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Who Controls the Market (Ministerio de Gobernación) - Guatemala

Shortly

Guatemala has no single modern law that comprehensively regulates casinos and online gaming; the base remains the norms of the Criminal Code and special regulations for certain formats. Therefore, market control is distributed: the key "visible" role is played by Ministerio de Gobernación (Mingob) - in terms of permits for lotteries, reefs and "similar games"; the rest is covered by general norms, municipal permits and supervision through AML/advertising/consumer protection.


1) What the Ministerio de Gobernación directly does

Issues licenses for lotteries, reefs and similar games. This is enshrined in Provincial Agreement No. 54-2015: "The Ministry of the Interior issues licenses for lotteries and other similar games"; tickets must contain license details and circulation parameters. In practice, the filing goes through electronic forms/mail and/or departmental governorships.

Coordinates departmental "Gobernaciones." The websites of the governorates directly indicate reliance on No. 54-2015 and KUoAP/Codex: this confirms that Mingob is an "entry point" for legal reefs/lotteries in the region.

💡 Important: Mingob does not administer a full-scale "casino act," and casinos are not formally legalized as a separate category at the national level.

2) What's not: why control looks like a "mosaic"

Unified codification of the gambling market (register of operators/games, technical regulations RNG/RTP, unified inspections) - no; this has been argued about for years in Congress (initiatives 4294, 4685), but they never became the current law.

A separate "online chapter." Online casinos/bets remain in the "gray zone": general norms apply (advertising, taxes, consumer protection, AML). Media and industry reviews consistently state the absence of modern online codification.


3) Who else is involved (besides Mingob)

SAT (taxes) - collection and control of payments/fines according to the general regime; the bills regularly discuss separate tax provisions for games.

IVE at Superintendencia de Bancos (AML/sanctions). Financial monitoring, risk-base approach, registration of obliged persons - critical for gambling operations and payment partners.

Municipalities - premises, operating hours, signs, mass of "land" requirements for halls/bars with devices. In practice, this explains the regional variation in rigor. (See also longstanding publications on real-world claims.)

Ministry of Public Security/Prosecutor's Office (MP) and Police (PNC) - suppression of illegal halls/machines under the Criminal Code, especially for risks for minors. New initiatives directly increase criminal liability for "slots in stores."

Consumer protection/advertising (DIACO, etc.) - general rules apply to promotions/issuing prizes, transparency of conditions.


4) Change projects (what the market is breathing in 2025)

Reform of the Criminal Code (initiative No. 6645) - toughening responsibility for illegal slot machines in shops/puestas, emphasis on protecting children and immediate closure of points. This strengthens the "punitive circuit," but does not create a full-fledged licensing "online chapter."

Old initiatives (4294, 4685) - offered a basic betting/casino/video lottery framework; discussion about the need for a single regulator has been going on for more than ten years.


5) What it means for businesses and players

For reef/lottery organizers

Work through Mingob/departmental Gobernaciones to # 54-2015; indicate the license details on the tickets, keep a report on the prize funds.

For halls with devices/" mini-casinos"

Risks have grown: the trend towards the criminalization of illegal slots and the closure of points. Check legal grounds, age control, cash register and communication with municipal regimes.

For online operators/affiliates

There is no formal "online act": rely on AML/KYC (IVE), transparent advertising, consumer norms; be prepared for the requirements of payment partners (SLA payments, rejection of "dark patterns").

For the players

Legal lotteries/bingo receive permits through Mingob; for the rest of the formats, check the transparency of the rules, payments and support channels - there is no single national register of casinos.


6) Pros and cons of the model with Mingob "in the center of lotteries"

Pluses

There is a clear channel for socially acceptable formats (lotteries/reefs), including charitable ones.

Minuses

Fragmentation: different practices by region, no single digital register of licenses/operators.

Payment risks: banks/PSP need a predictable framework; without it, derisking is higher. (Industry reviews point to this multiple times.)


7) Recommendations until 2030

1. Leave Mingob for lotteries/reefs, but create a single e-portal with a register of permits (open data, QR validation of tickets).

2. Codify online products (slots/live/sports/eSports/bingo) and advertising/affiliates; synchronize with IVE AML requirements.

3. Update the Criminal Code regarding illegal slots (already in operation), but supplement with the administrative part: equipment standards, RG-minimum, inspection procedures.


Today the Ministerio de Gobernación in Guatemala is the profile body for lotteries/reef, operating under No. 54-2015; casinos/online remain outside of a single codification, and control is distributed between municipalities, tax and AML departments. For a predictable market by 2030, we need: a single register and an e-portal, an online chapter, agreed AML/advertising standards and an update of the criminal administrative part against illegal devices - then the "mosaic" will form an understandable system for the state, business and players.

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