Peru’s Registro de Personas Prohibidas: Cross-Channel Self-Exclusion Obligations Under MINCETUR DGJCMT

Peru’s Registro de Personas Prohibidas a Acceder a Salas de Juegos de Casinos y Máquinas Tragamonedas predates Peru’s online gambling regime by more than two decades. Established under Ley N° 27153 of 1999 and administered by the Dirección General de Juegos de Casino y Máquinas Tragamonedas (DGJCMT) within the Ministerio de Comercio Exterior y Turismo (MINCETUR), the register was originally designed to bar named individuals from physical casino floors and slot machine halls across the country. When Ley N° 31557 of 13 August 2022, as consolidated by Ley N° 31806 of 28 June 2023 and implemented by Decreto Supremo N° 005-2023-MINCETUR of 13 October 2023, created Peru’s online gaming regime, the legislature did not build a parallel digital exclusion structure. It extended the pre-existing prohibition architecture into the online channel. For every authorisation holder operating a plataforma tecnológica de juegos a distancia or a sala de apuestas deportivas a distancia in Peru, compliance with the Registro de Personas Prohibidas is a pre-play gate, not an optional responsible gambling feature.

Legal Architecture: Ley 27153 and the Land-Based Origin

Ley N° 27153 constituted the foundational legal framework for casino games and slot machines (máquinas tragamonedas) in Peru. Under that statute, the DGJCMT was given authority to maintain the Registro de Personas Prohibidas, a list of individuals barred from entering and participating in gambling activities within licensed land-based venues. The register accepts inscriptions on multiple grounds: voluntary self-exclusion by the individual, inscription by a qualifying relative or third party acting on the person’s behalf, and administrative registration ordered by the regulator itself.

The MINCETUR portal continues to list “Inscribirse en el Registro de Personas Prohibidas a Acceder a Salas de Juegos de Casinos y Máquinas Tragamonedas” as an active public service, confirming that the land-based instrument remains operational in parallel with the newer online regulatory stack. Compliance officers entering the Peruvian market for the first time sometimes treat this register as a legacy land-based obligation with limited relevance to their digital operations. That reading is incorrect under the current statutory framework.

What Does Ley 31557 Actually Prohibit?

The prohibition provisions of Ley N° 31557, as analysed in the Estudio Echecopar (Baker McKenzie member firm) commentary on the law, establish the following categories of persons prohibited from participating in juegos a distancia and apuestas deportivas a distancia:

Minors. Persons under 18 years of age are categorically prohibited. The identity, age, and nationality or migratory status verification obligation in DS 005-2023-MINCETUR is explicitly linked to this prohibition: operators must verify these attributes before permitting a player to participate, not merely at initial account registration.

Persons with influence or incidence over game outcomes. Individuals whose position, role, or relationship gives them influence or incidence over the result of a sporting event or game are prohibited. This extends to officials, athletes, referees, and related persons in the sporting ecosystem, a provision with direct implications for sports-integrity compliance as well as responsible gambling controls.

Persons inscribed in the MINCETUR register. All individuals whose names appear in the DGJCMT-administered Registro de Personas Prohibidas are prohibited from accessing any MINCETUR-authorised online platform, regardless of whether their original inscription was for a land-based or online context. The cross-channel effect flows from the single register serving both channels.

“Se encuentran prohibidos de participar en juegos a distancia: Los menores de edad. Las personas con influencia o incidencia en el resultado de los juegos.”
, Estudio Echecopar (Baker McKenzie), summarising the prohibition provisions of Ley N° 31557, Ley que Regula la Explotación de los Juegos a Distancia y Apuestas Deportivas a Distancia

The statutory prohibition does not distinguish between a person who inscribed themselves voluntarily after developing a gambling problem and a person inscribed administratively following a court order or MINCETUR determination. Both statuses carry the same effect: the authorisation holder must deny access.

