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Possibility of partial liberalization of the online gambling market - Uruguay
Possibility of partial liberalization of online gambling (Uruguay)
Summary
Uruguay has historically developed gambling with a focus on offline (resort casinos, lotteries) and cautious digitalization. Partial liberalization of the online segment is not a "free market," but a managed admission: a limited number of licenses, phased entry of verticals, strict advertising rules and Responsible Gaming (RG) priority. The goal is to reduce the outflow to the "gray zone," maintain budget revenues and increase consumer protection - without loss of manageability.
Why discuss liberalization
1. Consumer protection: part of the demand still goes offshore; "whitewashing" puts players in a legally protected environment.
2. Budget and investment: GGR tax increase, duties, IT/support/compliance jobs.
3. Technology and UX: competition accelerates product upgrades, mobile experiences, honest SLA payments.
4. Risk control: legal operators take over KYC/AML, limits, self-exclusion, reporting.
Partial liberalization formats (variants)
Option A - "Sandbox" (Regulatory Sandbox)
The bottom line: 12-18 months are tested 1-2 verticals (e.g. bets/live casinos or RNG slots only) in a limited number of providers.
Pros: controlled launch, RG/AML analytics, flexibility.
Cons: limited assortment, risks of inequality of access.
Option B - Vertical Licenses
Essence: separate licenses for sportsbook, casino RNG, live-casino, poker/bingo.
Pros: Tax/control fine-tuning.
Cons: More complex oversight, possible "arbitrage" between betting and casinos
Option C - Limited Multi-Licensing
Essence: 3-6 licenses in the country with strict KPIs and annual revision.
Pros: competition and investment while maintaining manageability.
Cons: high entry threshold, transparent selection procedure is needed.
Case D - Model B2B2C
Bottom line: the national operator remains the front of B2C, private studios/platforms are allowed as certified B2B suppliers.
Pros: Controlled storefront, rapid content growth.
Cons: Less incentive for price competition and marketing innovation.
Tax and Financial Frame (Design Elements)
Taxable object: GGR (bets minus winnings), not turnover.
Rates and fees: GGR flat tax + one-off licence fee + annual supervision fee.
Earmarks: interest in RG, sports/culture, digital security funds.
Prohibition of "predatory" schemes: ceilings for bonus flips, caps for cashbacks, clear deadlines and examples of calculations in the interface.
Payments, KYC/AML and withdrawals
KYC by design: verification of identity, address, coincidence of the name of the payment method and account.
AML monitoring: transaction scoring, suspicious activity reports, limits on amounts and frequency.
Cryptocurrencies - limited: only with full on-chain screening and withdrawal to a registered bank account.
Payment SLA: public standards (e.g. T + 24-48 hours with full verification), visible cashout status in the application.
Advertising and communication (code)
Tone: "game = entertainment," banning promises of "quick money."
Age target: strict filtering 18 +, ban on channels with a youth audience.
Transparency promo: vager, deadline, maximum win - one screen, no stars.
Affiliates: register of partners, mandatory marking 18 +/RG, fines for violations, blacklists of sources.
Player Protection (RG) - mandatory minimum
Limits: deposit/loss/time; by default "soft" limits at registration.
Self-exclusion: a single inter-operator register, terms 24 h/7/30 days/6-12 months.
Reality-check: reminders about the time and session results, one-click pause timer.
Risk labeling: RTP/volatility in the game card, bet contribution to the jackpot, honest probabilities.
Support: round-the-clock chat/hotline, psychological assistance contact base.
Sport integration (for betting)
Partnership with leagues/federations, feed independence, monitoring of abnormal patterns, protocols for suspected match fixing.
Responsible sponsorship policy: banning logos on children's uniforms, RG disclaimers in stadiums and broadcasts.
Technical supervision
Certification of RNG and live platforms by independent laboratories.
Telemetry: session logging, anti-bots/anti-abuse, CAP on risky live scenarios.
Quarterly open reports: GGR, payments, RG metrics, AML/integration incidents.
Roadmap (0-24 months)
Stage 1 - Engineering (0-6 months)
Reform white paper, industry and NPO consultation on RG.
Definition of model (A/B/C/D), taxes and advertising code.
ToR for self-exclusion register and reporting portal.
Stage 2 - Selection and sandboxes (6-12 months)
Transparent tender/qualification of bidders.
Launch of 1-2 verticals in the sandbox, public KPIs and audits.
Stage 3 - Scaling (12-24 months)
Extension of the list of verticals/licenses upon achievement of KPI.
Publication of the annual RG/AML report; adjusting the advertising code.
Success KPI (at market level)
Fiscal: GGR tax, licence fees, earmarks (RG/sport).
Consumer: share of "white" accounts, NPS, median withdrawal time, share of successful transactions.
RG/AML: the proportion of accounts with active limits, the number of self-exclusions and duration, the response time of the support, the number of STRs submitted.
Integration: number of anomalies/investigations, cooperation with leagues.
Advertising: share of creatives with correct labeling, sanctions against affiliates, no violations of "watershed."
Risks and how to mitigate them
Hyperactive promo and pressure on vulnerable players → hard mouthguards, watershed watches, affiliate audits, fines/license pauses.
Gray segment growth due to pricing/assortment → competitive but controlled licenses; blocking non-legal sites + campaign information.
Money laundering through fast cashouts → on-chain screening (if crypto), limits, monitoring and reporting.
Negative to the image of sports → integrity agreements, a ban on sponsorship of children's sports, RG messages in the arena.
What stakeholders will get
State
Transparent revenues, managed market, RG/AML reporting, reduced gray turnover.
Operators
Clear rules, access to the market, a long payback horizon, subject to KPI and code.
Players
A legitimate product with quick payments, self-control tools and clear promo rules.
Tourism/economy
New jobs: support 24/7, compliance, data analytics, cybersecurity, IT integration.
Best Practices for Regulator
1. Start with sandboxes and limited verticals; link scaling to RG/AML KPIs and payout housing.
2. Oblige the unified register of self-exclusion to oflayn↔onlayn and public RG reports.
3. Introduce a simple and strict code of advertising and affiliates (including "black lists" of sources).
4. Register the SLA for verification and cashouts, the interface of the "one tap" payment status.
5. Invest in sports integration supervision and independent certification laboratories.
Partial liberalization of online gambling in Uruguay is about managed competition, not deregulation. A model with sandboxes, limited licenses, GGR tax, strict advertising rules and RG/AML priority allows you to return demand from offshore, improve consumer experience and increase budget revenues. The key to success is phasing, transparent KPIs and "safety rails" at every step.