Payments for participation in games of chance, whether they are organized on the Internet or in areas designated for this purpose, should be made possible exclusively through payment cards, which would be used at the same time for player registration.
This is one of the proposals that about thirty non-governmental organizations and several individuals, including parents of persons with the problem of this type of addiction, sent to the Ministry of Finance for the Draft Law on Games of Chance.
Apart from the fact that in this way, as they state, the possibility of minors to participate in games of chance would be completely suppressed, it would also, they add, "prevent the widespread practice of cheating".
Accelerator of social changes-Zid (ADP-Zid), as the initiator of the initiative, is an organization that has been dealing with the problems caused by the organization of games of chance for more than 15 years. They are the founders of the "Entera" counseling center in Podgorica, which deals with the prevention and treatment of people with problems caused by gambling.
Among the non-governmental organizations that supported the initiative are the "Parents" Association, Civic Alliance, Montenegrin Women's Lobby, Center for Civil Liberties, Center for Investigative Journalism of Montenegro, NGOs "Prima", "Prona", Sos telephone for women and children victims of violence from Nikšić and Podgorica, LGBT Forum Progress...
In the comments sent to the finance department, they state that the problem with gambling, according to the International Classification of Diseases ICD-10, is described in the chapter "Habit and impulse control disorder" as "pathological gambling (F63.0)" and that it is "a disorder where a person unable to resist gambling impulses, leading to serious health, family, social and professional consequences”.
"Although the analysis of the impact of the Law states that the first priorities of the new Draft Law are socially responsible organizing and prevention/protection of players and minors, we appreciate that the existing text missed the opportunity to fundamentally act in these two segments or take over the legal acquis of developed countries as the starting point and minimum for the arrangement of this area", reads the text sent to the department News of Vuković.
They add that the text of the law has been improved, but that "solutions are again being pushed that have not yielded any results so far":
"Like the distance of the gambling place from the school, which has now, look at the absurdity, been reduced from 250 to 170 meters, or the cancellation of the consent of the tenants' assembly to open a betting shop, which was foreseen in the previous Draft Law", the text reads.
In front of about thirty NGOs and several individuals, they presented several proposals for changes to the law. In addition to the request to abolish any possibility of cash payments, they propose regulation of that procedure through registration cards.
"In such a way that individual accounts would be linked to bank accounts and credit cards of cardholders and accounts through which cards can only be topped up. The cards would simultaneously be used for registration when entering the premises intended for the organization of games of chance and on the organizers' websites", they suggest.
Advertising
ADP-Zid and other NGOs believe that it is necessary to ban all forms of external advertising of organizers and their products and services, including billboards and any branding of automatic clubs and premises for organizing games of chance and betting.
"Introduce bans on advertising and advertising in the media, ban advertising on electronic media with the introduction of exceptions, which would improve the prevention of gambling addiction among children and minors. This also applies to all social media and profile owners, influencer accounts and pages," the initiative states.
Along with the proposal of how a specific article of the law should read, they also state that, exceptionally, advertising of organizers and organizers of games of chance can be allowed "on television and radio stations between 22.00:6.00 p.m. and XNUMX:XNUMX a.m., on the official Internet addresses of game organizers at fortunately, the websites of sports clubs sponsored by the organizer that advertises, as well as sports equipment of senior categories, and "inside the printed media".
In the proposal, they state that the advertising of games of chance "must contain a warning in the same font size of the organizer or the length of the advertising message" that persons under the age of 18 are prohibited from participating in games of chance and that games of chance can cause pathological gambling disorder with permanent consequences for the player and his family.
In the explanation of the proposal, they state that the text of the draft in the part related to advertising "does not provide adequate protection for children and young people".
"Especially bearing in mind that it is difficult to define which shows are for children and young people, and that advertising on the Internet and billboards is not completely excluded, leaving room for creative interpretation. Today, the Internet is the most powerful place for promotion. Also, it is possible to advertise logos and brands that, due to aggressive advertising in the previous period, clearly indicate the promotion of gambling... No care was taken about advertisements on jerseys and sports equipment of minors and all sports and other events intended for children and young people up to 18 years old. , they state and add that "it is necessary for everyone to ban advertising and displaying the logo of the organizer of games of chance".