Operator Verification Obligations Under DS 005-2023-MINCETUR

Decreto Supremo N° 005-2023-MINCETUR, the administrative implementing regulation published on 13 October 2023, sets out the service conditions that authorisation holders must satisfy. Among these, holders must verify the identity, age, nationality, and migratory status of jugadores (players). The verification obligation under the regulation is the mechanism through which authorisation holders discharge the prohibition check: without accurate identity confirmation, an operator cannot determine whether a person’s name appears in the Registro de Personas Prohibidas or falls within a statutory prohibition category.

The regulation also requires that payment methods used by players must allow identification of the player and must be used exclusively by the registered player, an anti-circumvention measure that reinforces the prohibition framework. Authorisation holders may not accept cryptocurrency as a payment method, and the means of payment must link the transaction to the player’s verified identity. These provisions together form a technical architecture within which prohibition-list compliance must operate.

DS 005-2023-MINCETUR does not publish a verbatim “daily query” cadence in terms visible from publicly available secondary commentary. The implementing regulation’s technical specifications for precisely how and when authorisation holders must interrogate the DGJCMT-held register are contained in the relevant articles of the decree and in the technical standards issued under Resolución Ministerial N° 244-2023-MINCETUR. Operators should confirm the exact query frequency, API or file-transfer specifications, and response-time obligations directly with DGJCMT rather than inferring them from secondary summaries.

The Cross-Channel Architecture in Practice

Peru’s cross-channel design differs materially from the parallel-register models used in several European jurisdictions. Spain’s Registro General de Interdicciones de Acceso al Juego (RGIAJ) under Ley 13/2011 operates as a national self-exclusion register with its own distinct regulatory instrument, administered by the DGOJ and fed by both voluntary inscriptions and judicial orders. Sweden’s Spelpaus, formalised in technical terms by SIFS 2026:3, is an API-driven national register that all Swedish-licensed operators must query at defined trigger events. France’s Interdiction Volontaire, Germany’s OASIS, and Denmark’s ROFUS each operate as standalone national infrastructure sitting above individual operators.

Peru’s model is structurally different: there is a single DGJCMT-administered register, originating in the land-based Ley 27153 regime, that serves both land-based venues and MINCETUR-authorised online platforms. A player who inscribes in the Registro de Personas Prohibidas at a MINCETUR office or through the gob.pe portal, whether requesting their own exclusion or through an authorised third party, is simultaneously excluded from casino floors and from all authorised plataformas tecnológicas. The same administrative record produces two enforcement obligations: physical venue staff must refuse entry, and online platform operators must deny account access and play.

This creates a compliance interdependency that purely online operators entering Peru from markets with operator-level self-exclusion models (such as Curaçao, MGA Malta, or US state-level frameworks) may not expect. An operator with no land-based presence in Peru is nonetheless bound by an exclusion architecture whose primary input mechanism was designed for physical venues. The DGJCMT is the custodian of the register regardless of channel, and MINCETUR’s supervisory authority extends across both. For a full profile of Peru’s licensing requirements and how this framework fits within the broader authorisation regime, see the MINCETUR Peru licence requirements profile on this site.

Who Can Inscribe in the Register, and for How Long?

The Registro de Personas Prohibidas accepts inscriptions through several recognised pathways under the Ley 27153 framework, as confirmed by the current MINCETUR portal service listing. The individual requesting their own exclusion (autoexclusión) may approach MINCETUR directly. A qualifying family member or court order may also trigger inscription where the circumstances warrant. MINCETUR itself may register a person on administrative grounds where the regulator’s supervisory findings support exclusion.

The inscription creates a legal bar across all channels for the duration of the registered period. There is no separate registration process for online-only exclusion under the current framework: the land-based and online prohibition derive from the same entry in the same register. An individual seeking to self-exclude from online gambling in Peru cannot limit their exclusion to digital platforms while remaining permitted to enter a casino floor under the current statutory design.

Authorisation holders must ensure their player identification and account management systems are capable of receiving, matching, and acting on updates to the DGJCMT register. Given that new inscriptions take effect from the date of administrative registration, operators cannot rely on periodic batch downloads if the technical specifications of the DGJCMT interface impose a more frequent interrogation cadence. The current technical interface specifications are governed by the relevant provisions of DS 005-2023-MINCETUR and RM 244-2023-MINCETUR.

