transfer from the gambling platform account into the bank or similar account. Consequently, the obligation to compute, withhold, report and pay the tax is allocated to the organisers and must be met by the 25th of the month following the month in which withdrawals are made.
Romania is an active environment where individuals of all ages and social backgrounds have an increased appetite for technology and everything that’s new. Whether we are talking about the IT sector, which gains an increasing share of GDP year-to-year, or if we refer to electronic cigarettes or to the blockchain technology that revived the mining-spirit in cryptocurrency “seeker”, Romanians are among the early-adopters. Going forward, professions / activities which have lost their shine make no exception and once they are moved online, they seduce more and more interested individuals. As previously highlighted, this trend also engulfed the gambling.
The legislator’s willingness to understand these new fields of interest and its objective to keep up with this trend, by providing the framework for the authorisation, deployment and taxation of these types of activities is nothing short of gratifying. Of course, the fast pace in which the online industry is developing creates difficulties in the application of unitary taxation mechanisms, and the need to adapt them to the specificities of revenue-generating activities is obvious. Perhaps even more important is the identification of non-functioning models and their improvement. Once again, the most eloquent example I can think of is that of online gambling revenue.
New rules regarding the Taxation Methods for Gambling Income
Although the gambling income tax regime is clear, the compliance obligations allocated to both organisers and players have been until recently somewhat disproportionate. Both parties were responsible for preparing detailed annual statements, addressing each individual withdrawal from the gaming account to their personal bank account. Subsequently, the Tax Authorities involved resources for processing the statements submitted by the players, for issuing the related tax decisions and, at least in theory, for the cross-checking between all players’ statements and the informative statements submitted by the organisers.
Thereby, given that all three parties involved – the state, the online gambling operators and the participants – were losing time and resources to ensure the payment of undisputed tax charges unequivocally considered to be fair, the issue of adjusting the taxation mechanism has been raised.
The solution? In line with the previous assertions and other opinions expressed by industry stakeholders, the obvious answer was the introduction of certain rules concerning the withholding of personal income tax due, implemented through the Emergency Ordinance No. 18/2018 regarding the adoption of fiscal-budgetary measures (“GEO 18”). Practically, it was intended to standardise the taxation mechanism for all gambling income earned by Romanian residents, according to the model of those obtained offline, by obliging gambling organizers to withhold the tax due from the revenues obtained by game participants (including those obtained at poker festivals).
Of course, the personal income tax remains an obligation for the participants, but the amounts actually received by them after the enforcement of GEO 18 are net amounts, the related tax being already withheld and subsequently transferred to the state budget by the operators. I believe that this notion will be easily absorbed at the level of the income beneficiary, as long as the relationship with the tax authorities is completely relocated to the organisers.
However, the latter do not escape the fulfillment of the existing informative / declarative obligations, and additionally, they must set up internal systems to ensure automatic compliance with this simplified fiscal framework for each withdrawal made by the participants.
Potential problems generated by the adopted measures
Without disregarding the opportunity of adopting such a measure, the timing of its implementation is at least uninspired, and it can generate a number of practical problems in the transition year – 2018. Although it was pointed out that the inconveniences regarding the need for transitional measures would be easily avoided if the legislator were to follow the implementation of these measures at the beginning of a tax period, such signals, including those from online operators, were ignored.
Therefore, they are currently facing a situation where they do not have the necessary IT systems to withhold the corresponding tax on withdrawals made by players from accounts opened on online gaming platforms. Given that the new provisions entered into force with the publication of GEO 18 the Official Gazette (i.e. March 23, 2018), with no time to allow the gaming platform to adapt to the new tax obligations, there have been and still are in practice situations where the income is transferred to the players’ bank account without withholding the tax.
With the clear intention of avoiding any damage to the state budget, the emergency solution identified by most online gambling operators is to bear from their own funds the tax for which they do not currently have technical computing and automatic withholding capabilities. In this context, the only fair method for both the state and the players is to calculate the tax due by the gross up method.
Conclusions
There is no doubt about the opportunity of adopting the measure whereby the obligation to calculate, declare and pay for gambling revenue deployed on online platforms is transferred to the operators. As I mentioned earlier, the timing for its entry into force is not proper. To conclude, the online gambling organisers were dealt a handful of aces, but the cards on the table stack the odds against them. We now have to see who will adapt their game sooner.
The General Data Protection Regulation -Rights of GDPR data subjects
We continue to present important information extracted from (EU) Regulation 2016/679 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC. In this edition, we shall elaborate upon the aspects which refer to the Rights of GDPR data subjects.
CHAPTER III: Rights of data subjects
Section 2: Information and access to personal data
Art. 13: Information provided in case personal data is collected from a data subject
(1) In case personal data referring to a data subject is collected from said data subject, the operator, at the time of obtaining this personal data, shall provide the data subject with all of the following information:
- a) the identity and contact data of the operator and, as applicable, of its representative;
- b) the contact data of the data protection officer, as applicable;
- c) the purposes for which the personal data shall be processed, as well as the legal basis
for the processing;
- d) in case the processing is performed in accordance with article 6 paragraph (1) letter (f), the legitimate interests followed by the operator or by a third party;
- e) the beneficiaries or the categories of beneficiaries of the personal data;
- f) if applicable, the operator’s intention to transfer personal data to a third-party country or international organization and the existence or absence of a decision of the Commission regarding the adequate character or, in the case of transfers mentioned under article 46 or 47 or under article 49 paragraph (1), second paragraph, a reference to adequate or appropriate guarantees and to the means by which a copy of said guarantees may be obtained, in case they have not been made available.
(2) in addition to the information mentioned under paragraph (1), upon obtaining the personal data, the operator shall provide the data subject with the following additional information so as to ensure an equitable and transparent processing activity:
- a) the period of time during which the personal data shall be stored or, if not possible, the criteria used to establish said period;
- b) the existence of the right to request, with regards to the personal data regarding the subject data, that the operator grant access to, rectify or delete this data or restrict the processing of said data or the right of refusing processing, as well as the right to data portability;
- c) when processing is based on article 6 paragraph (1) letter (a) or article 9 paragraph (2) letter (a), the existence of the right to withdraw consent at any given time, without affecting the legality of the processing performed based on the consent before its withdrawal;
- d) the right to submit a claim to the supervisory authority;
- e) of providing the personal data represents a legal or contractual requirement or a requirement necessary as to conclude a contract, as well as if the data subject is required to provide personal data and what are the potential consequences of breaching this obligation;
- f) the existence of an equitable automated decision process, including creation of profiles, mentioned under article 22 paragraphs (1) and (4), as well as, at least in the respective cases, relevant information regarding the used logic and regarding the importance and foreseen consequences of such a processing for the data subject.