The proposal of ADP-Zida and part of the NGO is to adopt the existing practice of addictive products in advertising.
"We propose a ban on all forms of sponsorship advertising and other forms of communication with content that directly or indirectly promotes gambling, while the following paragraphs or article would clearly define the exceptions that represent a permissible compromise with the media and clubs that generate the necessary funds for work," the comments state. .
Limit the number of daily payments, licensed training for employees
The proposal of ADP-Zida and about thirty NGOs and individuals who supported the initiative is that self-service terminals cannot be placed outside the spaces intended for holding games of chance.
Also, they propose to impose an obligation on bookmakers and automatic clubs to monitor the frequency of gambling and to limit the number of payments on a daily basis.
The draft stipulates that persons who are employed by the organizer and have direct contact with the players must be trained in preventive action against addiction to the players before starting their work. ADP-Zid and other NGOs are of the opinion that it is necessary to regulate the organizer's responsibility in this sense more precisely "by clearly defining the training of employees and the method of exclusion from the games".
Along with the proposal that the article of the law should specifically read in this sense, they state that "practice has so far shown that people who are employed by employers in most cases are not people who, by their profession, are qualified for preventive action in the field of addiction prevention".
In addition to mandatory licensed training, they add, it is also necessary to define the penalties that the entrepreneur-employer would face if this does not happen.
"Only in this way, the premises where games of chance services are provided would have adequate personnel to control the application of this Law", they believe.
From ADP-Zid and other organizations that signed the comments, they are of the opinion that "the public debate on the Draft Law was not at the expected level", and that "the public position of a number of actors in society was absent", among which they cite medical institutions, the University, religious communities, civil sector, media..."
"With this initiative, we express our concern for the future of children and young people, as well as for the status of all citizens and families who are faced with this problem. We ask for a serious revision of the law in such a way that, at the beginning of the organized action of the state in suppressing this problem, further damage can be prevented and the process of protecting citizens from the consequences that gambling leaves on individuals, their families and the wider community", the initiative states.
In addition to addressing the finance department, at the end of November a similar initiative was sent to the Police Directorate and the director at the time Zoran Brđanin. With the request of UP to support the initiative, they state that the law regulating games of chance "directly affects the prevention of criminal acts... embezzlement, unjust enrichment and money laundering":
"The proposal to prohibit any possibility of cash payment in betting shops or to a betting account has a direct impact and prevents payments by 'greenkeepers' and 'agents' to the benefit of other people's accounts and thus hinders the possibility of borrowing".
Alcoholism, depression, violence...
In the comments sent to the Ministry of Finance on the Draft Law on Games of Chance, among other things, it is written that "social and social consequences of gambling and diseases are devastating". "Persons who gamble at a pathological level abuse alcohol, and nearly three-quarters of gambling addicts have a developed picture of depression. The comorbidity of gambling addiction and antisocial personality disorder is often present, and even 60 to 90 percent of pathological gamblers meet the criteria for a personality disorder," the text adds.
From the civil sector, they also state that "pathological gamblers have the highest suicide rate compared to all other addictions", and that "violence in the family increases 10 times when the partner is a pathological gambler".
"In a study of 144 spouses of pathological gamblers, it was found that 50 percent of them were physically and verbally abused, and 12 percent attempted suicide. Research shows that teenagers whose parents gamble at a pathological level are at risk of developing a disorder in them as well," reads the comments on the Draft Law on Games of Chance, which was sent to the finance department by ADP-Zid on behalf of about thirty NGOs.
As they state, in Montenegro "the situation is alarming":
"Considering that we are one of the few European countries with an extremely liberal approach to this area, which, along with weak administrative capacities for control, leads to the current situation, which is reflected in the number of citizens with serious symptoms that classify them in the group of impulse control disorders-pathological gambling”.
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