Sanctions for Non-Compliance

The sanctioning framework under Ley N° 31557 operates on a three-tier scale denominated in Unidades Impositivas Tributarias (UIT). The 2026 UIT value is S/ 5,500, set by Decreto Supremo N° 301-2025-EF. Infractions are classified as leves (light), graves (serious), and muy graves (very serious).

Light infractions carry 1 to 50 UIT, equivalent to up to S/ 275,000 (approximately USD 70,000 at approximate 2026 exchange rates). Serious infractions carry 50 to 150 UIT, equivalent to a range of S/ 275,000 to S/ 825,000. Very serious infractions carry 150 to 200 UIT, equivalent to S/ 825,000 to S/ 1,100,000, and may be accompanied by cancellation of the authorisation.

Permitting a prohibited person to participate in games or failing to maintain adequate verification systems capable of identifying prohibited persons sit within the category of infractions that, depending on the classification determination made by MINCETUR, are capable of attracting the upper bands of the scale. The combination of financial penalty and authorisation risk makes the prohibition-list compliance framework one of the higher-stakes operational obligations in the Peruvian regime, even for operators whose primary regulatory exposure is typically characterised as tax-risk from the IJD and ISC obligations.

The sanctions scale under Ley N° 31557 reaches 200 UIT plus authorisation cancellation for very serious infractions, making prohibition-list enforcement a financial and licensing risk, not a secondary compliance consideration.

Integration with PLAFT and KYC Requirements

The prohibition-list check does not operate in isolation from Peru’s broader player-protection and financial compliance stack. Resolución SBS N° 03622-2025, which imposed mandatory PLAFT (Programa de Lavado de Activos y Financiamiento del Terrorismo) requirements on MINCETUR-authorised operators from 15 October 2025, requires authorisation holders to implement identity verification and customer due diligence procedures under the supervision of the Superintendencia de Banca, Seguros y AFP (SBS). The USD 2,500 threshold for reporting unusual operations (ROS) to the Unidad de Inteligencia Financiera del Perú (UIF-Perú) applies alongside the player verification obligations.

Both the PLAFT regime and the Registro de Personas Prohibidas requirement share the same foundational obligation: operators must positively identify each player before permitting participation. A robust KYC workflow that satisfies Resolución SBS 03622-2025 will, if properly integrated with DGJCMT register queries, simultaneously discharge the prohibition-list verification. Operators whose KYC workflow was designed primarily around the PLAFT requirement should verify that their onboarding logic includes a discrete prohibition-list check rather than treating the two obligations as interchangeable.

MINCETUR’s obligation to share authorisation information with the UIF-Perú and SUNAT under the Ley 31557 framework means the regulator already maintains communication channels with Peru’s financial intelligence infrastructure. This cross-agency information flow is material context for operators assessing their overall compliance posture: the prohibition list, the PLAFT regime, and the tax reporting obligations (IJD at 12% and ISC at 1% from 1 July 2025) are administered by separate agencies, but all depend on the same underlying player identity architecture. Compliance teams building out their AML and KYC documentation can benchmark their approach against multi-jurisdictional frameworks covered in the AML and Financial Compliance hub on this site.

How Does Peru’s Model Compare to Other Regulated Markets?

Peru’s approach is instructive when placed alongside other regulated markets. Colombia’s Coljuegos regime operates a single-cédula (national ID number) player register through which an individual’s self-exclusion carries effect across all licensed online operators, somewhat analogous to Peru’s single-register logic but administered through a distinct digital concession-contract architecture. Brazil’s Portaria SPA/MF N° 2.579/2025 established a national self-exclusion register infrastructure for the federal betting regime, pushing the country toward a centralised model closer to European practice. The Brazil vs Colombia vs Peru comparison on this site sets all three frameworks side by side across player protection, AML, and market-entry requirements.