(3) In the case in which the operator intends to subsequently process the personal data with another purpose than that for which the data was collected, the operator shall provide the data subject, before the subsequent processing, information with regards to the secondary purpose and respectively any relevant additional information in accordance with paragraph (2).
(4) Paragraphs (1), (2) and (3) shall not apply if and to the extent to which the data subject already holds said information.
Art. 14: Information provided in case the personal data has not been obtained from the data subject
(1) In case the personal data has not been obtained from the data subject, the operator shall provide the data subject with the following information:
- a) the identity and contact data of the operator and, as applicable, of its representative;
- b) the contact data of the data protection officer, as applicable;
- c) the purposes for which the personal data shall be processed, as well as the legal basis for the processing;
- d) the targeted categories of personal data;
- e) the beneficiaries or the categories of beneficiaries of the personal data, as applicable;
- f) if applicable, the operator’s intention to transfer personal data to a beneficiary in a third-party country or international organization and the existence or absence of a decision of the Commission regarding the adequate character or, in the case of transfers mentioned under article 46 or 47 or under article 49 paragraph (1), second paragraph, a reference to adequate or appropriate guarantees and to the means by which a copy of said guarantees may be obtained, in case they have not been made available.
(2) In addition to the information provided under paragraph (1), the operator provides the data subject with the following information necessary so as to ensure an equitable and transparent processing with regards to the data subject:
- a) the period of time during which the personal data shall be stored or, if not possible, the criteria used to establish said period;
- b) in case the processing is performed in accordance with article 6 paragraph (1) letter (f), the legitimate interests of the operator or of a third party;
- c) the existence of the right to request, with regards to the personal data regarding the subject data, that the operator grant access to, rectify or delete this data or restrict the processing of said data and the right of refusing processing, as well as the right to data portability;
- d) when processing is based on article 6 paragraph (1) letter (a) or article 9 paragraph (2) letter (a), the existence of the right to withdraw consent at any given time, without affecting the legality of the processing performed based on the consent before its withdrawal;
- e) the right to submit a claim to the supervisory authority;
- f) the source from which the personal data originates and, if applicable, if said data originates from publicly available sources;
- g) the existence of an equitable automated decision process, including creation of profiles, mentioned under article 22 paragraphs (1) and (4), as well as, at least in the respective cases, relevant information regarding the used logic and regarding the importance and foreseen consequences of such processing for the data subject.
(3) The operator shall provide the information mentioned under paragraphs (1) and (2):
- a) within a reasonable period of time after having obtained the personal data, no later than a month, by taking into full consideration the specific circumstances in which the personal data is processed;
- b) if the personal data is to be used with the purpose of communicating with the data subject, no later than the first communication had with the data subject; or
- c) if there is an intention to disclose the personal data to another beneficiary, no later than the date upon which said data is disclosed for the first time.
(4) In case the operator intends to subsequently process the personal data with another purpose than that for which the data was obtained, the operator shall provide the data subject, before the subsequent processing, with information with regards to the secondary purpose and respectively any relevant additional information in accordance with paragraph (2).
(5) Paragraphs (1) – (4) shall not apply if and to the extent to which:
- a) the data subject already holds the information;
- b) providing said information proves to be impossible or would imply disproportionate efforts, especially in the case of processing with the purpose of archiving in public interest, purposes of scientific or historic research or statistical purposes, under the conditions and guarantees provided under article 89 paragraph (1), or to the extent to which the requirement mentioned under paragraph (1) under the present article, it is possible to be subject to impossibility or to gravely affect the accomplishment of objectives associated to said processing activity. In such cases, the operator shall take adequate measures as to protect the rights, liberties and legitimate interests of the data subject, including making the information available to the public;
- c) obtaining or disclosing said data is explicitly provided by the European Union’s Law or by internal law, to which the operator is subjected and which provides adequate measures as to protect the legitimate interests of the data subject; or
- d) in case the personal data must remain confidential on the basis of a statutory requirement of professional secret regulated by the European Union’s Law or domestic law, including that of a legal obligation to keep the secret.
The (EU) Regulation 2016/679 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation) is to be applied in all Member States of the European Union as of May 25, 2018.
For more information, we recommend consulting the Data Protection Officer (DPO) Guide, which is available in the special section on the New Regulation on the website of the National Supervisory Authority for Personal Data – www.dataprotection.ro.
The Code of ethics on responsible commercial communication – beta version?
by Alina Dumitru and Andrei Cosma – NESTOR NESTOR DICULESCU KINGSTON PETERSEN
Alina Dumitru
In previous articles, we reviewed a series of regulatory initiatives or draft laws that, in the event of their
Andrei Cosma
entry into force, would generate a strong impact for the local gambling industry. However, all these lex ferenda proposals did not come from the gambling regulator, but from other authorities whose scope of competence extends also to the gambling sector. Nonetheless, in this issue we have the opportunity to make a short overview of a “pure blood” approach whose author is the National Office for Gambling (“NOG”) itself.
Thus, on February 14, 2018, the NOG published on its official website the Code of ethics on responsible communication in gambling (“the Code”). Inherently, any official attempt or position expressed by the NOG requires, as a preliminary technical examination, the determination of its legal nature and the effects it generates. This examination proved to be tortuous (to say the least) because, if the preamble to the Code states that it is “a set of self-regulatory norms” (although self-regulation, as a rule, entails a wholly different legal regime than the mere adoption of a unilateral act by a public authority), in the last section of the Code it is concluded, within the first paragraph, that the actors involved in the gambling sector “adhere freely” to the set of rules created, but, in the following paragraph, it is stated that the rules contained in the Code “are complementary” to the legal framework in the field of commercial communications.
A first official position regarding the legal force of this Code was expressed in the meeting of the NOG’s Consultative Committee organized on February 22, 2018, where the authority’s representatives stated that the document in question is purely consultative in nature and does not constitute an instrument for applying sanctions for possible violations of the rules/standards illustrated in the Code. Within the same meeting, it was agreed that the parties involved in the industry shall submit proposals for the amendment of the Code.
