No wouldnt apply to us - id hate though that because one country mandated it, casinos remove the option altogether...probably not I guess
though we have seen instances where SOW seems to be leaking over, though not required for us
Not really true, by MGA rulings SOW need to be collected if you are categorized medium/high-risk player (like in UKGC, some casinos just are for some reason using your lifetime threshold as been spoken here in many topics, think still waiting reply to that one topic from Guts where player got freespins with no deposit but was triggered for SOW, when making withdrawal but we havent hear lot from them....).
All these SOW requests should be based on risk analysis completed by casino, AFAIK player who plays 50€ monthly for 10 years with no changes to deposit or playing pattern (also some other measurement in there which can make you higher risk player like your game play, payment methods etc....) should mandatorily need to be requested SOW.
Page 27 have quite clear and simple picture, also from page 34 there are some simple examples about risk factors. It is about casino how they want to operate, as earlier somebody posted UKGC ruling, it is quite similar. Just taking an easy way out and be over scared is use some fixed lifetime amounts but that 2000€.
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I happily stand corrected if i am wrong, but also MGA licensed casinos are required to complete risk analysis and requested SOW if they think it is needed (sorry, didnt mean to make it to SOW again, just point out that if you play under MGA licensed casino, you can be requested it, only way to get rid of it are probably some Curacao etc... licensed casinos)