Peru differs from both Colombia and Brazil in that it has not yet established a separate standalone online self-exclusion platform with API specifications modelled on European centralised registers such as GAMSTOP (UK), Spelpaus (Sweden), or ROFUS (Denmark). Those systems were purpose-built for online channels and typically mandate real-time query-response cycles at defined trigger events. The DGJCMT register, by contrast, was designed around physical venue administration. Its extension to the online channel creates a practical implementation question about how authorisation holders are expected to interface with a register that was not natively designed for real-time API interrogation at scale. Operators with compliance experience from highly integrated online exclusion frameworks should not assume that Peru’s technical integration specifications mirror those of the European national register model.

For compliance teams assessing Peru alongside Ontario or Alberta, where the centralised self-exclusion architecture (BetGuard in Ontario and AGLC’s centralised self-exclusion programme in Alberta) was designed from the outset for online markets, the differences in integration depth are material to project planning and vendor selection. The Responsible Gambling Compliance hub on this site provides a comparative overview of national register versus operator-level self-exclusion models across all major regulated jurisdictions.

Operational Checklist for Authorisation Holders

For compliance teams building or reviewing their Peru operations, the obligations traceable to Ley N° 31557, Ley N° 27153, and DS 005-2023-MINCETUR produce the following operational requirements. Authorisation holders must maintain a player registration and identity verification workflow that confirms the player’s identity, age (confirming they are not a minor under 18), and nationality or migratory status before permitting play. That workflow must incorporate a check of the DGJCMT-administered Registro de Personas Prohibidas and must be capable of denying account creation and platform access to any person whose name appears in the register.

Authorisation holders must also manage the ongoing access obligation: a person who is inscribed in the register after account creation must be denied continued access from the point at which the exclusion becomes effective. The payment architecture must comply with the crypto prohibition and must use exclusively identifiable, player-specific payment methods that tie each transaction back to the verified player record. Where the PLAFT threshold is met, reporting obligations to UIF-Perú under Resolución SBS 03622-2025 apply in parallel.

No person with influence or incidence over game outcomes may participate on any authorised platform. Compliance officers responsible for sports-betting products should document how their platform operationalises this prohibition, including how the operator monitors and enforces it against players who may not be publicly identifiable as having such a relationship with a sporting event.

Record-keeping obligations under DS 005-2023-MINCETUR include maintaining databases to which MINCETUR can request access to verify player operations. Authorisation holders should ensure that prohibition-list check logs, verification records, and access-denial events are retained in a format accessible to DGJCMT inspection, consistent with applicable Peruvian data-protection requirements.

The precise technical interface specifications for querying the DGJCMT register, including query format, frequency, response handling for system unavailability, and data retention obligations, should be confirmed with MINCETUR directly and through qualified Peruvian legal and regulatory counsel. The framework described in this article is grounded in the primary statutory and regulatory texts available, the technical implementation layer requires engagement with DGJCMT’s current operational specifications.

Key Resources

Ley N° 31557, Ley que Regula la Explotación de los Juegos a Distancia y Apuestas Deportivas a Distancia, published 13 August 2022, Diario Oficial El Peruano.

Ley N° 31806, Modifies Ley N° 31557 to clarify concepts, published 28 June 2023, Diario Oficial El Peruano.

Decreto Supremo N° 005-2023-MINCETUR, Reglamento de la Ley N° 31557, published 13 October 2023. Available via gob.pe/mincetur.

Ley N° 27153, Original statutory framework for casino games and slot machines, establishing the Registro de Personas Prohibidas under DGJCMT, Diario Oficial El Peruano.

Resolución SBS N° 03622-2025, PLAFT regime for MINCETUR-authorised online gambling operators, effective 15 October 2025. Available via sbs.gob.pe.

MINCETUR Portal Service, “Inscribirse en el Registro de Personas Prohibidas a Acceder a Salas de Juegos de Casinos y Máquinas Tragamonedas.” Available at gob.pe/mincetur.

Estudio Echecopar (Baker McKenzie member firm), “Publican ley que regula los juegos a distancia y apuestas deportivas a distancia,” detailed commentary on Ley N° 31557 and its implementing framework.