However, in the announcement published on NOG’s website on February 26, 2018, following the meeting of the Consultative Committee, the invitation to propose amendments is no longer included, but, instead, the authority addresses the proposal to the operators to “assume” the Code.
Even if, in our opinion, at this stage, we are not in the presence of a proper set of rules, we still consider useful to imagine the impact created by some of the provisions currently comprised in the published version of the Code.
We would like to flag, in this sense, the rule within the Code according to which “communication made through media that does not belong to gambling organizers, regardless of the channel used, will be made by being placed – through the organizers’ diligence – in the areas, pages, real or virtual, during hourly intervals for which, in the case of that particular communication channel, assurances can be given that at least 90% of the audience is over 18 years of age or that the channel is intended exclusively for this age group”.
Seen theoretically, this provision is grafted on the interpretation expressed by the National Audiovisual Council (“NAC”) within the framework of a general decision aimed at making certain TV ads compliant and issued in December 2017, within which the NAC argued that, starting with January 1, 2018, audiovisual commercial communications that referred to gambling could only by broadcasted between 23:00 pm and 07:00 am. However, the standard proposed by the NOG seems to lead to even more onerous restrictions than those put forward by the NAC, since implementing the rule from the current version of the Code could equate, in our opinion, to a total ban on gambling advertising on television. More specifically, according to the provisions of the National Audiovisual Code (a binding legal instrument), +18 channels cannot be broadcasted by audiovisual media services providers that are under Romanian jurisdiction, but only by foreign channels and in an encrypted manner; therefore, if we talk about “channels intended exclusively for this age group”, it could very easily be mistaken for the same restriction imposed by the National Audiovisual Code to +18 channels.
At the same time, with regard to the requirements of accuracy and clarity of those rules, we cannot fail to notice the rule in the Code which requires the provisions of guarantees on the minimum age of the audience, although, by definition, audience measurement and its categorizing is made by using statistics techniques, while conclusions are extracted on a sample basis, and not by an exhaustive analysis of an audience segment.
Another rule inserted in the Code, which is apparently contrary to commercial practices currently and largely used by many gambling organizers and which have not been censored by the NOG (up to now, at least), is the one that specifies that “communication must not be made through famous persons such as famous models, actors, athletes – by using their presence or image”. In our opinion, the impossibility of using, for instance, renowned athletes to promote a service that is so closely related to sports events could create an excessive barrier to commercial communication, since it is a standard marketing technique to use those people whose public image/reputation resonates in the perception of the recipients of the promoted product/service.
Therefore, although we cannot but welcome the NOG’s intention to create a set of responsible advertising rules meant to protect minors and other categories of vulnerable persons against the negative effects of gambling, it should be stressed that the notion of “responsible advertising” presupposes, first of all, the existence of advertising, and not its complete ban. Secondly, responsible conduct within the industry can only be attained by setting clear, predictable and transparent standards. In other words, one cannot be accused of irresponsibility, as long as one does not know clearly the limits of responsibility.
At this time, we can only hope that the openness manifested by the NOG in receiving the proposals of the industry to amend the Code will lead to the result desired by all those involved in this phenomenon, namely to create a viable, healthy industry that works in clearly defined parameters.
Place your bets!
2018: A year to consolidate the industry from ROMBET’s perspective
The year 2018 is the year in which the primary and secondary legislation, by means of GEO 77/2009 and GR 111/2016, shall entirely show their effects given that they have set the foundation of a regulation that is modern and in complete compliance with European recommendations with regards to a common goal, which is a stable and well regulated industry.
It is the year in which the NOG (National Office for Gambling) shall regulate certain key fields which have yet to be sufficiently clarified, be it either responsible games, which shall become more evident in 2018, including through the Responsible Game Foundation, a clarification necessary for approving publicity activities, because there are still debates and different approaches among operators, especially between the specificity of promoting on-line operators and land-based operators.
2018 is the year in which the provisions of the “tax revolution” enter into force and in which ROMBET, by means of the seminaries it shall organize, both in Bucharest and at national level, must give answers to a series of questions which are constantly asked by gambling organizers:
- Establishing the type of tax which is to be paid, by respecting the statement obligations provided by law:
- The income tax of micro-enterprises, in the context in which, on 31.12.2017, they gained income which has not exceeded the RON equivalent of a million euros, at the exchange rate valid upon the closing of the fiscal year, with the question, if, perhaps, with the approval of GEO 79/2017, things shall return to their initial provisions, according to which the income from gambling cannot be taxed as such;
- The specific tax, for activities provided under Law 170 from 2016 in conditions in which it does not enter within the income tax of micro-enterprises, which has priority against the specific tax for all other gambling adjacent activities;
- Practical measures as to apply provisions regarding transferring compulsory social contributions due on behalf of employees with obligations attributed to employers. To this respect, the employer is to establish, retain, declare and pay the obligations due by employees, as well;
The level of contributions due and the income tax starting with the year 2018:
Employee: social security contribution due to the state social security budget – 25%; health insurance contributions due to the Sole national health insurance fund – 10%.
Employer: labor collateral contribution due to the state budget – 2.25%.
Tax rate: the tax rate is of 10% and it is applied to the taxable income associated to each source of each category used to determine tax.
Speaking about 2018, Mr. Dan Ghiță, ROMBET president, said that “it is important to give the signal we have to give: we have consolidated market, stable, transparent and regulated. Moreover, we are predisposed to change as the desire to grow is still extremely strong. We have a young generation of business people in the industry, and this is another very good sign, because they have made their reputation in an era of change, they know what it means and are prepared for it. Even more so, they will also generate it”.
Mr. Bogdan Coman, ROMBET Executive Director, believes that 2018 shall produce several more changes: more and more support companies arise for the gambling industry, which provide services especially for specialized software development. “If we turn our attention to neighboring countries – Bosnia, Serbia, Macedonia, Bulgaria – we see that this is becoming a more and more accentuated trend. IT companies in the industry, from the Balkans, are becoming more and more important all over Europe. This represents an extraordinary opportunity for Romania because of the fact that our country is known for its human resources in IT. We believe that this trend shall go on and shall become even more evident this year, not only based on accessing resources in the region, but also as a result of internal growth signaled by many of our association’s members”.
