Illustrated portrait of Giulia Romano

About the author

Giulia Romano

Consulente indipendente — iGaming ADM e finanza CONSOB (ex-Sirius Sport Italia)

Giulia Romano ha lavorato per sei anni a Sirius Sport Italia (2018-2024) sul book di traffico regolamentato — operatori iGaming licenziati ADM e affiliati CONSOB. Se n'è andata nel marzo 2024 perché il ciclo di revisione compliance era diventato più lungo del ciclo di campagna.

Background

Giulia joined Sirius Sport Italia in early 2018, six months before the Decreto Dignità banned most gambling advertising in Italy and changed every assumption every Italian iGaming operator had been working from. The job was meant to be a junior media-planning role on the iGaming book. Within a year she was the person clients called when they had a question that involved both ADM licensing implications and CONSOB tolerance for adjacent creative — because the senior planners had been trained before the reform and the lawyers were too expensive to call for the third revision of the same headline.

What she learned in the next six years isn't in any industry write-up. It's in the gap between what the regulation says and what the regulator actually enforces — the difference between Article 110 read literally and Article 110 as the ADM applies it to popunder placements on Italian publisher properties; the gap between a CONSOB-compliant investment-affiliate landing page and a Banca d'Italia-compliant consumer-loan affiliate landing page (they are not the same, and the buyers who treat them as the same get a letter); the regional reality that Milano CPMs and Napoli CPMs and Palermo CPMs behave as three different markets even when the operator and the offer are identical.

She left Sirius Sport in March 2024 after the post-2024 ADM reform consultation period closed and the agency's response was to cut creative budget and add three layers of internal review. She started writing publicly because the conversations she was having with operators in private — about which creative would survive an ADM letter and which wouldn't, about which Italian-specific networks paid on time and which didn't — were conversations the industry couldn't have in public while everyone was still on someone's payroll.

What Giulia writes about

  1. 01 Italian ADM licensing — post-Decreto Dignità 2018, post-2024 reforms. The ~95 ADM-licensed operators, their licence categories, their typical creative tolerances.
  2. 02 Italian finance affiliate compliance — CONSOB (investment products, including CFDs and consumer-facing trading platforms) and Banca d'Italia (consumer loans, BNPL, credit cards).
  3. 03 Italian iGaming buying patterns — Northern Italy (Milano, Torino, Bologna) vs Central (Roma, Firenze) vs Southern (Napoli, Bari, Palermo). The CPM split, the conversion split, the LTV split.
  4. 04 Italian-specific payment methods — Carta di Credito vs Postepay vs SEPA Direct Debit vs the newer Bancomat Pay flow. Conversion rates differ meaningfully.
  5. 05 Popunder format economics — adjacent expertise; she ran popunder budgets but is vertical-deep, not format-deep. Defers to format-specialists for non-Italian context.
  6. 06 What she avoids: technical SEO (not her domain), Anglo creative strategy (Italian creative is its own discipline), the post-2024 LATAM iGaming framework (she has read it; she has not run campaigns under it).

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