Court backs broad GGL payment blocking order against foreign provider
The Halle Administrative Court upheld a GGL order barring a Swiss payment provider from processing payments for any unlawful gambling offer.
By Oliwer Brewitz, Head of Marketing
Key changes
- GGL payment blocking order upheld against a foreign payment provider
- Order may cover all unlawful gambling offers, not only named ones
- Confirms that national borders do not prevent enforcement
What changed
In a decision dated 2 October 2024, reported by the GGL on 14 October 2024, the Administrative Court of Halle (VG Halle) upheld a GGL order against a payment service provider based in Switzerland. The order barred the provider from facilitating not only specifically named unlawful gambling offers but all unlawful gambling offers. The GGL noted that this goes beyond the usual practice of first naming specific offers. Payment blocking under the Glücksspielstaatsvertrag 2021 is one of the GGL's main tools against the illegal market, alongside action against host providers and advertising.
What it means for advertising
The decision is not about advertising directly, but it strengthens the GGL's ability to cut off the revenue of unlicensed operators, which compete with licensed brands for the same audiences. Media owners and ad networks working in Germany should expect the GGL to keep using intermediaries, including payment and platform providers, to enforce the licensing requirement. This is likely to support licensed operators' share of the market.
What operators should do
Licensed operators should make sure that payment partners can identify them as whitelisted, to avoid accidental blocking of legitimate transactions. Media partners should check advertisers against the GGL whitelist before accepting campaigns. Operators should also review affiliates and partners to make sure none promote unlicensed brands alongside licensed ones, since this could draw GGL attention. Where a payment partner asks for evidence of licensing, the operator should be able to supply it quickly.
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