From an organizational point of view, ROMBET hopes that 2018 shall be the year in which associations in the field shall work best together and shall unite their efforts for more unity in strategies and actions. It all has already started in 2017: now, it’s time to enforce the partnership between associations.
Editorial – A Big Family
by INSIDER
The year that just started could be a benchmark for our gaming industry. When I say this I rely on the analysis of the last few years. I feel that this year can be a very good one for us, with all the political and economic “madness” around us. Our market has reached a maturity level large enough to sediment what it has built in recent years. All it has to do is keep going on its own way and be consistent with the ideas and values it has been promoting lately. I think our industry is at the moment a model. Of course, we need to keep an eye on what’s going on around us, but I think we all have the ability to continue building a safe road for us. Many people depend on us, and that can only make us more responsible. The gaming industry is at this moment in Romania a support for the Romanian economy, both at the macro (statistics) and micro (human) levels. We pay taxes, employ people, contribute to the economic cycle through consumption of goods and services, entertain players / clients, carry out CSR-type activities and, above all, we are responsible! We congratulate you for what you have achieved and we are glad that we are also part of this big family.
At the end of last year, our magazine awarded the Las Vegas casino floors for the most dynamic territory development in Romania in 2017. This was due to the sustained growth of the company, the growth of the brand’s reputation and the fact that this company has become a representative one for our profile market. Now Las Vegas has a new owner in the person of Mr. T. Andranik, and he naturally chose the Casino Inside Magazine to introduce himself to the Romanian gambling industry. We welcome him and assure him of all our faith and support. Learn more about this topic in the Cover Story!
The Jack & Play Again is gradually becoming an important operator, a company that is investing more and more in its casino floors, people, marketing and brand. Their location in Deva was inaugurated in the fall of 2015 on the premises of Shopping City Deva, and not only does it benefit from an excellent location, but it also has a professional team which offers players a special place dedicated to best quality entertainment, in addition to marketing campaigns and promotions thought out in accordance with the specific of the location. Currently, the “Mercedes C Class” Campaign is in progress and its final draw which will take place on February 22, 2018! Besides the luxury car, prizes worth RON 78,000 will also be awarded. This campaign was carried out over almost 5 months, and the total prizes exceed RON 350,000!
Danemar Trading will turn 25 years since its inception in March this year! I believe this is extraordinary and we congratulate Victor Marin and his team of professionals for what they have done all this time. We love that Danemar makes a positive contribution to the procurement process between the manufacturer and the end customer, having a double role: Specialist and Supplier. They are leaders on the cash payment systems market and the largest Distributor and Authorized Service Center for payment systems in Eastern Europe. Learn more about their accomplishments and success by reading the material that we dedicated to their anniversary.
At the end of this first 2018 edition, Casino Inside team wishes you an excellent year, as we are convinced you will have it!
The 2018 Hot List
By Cristian Radu, Partner at Țuca Zbârcea & Asociații
After a long period of legislative convulsions, we can say quite strongly that this year the gambling industry has stepped on the path to normality, stability and relatively few uncertainties. The almost unanimous opinion of the industry is that Romania now has a consistent and functional legal framework which is fair for all market players.
However, as we already indicated throughout this year, some issues must still be considered in the near future, as summarised herein below.
Taxation of online players’ revenues
Despite the existence of a tax burden generally accepted by players as being more than reasonable, the practice has shown that compliance with operators’ and players’ declarative obligations and tax payment obligations raises many problems. Also, the processing of such information by the taxation authorities spends disproportionately large resources by reference to the relevance of such taxes for the State budget.
In line with most opinions in the industry, we supported the promotion of a legislative draft for the amendment of the Tax Code, which would provide for the withholding of the players’ income tax. Based on the latest developments, it seems that this desideratum may soon become a reality. At the beginning of December, the Romanian Senate voted the draft law for the approval of the famous GEO 79/2017 with an amendment providing for the withholding of such tax. Of course, the Chamber of Deputies will have the last say in this matter.
However, the lawmaker must carefully consider when such amendment should become effective. An immediate enforcement will surely cause a new deadlock, considering that it takes 3 to 6 months, depending on the platform complexity, to develop a software to allow tax withholding by operators. Also, the application of two sets of taxation regimes in 2018 can prove a major hassle for all stakeholders. Therefore, the most reasonable solution would be for the amendment to become effective starting with 1 January 2019.
Gambling advertising
Advertising is an essential instrument in promoting the gambling industry, particularly the online sector, and at the same time it is a major source of revenue for broadcasters. However, the National Audiovisual Council restricted, in March 2017, the broadcasting of (TV/radio) gambling advertising past 11:00 PM, on grounds related to the protection of minors. Without rebutting the grounds invoked by the National Audiovisual Council (CNA), we deem that in line with the practices of other European jurisdictions, this decision could be reviewed so as to allow the broadcasting of advertisements at any time slot under the conditions set by a self-regulatory body and to the extent that they do not include persuasive calls-to-action messages.
GDPR implementation as of 25 May 2018
It is a matter of public knowledge that the New Regulation on personal data protection entered into force on 24 May 2016, but its implementation was deferred for 2 years, so as to allow data processors to align their activity to the new standards. The amendments are substantial and ambitious, with particular implications for the gambling industry which provides B2C services. As from 25 May 2018, the new data protection regulations will be directly applicable in all Member States of the European Economic Area, and the penalties provided for the breach thereof call for special attention to this matter.
GDPR’s implications are complex and they can vary significantly from one data controller to another, according to the collected and monitored data, the current architecture of data processing automation systems, or the B2B relationships to other suppliers of specialised services on the gambling market, acting as data processors for the controller (valid for the entities outsourcing services of risk management, player profiling or database transfer related to player’s activity on platforms independent from controller’s platform, such as in case of SaaS implementation, where the service supplier provides both hosting and processed data storage).
Given that potential penalties can be extremely high (they may reach EUR 20,000,000 or up to 4% of the global turnover of data controller’s group, whichever is higher), gambling operators will have to make their best efforts to secure compliance with the new GDPR provisions.
Implementation of AMLD4
Similarly to GDPR, in the near future operators will have to take into consideration the new regulations on fighting money laundering and the financing of terrorism that will be set forth in the national legislative act implementing the AMLD4. The most important novelty will be an extension in the scope of enforcement of relevant legislation to all gambling suppliers. Several obligations will result for the entire industry, among which the most important concern the enforcement of know-your-client measures and those on reporting transactions in excess of EUR 10,000 and suspect transactions.
