Lithuanian Supreme Court Confirms Fine Against Amber Gaming for Unapproved Betting Offer

Investigation uncovered undisclosed betting restrictions

In May 2022, Lithuania’s Gambling Supervision Authority began an unscheduled inspection of Amber Gaming. The review followed a player complaint about limited access to betting options. Investigators found that the operator had used a custom “simplified offer” to block bets on lower-tier sports events. This offer did not appear in the public terms and conditions.

On November 10, 2022, the regulator issued Order No. DIE-762, imposing a €6,000 fine. The Authority cited Article 18(1) of the Lithuanian Gambling Act, which requires all terms that impact players to be clearly defined and publicly available.

Amber Gaming cited internal risk controls

Amber Gaming appealed the fine, arguing that its internal anti–money laundering and counter-terrorist financing (AML/CTF) policies justified the betting restrictions. According to the company, events with low popularity carried higher risk and required tailored controls.

However, the Vilnius Regional Administrative Court rejected the argument in November 2023. The court stated that internal policies cannot override the need for transparency in published terms and conditions. Without objective criteria in those terms, individual betting limits cannot be enforced.

Supreme court confirms the need for clear, equal terms

Amber Gaming brought the case to the Supreme Administrative Court. In its final ruling, the court dismissed the appeal. It confirmed that operators can only limit bets when terms are “clearly permitted and defined” in their public offer. The judges also emphasized equal access.

All players must receive the same betting options unless the rules state otherwise. If terms are not published and regulated, restrictions or suspensions are not allowed.