Please note that it is not clear enough when the national legislative act for implementing AMLD4 will be adopted, although the deadline for transposition has been exceeded.
Need to adapt the legislative framework to technological progress
The gambling industry has always stood out by its openness to the innovations brought about by technological progress.
Some time ago we mentioned that a new type of gambling needs special regulations, i.e. e-sports, an increasingly popular sector in many European jurisdictions with advanced gambling regulations.
At global level, lawmakers are now keen to accept cryptocurrencies as payment instruments in transactions between operators and players, and to allow the authorization of gambling platforms that operate exclusively on cryptocurrencies (the so-called blockchain gambling trend). We consider that this is an opportunity for the Romanian lawmaker to consider the regulation of a cryptocurrency system so as to position Romania at the forefront among the countries that have understood the importance of cryptocurrencies in trade relationships.
Still in draft stage – this time AMLD
By de Cosmina Simion and Andrei Cosma– NESTOR NESTOR DICULESCU KINGSTON PETERSEN
We promised in the previous article that we were going to tell you more about the possible implications for the gambling industry determined by the implementation of the fourth EU Directive on money laundering (AMLD).
It seems however that we have been a little too optimistic and in the following paragraphs we will not have the opportunity to analyze the situation in concrete terms for a very obvious reason: AMLD has not been transposed into national legislation to the date of this article and the relevant normative act is still in draft stage.
From the beginning, we would like to state that in what follows we do not intend to detail the content of the obligations and provisions of the Draft law, but rather to signal a status quo. We cannot however ignore the fact that the new legislative framework regarding money laundering and terrorism financing will impose considerably higher standards to prevent this phenomenon.
With regard to the gambling sector, a first important modification is the expansion of the category of reporting entities. Thus, if under the current law (Law no. 656/2002), only casinos are explicitly included, the new legislation expands the scope to the common category, namely to the generic category of all “gambling services providers”. Furthermore, the Draft law expressly specifies that the norms apply both to traditional gambling operators as well as to online gambling operators.
At the same time, we cannot fail to notice the modifications regarding know-your-customer measures or those applicable to keeping documents. Under the future normative provisions, gambling operators will need to run the process of identification and knowledge of the players by reference to a multitude of criteria and risk factors, being also obliged to keep the documents and information obtained in this sense on paper and in digital format, in a form that is admitted in judicial proceedings. Without dissecting the interpretation that can arise regarding these obligations, we can anticipate even now that the impact felt by operators will be a significant one.
Beyond the date that the Draft law will see the light of the Official Gazzette (it should be reminded that the deadline for transposing the Directive in national legislation was 26th of June 2017), a few substantial issues remain unclear. More specifically, by corroborating the provisions of the gambling legislation with those in the Draft law, it cannot be established with certainty if the new national law in the AML field will be applicable to non-resident online gambling operators that operate in Romania and offer services to local players on the basis of the license and authorization granted by the National Gambling Office (NOG) or if these non-resident gambling operators will be subject to the AML legislation in the country of their establishment only. This problem is not simply a theoretical issue, on the contrary, by reading the list published by NOG on their official internet page, one can notice that the overwhelming majority of the licensed operators is made up of nonresident entities.
With the desire to clarify this inconsistency, we looked for the official point of view of the regulatory authority, namely the National Office for Preventing and Combating Money Laundering (NOPCML). The position expressed during conferences as well as their written answers were, however, unclear and somewhat confusing, since NOPCML specified that the solution should be given by the NOG, as the authority that granted licenses to nonresident operators. Certainly, NOG’s powers cannot extend to issues regarding AML legislation, whose observance and interpretation are the responsibility of another regulatory authority, an aspect that NOG also confirmed.
It seems, however that subsequently, NOPCML identified an answer to our question, through the voice of Ms Steluța Oncică, who, during the last edition of the Reunion of Gambling Professionals organized on the 7th of December 2017, specified clearly and concisely that nonresident online gambling operators who benefit from a license and authorization from the NOG are not subject to the reporting obligations that will be imposed by the new national legislation in the AML field, but that they will report the necessary information and transactions to the relevant authority from their state of residence.
We hope that the above represents NOPCML’s point of view and we will not end up in a situation where, at the moment of implementation, non-resident operators licensed in Romania will learn that they still have reporting obligations also towards the Romanian State or, even worse, are sanctioned for non-compliance.
The situation of these operators is still uncertain under the current Law no. 656/2002 (which implemented the third directive in the anti-money laundering field). In this case, it appears once again that NOPCML’ opinion has changed during time. Initially, non-resident operators licensed in Romania have been imposed with the reporting obligations established by Law no. 656/2002, but subsequently, the authority’s opinion has changed and they represented that the Romanian legislation in this field is not applicable for this category of operators.
The sequence of official and unofficial interpretations, expressed either in writing or publicly during conferences is difficult to follow even for us. From a regulatory perspective, there are no risks for these operators since they opted to over-report, even though (apparently) this was not necessary…or was it?
The implementation process seems to be far from being over, and the Draft law may still suffer amendments. Regarding certain estimates made by NOPCML representatives, the Draft law will enter into force in February 2018, but the secondary legislation is yet to be expected at the earliest at the end of next year.
Place your bets!
HAPPY BIRTHDAY!
by Insider
With this 80th jubilee edition, we also mark the 8th anniversary of our magazine.
These have been beautiful years, working for the gambling industry and its people. We have did our best to channel all our energies towards the good of the Romanian gambling community. We only have good intentions for our gambling market, for developing it and for changing its mentality from a closed, less communicative field (as it once was) into a transparent, active field that cares about its fate.
We went from fatality (remember the talks on tax increases and legislative changes of past years) to action, information, and involvement. It’s clear, there’s still a lot to do, and we’ll do it. We have our projects for the industry and when everything is ready we will inform you to get involved; we do everything for you.
As for this edition, I have to highlight the Cover Story material in which the company Imperial Slots represented by Mr. Bogdan Crețu gives us a lot of details about this important brand that has a significant share in the Romanian gambling market, holding over 3,000 slot machines, and having been active in this field since 2004, with its headquarters in Moldova in Fălticeni municipality, Suceava County.
This company has 100% Romanian capital and is run by a young management team, which is the driving force of the company. The company operates several other companies, which are spread out throughout the country and have 72 gaming rooms located in Bucharest and in the counties of Suceava, Bacău, Vaslui, Bistrița-Năsăud, Botoșani, Brăila, Constanța, Hunedoara, Timiș, Alba, Iași, Neamț and Caraș-Severin. In addition to these, the company also has several dozens of secondary offices.
All of these things have persuaded us this year at the gala event – the 4th Romanian Gaming Celebration on December 7 – to grant them the Best Gaming Operator outside of Bucharest Award, and to grant Mr. Bogdan Creţu, the General Manager of the company, the Award for Excellence in the Gambling Industry.
For the rest, the 80th CI edition includes only the high-quality and very interesting materials you’ve become accustomed to. We invite you to go through all of them because they are interesting.
I would like to take this opportunity to wish you from the Casino Inside Team:
“A very Merry Christmas and a very Happy New Year!”
May we meet again next year, in good health and with replenished strength!
THE 6TH ReUNION OF THE GAMBLING PROFESSIONALS -Another standard for business events-
Someone in whom we have great confidence told us at the end of our events of December 7: “Let’s see what you’ll be doing next year … because you’ve raised the bar high.” We’ve already figured it out and we’re going to start preparing an event for the spring of next year. We will certainly ask for your opinion on what you want us to discuss during our 2018 events.
This year, the 6th Reunion of the Gambling Professionals has achieved its goals. We’ve had over 120 guests in the audience, 19 speakers who covered topics for 10 panels, we’ve had countless presentations, analyses, statistics, questions, answers, debates, controversies, and a lot of people happy with what they got out of the 6th RPG edition.
The theme proposed this year was Responsibility and Profit in the Gambling Industry. We thought of it because it seems natural to us to balance the two notions as much as possible. We need to think about our business in the long-term and keep in mind that our role is to entertain people through quality games and entertainment. Sustainable profit occurs over time, as the players coming to our gaming rooms are protected.
We are convinced that this is the right trend and we noticed that the vast majority of gambling operators have understood this and have adapted their business policies and strategies accordingly.
We would like to provide you with an overview of the more important moments on December 7th in the Paris room of the Novotel Hotel in Bucharest at the 6th Reunion of the Gambling Professionals.
-FIRST PART-
The first part of the event took place between 10:00-13:00 and started with the presentation given by the President of the National Gambling Office (ONJN) Dan Iliovici, who succinctly reviewed the successes of his mandate so far and future projects. Vice-president Valentin Korman followed and presented a brief analysis of the ONJN Control Department, a department of the institution he is the head of.
This panel was completed by the speech of the former ONJN President, Mrs. Odeta Nestor, who wished to summarize her mandate as the head of the said office.
The panel dedicated to legislation was led by attorneys Mrs. Ana-Maria Baciu and Mrs. Cosmina Simion – the coordinators of the Gambling Practice Department of the Nestor Nestor Diculescu Kingston Petersen (NNDKP) law firm. They made a special presentation in the form of a case study of Social games / Skill games in Europe and discussed the future of this field represented especially by Daily Fantasy Sports in the field of gambling. The debates in which Dan Iliovici, Viorela Rădoi and Odeta Nestor took part mainly dealt with the interest of some companies in this field of licensing in Romania, and the search for the appropriate legislative framework in which these types of games could be classified under the current legislation. The fine line between classic gambling and these new types of games was also discussed, with controversy (at least with regard to legislation), namely whether DFS should be considered skill games or gambling.
Our main partner, NOVOMATIC, through Mrs. Laura Boşneag – Sales Manager, gave an interesting presentation on Responsibility and profit in the gambling industry. This presentation focused primarily on the need to combat the black market of counterfeit gaming equipment, presenting things from the player’s perspective, the operator’s perspective, the perspective of risk vs. profit and the perspective of the responsibility of the manufacturer. We saw an excellent presentation that highlighted the idea of legality and originality in the gambling market in our country, as unofficial sources claim that there are about 25,000 counterfeit pieces of gaming equipment on the Romanian market.
Responsible Gambling from the perspective of the Gambling Operator was a panel where dr. psychologist Cristian Andrei (the Responsible Gambling Program Consultant) surprised us by appearing at the event with Robert, a 21-year-old man, who presented to the audience, by questions and answers, his view of things as a gambler, and by doing this dr. Cristian Andrei wanted to provide a very interesting communication bridge between the players and the gambling operators in the room. It was interesting, it was especially useful, and at the same time I think this initiative has allowed us to see better how people outside the industry see us, and to better understand the perspective of the players and especially those who do not always manage to see gambling as a form of fun, but rather as one to attain more income.
The first session of RPG 6 ended with the disclosure from 3 perspectives of the impact of the New General Regulation on the Protection of Personal Data in the Gambling Industry in Romania. The speakers were: Adreea Ilie (Legal Department and Communication Counselor at the National Authority for Personal Data Processing Supervision (ANSPDCP) and Valentina Drăguț (ANSPDCP Operator Registration Service Counselor), Dana Matache (a lawyer specialized in the personal data processing legislation) and Iulian Matache (Privacy & Data Protection consultant).
All the presentations were well received by the public and were first given for our industry here at RPG 6.
We enjoyed having all the possible perspectives: The regulatory and control authority in the field – ANSPDCP, legislative applicability and explanation of common terms and the technical area of actual implementation. We assure you that we are starting with this topic and that we will develop it in future events.
Between 13:00 – 14:00 lunch was served at the Novotel hotel restaurant.
-SECOND PART-
The second part of the event took place between 14:00-17:00.
The afternoon session started with the panel Gambling and Transposition of EU Directive 2015/849 into the National Law. The speaker was Mrs. Steluța Oncică, Director of the Directorate for Inter-institutional Cooperation and International Relations within the National Office for the Prevention and Control of Money Laundering (O.N.P.C.S.B.).
Here there were heated discussions as well, in which Doru Gheorghiu, executive director of Romanian Bookmakers and Ana-Maria Baciu, NNDKP partner lawyer also took part. From the debate, I concluded that the thresholds and the exemptions from the law for certain categories of games in the industry are still under discussion and that from the time the law comes into force, there will be about a year of transition in its application.
The Panel dedicated to Human Resources in the Gambling Industry in Romania was led by the oldest and most renowned head-hunter and recruitment expert, George Butunoiu (founder of George Butunoiu Executive Search Consultants), who gave an original presentation pointing out the direct causality between the level of generalized trust in Europe made every five years within the European countries by
www.europeansocialsurvey.org and the matter of human resources. Mr. Butunoiu also answered questions from the audience. We have received the public promise that he will honor a new invitation from us to further debate this issue.
This panel ended with the presentation given by the Jobzz.ro job site, through Lăcrămioara Stan.
The following panel, on International Rules and Tax and Audit Issues in the Gambling Industry, was led by Mr. Dan Schwartz, a fiscal and accounting expert in our country, and focused on some practical considerations on revenue recognition, according to the US GAAP – Generally Accepted Accounting Principles in the United States. It was an exciting presentation for the specialists in the field and it was appreciated by the audience.
The Panel on insolvency was provided, with legislative data and applied information, by Andra Șurariu (Senior Lawyer at the Biriș-Goran law firm) who gave us a presentation on Insolvency and Gambling Organizations. Post-insolvency operation. Risks.
The last panel of the day was dedicated to the real estate area and gave us the opportunity to learn more about How the recent developments of the Romanian real estate market affect the Romanian gambling industry. The speaker was Costina Petrescu (executive director of the Titirez.ro real estate portal). On this occasion, we learned a lot about the average level of rents in commercial areas broken down by country or Bucharest neighborhoods, as well as street rental opportunities at this time, which are the ideal locations for gambling, perspectives and trends in this area related to gambling.
This event was a complete, gigantic one due to the diversity of the areas addressed, by the number of speakers and topics reported on a single day of the event. We wish to thank the Casino Inside team, Partners, Speakers and all those who were in the audience and who appreciated the major effort of putting together this organizational marathon.
WE WISH TO THANK OUR PARTNERS:
Main Partner
ADMIRAL – NOVOMATIC
Partners
GAME WORLD, BAUMBET.RO, BAUM GAMES
Exclusive Partner in the Patronage Area:
ROMANIAN BOOKMAKERS – THE PATRONAGE OF BETTING ORGANIZERS IN ROMANIA
LEGAL COLLABORATOR:
NESTOR NESTOR DICULESCU KINGSTON PETERSEN
-Un alt standard în materie de evenimente de business-
Cineva, în care avem mare încredere, ne-a spus la finalul evenimentelor noastre de pe 7 Decembrie: “să vedem la anul ce mai faceți…, pentru că ați ridicat standardul foarte sus”. Ne-am gândit deja și vom începe să pregătim un eveniment pentru primăvara anului viitor. Cu siguranță vă vom cere și vouă părerea despre ceea ce vă doriți să dezbatem în cadrul evenimentelor noastre din 2018.
Anul acesta ReUniunea Profesioniștilor din Gambling 6 și-a atins obiectivele. Am avut peste 120 de invitați în auditoriu, 19 speakeri care au acoperit subiecte pentru 10 paneluri, am avut nenumărate prezentări, analize, statistici, întrebări, răspunsuri, dezbateri, controverse și o mulțime de oameni mulțumiți cu ceea ce au plecat de la RPG, ediția a 6-a.
Tema propusă în acest an a fost Responsabilitate și Profit în Industria Jocurilor de Noroc. Ne-am gândit la asta pentru că ni se pare normal să punem cele două noțiuni într-o balanță cât mai echilibrată. Trebuie să ne gândim afacerile pe termen lung și să ținem cont că rolul nostru este să distrăm oamenii prin joc și entertainment de calitate. Profitul durabil se face în timp, odată cu protecția jucătorilor care vin în locațiile noastre de joc.
Suntem convinși că acesta este trendul corect și am observat că marea majoritate a operatorilor de jocuri de noroc au înțeles asta și și-au adaptat politicile și strategiile de business în consecință.
Aș dori să vă facem o trecere în revistă, punctând momentele mai importante, a ceea ce s-a întâmplat pe 7 Decembrie în Sala Paris a Hotelului Novotel din București la ReUniunea Profesioniștilor din Gambling 6.
-PRIMA PARTE-
Prima parte a evenimentului a avut loc în intervalul 10:00 – 13:00 și a început cu prezentarea Președintelui Oficiului Național pentru Jocuri de Noroc (ONJN) Dan Iliovici care a trecut în revistă succint reușitele mandatului său de până acum și proiectele de viitor. L-a urmat domnul Vicepreședinte Valentin Korman care a dorit să facă o scurtă analiză a Departamentului de Control din ONJN, direcție a instituției pe care o are sub conducere.
Panelul acesta a fost completat cu discursul doamnei ex-președinte ONJN, Odeta Nestor, care a dorit să facă o prezentare rezumativă a mandatului domniei sale în fruntea oficiului.
Panelul dedicat legislației le-a avut în prim-plan pe doamnele avocat Ana-Maria Baciu și Cosmina Simion coordonatoarele departamentului de Practică în Jocuri de Noroc a casei de avocatură Nestor Nestor Diculescu Kingston Petersen (NNDKP). Au făcut o prezentare deosebită sub forma unui studiu de caz a jocurilor Social games / Skill games în Europa și care ar putea fi viitorul acestui domeniu reprezentat mai ales de Daily Fantasy Sports în cadrul domeniului jocurilor de noroc. Dezbaterile la care au mai participat cu opinii Dan Iliovici, Viorela Rădoi și Odeta Nestor s-au axat mai cu seamă pe interesul unor companii din acest domeniu de licențiere în România, și căutarea cadrului legislativ potrivit unde aceste tipuri de jocuri ar putea fi încadrate în actuala legislație. De asemenea, s-a mai discutat depre linia fină dintre jocurile de noroc clasice și aceste tipuri noi de jocuri, existând încă controversa (cel puțin din punct de vedere legislativ) dacă DFS ar trebui considerate skill games sau gambling.
Partenerul nostru Principal, NOVOMATIC, prin doamna Laura Boșneag – sales manager, a realizat o prezentare interesantă cu tema Responsabilitate și Profit în Industria Jocurilor de Noroc. Această expunere axându-se cu precădere pe necesitatea combaterii pieței negre de echipamente de joc contrafăcute expunând lucrurile din perspectiva jucătorului, perspectiva operatorului, risc vs. profit și responsabilitatea producătorului. Ni s-a părut o prezentare excelentă care a subliniat ideea de legalitate și originalitate în piața jocurilor de noroc din țara noastră în condițiile în care surse neoficiale susțin că pe piața românească există aproximativ 25.000 de echipamente de joc contrafăcute.
Jocul Responsabil prin prisma Operatorului de Jocuri de Noroc a fost un panel unde dr. psiholog Cristian Andrei (Consultantul Programului Joc Responsabil) ne-a surprins prin apariția la eveniment cu Robert, un tânăr de 21 de ani, care a expus sălii printr-un exercițiu de întrebare și răspuns cum vede el lucrurile din perspectiva lui de jucător, iar prin acest mod dr. Cristian Andrei a dorit să ofere o punte de comunicare foarte interesantă între jucători și organizatorii de joc aflați în sală. A fot interesant, a fost, mai ales, util și totodată cred că această inițiativă ne-a permis să vedem mai bine cum ne văd oamenii din afara industriei, iar noi să înțelegem mai bine perspectiva jucătorilor și mai ales acelora care nu reușesc întotdeauna să vadă gamblingul ca pe o formă de distracție, ci mai mult ca pe una de a-și suplimenta veniturile.
Prima sesiune a RPG 6 s-a încheiat cu dezvăluirea din 3 perspective a impactului Noului Regulament General Privind Protecția Datelor Personale în Industria de Gambling din România. Speakeri au fost: Adreea Ilie (consilier Birou Juridic și Comunicare la Autoritatea Nationala de Supraveghere a Prelucrarii Datelor cu Caracter Personal (ANSPDCP) și Valentina Drăguț (consilier Serviciu Înregistrare Operatori la ANSPDCP), Dana Matache (avocat specializat în legislația prelucrării datelor cu caracter personal) și Iulian Matache (consultant Privacy & Data Protection).
Toate prezentările au fost bine primite de public și au fost în premieră realizate pentru industria noastră aici, la RPG 6.
Ne-am bucurat că am avut toate perspectivele posibile: Autoritatea de reglementare și control din domeniu – ANSPDCP, aplicabilitate legislativă și explicare termeni uzuali și zona tehnică de implementare efectivă. Vă asigurăm că suntem la început cu acest subiect și că-l vom dezvolta în cadrul evenimentelor viitoare.
Între orele 13:00 și 14:00 s-a servit prânzul în cadrul restaurantului Hotelului Novotel.
-A DOUA PARTE-
Partea a doua a evenimentului a avut loc între orele 14:00 și 17:00.
Sesiunea de după-amiază a debutat cu panelul Jocurile de Noroc și Transpunerea Directivei UE 2015/849 în legislația națională. Speaker a fost doamna Steluța Oncică, Director la Direcția de Cooperare Interinstituțională și Relații Internaționale în cadrul Oficiului Naţional de Prevenire şi Combatere a Spălării Banilor (O.N.P.C.S.B.)).
Și aici am avut parte de discuții aprinse la care au mai participat cu opiniile lor Doru Gheorghiu, director executiv Romanian Bookmakers și Ana-Maria Baciu, avocat partener NNDKP. Din dezbatere am înțeles că pragurile și exceptările de la lege pentru anumite categorii de joc din industrie încă se mai discută și că din momentul apariției legii va exista aproximativ 1 an de zile de tranziție în aplicarea ei.
Panelul dedicat Resurselor Umane în Industria Jocurilor de Noroc din România a fost susținut de cel mai vechi si reputat head-hunter și expert în recrutare, George Butunoiu (fondator George Butunoiu Executive Search Consultants) care a făcut o prezentare originală arătând directa cauzalitate dintre nivelul de încredere generalizată în Europa realizat o dată la 5 ani în cadrul în țărilor europene de către
www.europeansocialsurvey.org și problema resurselor umane. De asemenea, dl. Butunoiu a răspuns și întrebărilor venite din public. Am primit promisiunea publică de la domnia sa că va onora o nouă invitație din partea noastră de a dezbate mai pe larg această chestiune.
Acest panel s-a încheiat cu prezentarea realizată de site-ul de locuri de muncă Jobzz.ro, prin Lăcrămioara Stan.
Următorul panel, cel privind Regulile internaţionale şi problemele legate de taxare şi audit în industria jocurilor de noroc a fost susținut de domnul Dan Schwartz o somitate în domeniul fiscal & contabil din țara noastră și s-a axat pe câteva considerații practice asupra recunoașterii veniturilor, în conformitate cu US GAAP – normele profesionale contabile din Statele Unite. A fost o prezentare captivantă pentru specialiștii domeniului și a fost apreciată de auditoriu.
Panelul dedicat insolvenței a fost asigurat cu date legislative și informație aplicată de către Andra Șurariu (Senior Lawyer în cadrul firmei Biriș-Goran) care ne-a expus o prezentare cu tema Insolvența și societățile organizatoare de jocuri de noroc. Funcționarea post-insolvență. Riscuri.
Ultimul panel al zilei a fost cel dedicat zonei de imobiliare și ne-a oferit ocazia să aflăm mai multe despre Cum afectează actuala evoluție a pieței imobiliare din România industria jocurilor de noroc. Speaker a fost Costina Petrescu (director executiv al portalului imobiliar Titirez.ro). Cu această ocazie am aflat multe informații la zi despre nivelul mediu al chiriilor spațiilor comerciale defalcat pe zone ale țării sau pe cartierele Bucureștiului, dar și posibilitățile de închiriere pe street în acest moment, care sunt locațiile ideale pentru jocurile de noroc, perspective și tendințe în acest domeniu related cu gamblingul.
Acest eveniment a fost unul complet, uriaș prin diversitatea domeniilor abordate, prin numărul de speakeri și topicuri raportat la o singură zi de eveniment. Mulțumim echipei Casino Inside, Partenerilor, Speakerilor și tuturor acelora care au fost prezenți în auditoriu și care au apreciat efortul major în realizarea acestui maraton organizatoric.
MULȚUMIM PARTENERILOR NOȘTRI:
Partener Principal
ADMIRAL – NOVOMATIC
Parteneri
GAME WORLD, BAUMBET.RO, BAUM GAMES
Partener Exclusiv Zona Patronală:
ROMANIAN BOOKMAKERS – PATRONATUL ORGANIZATORILOR DE PARIURI DIN ROMÂNIA
COLABORATOR JURIDIC:
NESTOR NESTOR DICULESCU KINGSTON PETERSEN
