AML Compliance for iGaming and Online Gambling Operators

Gaming jurisdictions expect named AML officers and documented player risk controls. Licenses require ongoing audits and evidence of program effectiveness. We provide MLRO coverage and gaming-specific AML frameworks that satisfy regulators and payment partners

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Gaming compliance is not optional

Gaming licenses come with strict AML obligations. Jurisdictions like Malta maintain specific compliance frameworks that expect MLRO appointments and approved AML key function arrangements. Other major gaming licensing regimes impose similar requirements, though the specific rules and approval processes vary.

Regulators audit gaming operators regularly. They review player onboarding procedures, transaction monitoring evidence, suspicious activity reporting decisions, and compliance officer oversight. Audit findings can result in fines, license conditions, or in serious cases, license suspension.

Beyond regulatory requirements, payment processors conduct their own due diligence. They want evidence of affordability controls, velocity monitoring, and fraud detection before processing gaming transactions. Without strong AML documentation, you’ll struggle to maintain payment relationships.

This creates a practical reality: you need qualified MLRO coverage, documented controls addressing gaming-specific risks, and monthly evidence demonstrating program effectiveness.

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Controls that matter in gaming

Player risk scoring and segmentation

Not all players pose the same AML risk. Your framework must differentiate risk levels based on factors like deposit amounts, frequency of play, game types selected, geographic location, payment methods used, and behavioral patterns.

Risk scoring should be automated where possible, with clear thresholds triggering enhanced review. High-risk players require additional due diligence, source of funds verification, and ongoing monitoring. Your procedures must document the scoring methodology, risk thresholds, and enhanced due diligence requirements.

Velocity and structuring indicators

Gaming platforms see rapid transaction activity that can mask money laundering. Monitoring must detect patterns like repeated deposit-withdrawal cycles with minimal play, transaction amounts just below verification thresholds, payment method switching to avoid scrutiny, and cash-out requests shortly after deposits.

Your transaction monitoring approach should define specific scenarios for gaming activity, set thresholds based on your player base, document investigation procedures, and establish escalation criteria. Generic monitoring designed for traditional financial services won’t catch gaming-specific typologies.

Affordability and source of funds triggers

Regulators increasingly expect gaming operators to assess whether player activity is consistent with their financial situation. This means collecting source of funds documentation when deposits exceed what the player profile would support, conducting enhanced due diligence for unusually high spending, and potentially limiting or refusing deposits that appear inconsistent with affordability.

Your procedures must define affordability triggers, specify what documentation you collect, document how you verify source of funds information, and establish decision criteria for accepting or rejecting deposits. This is sensitive work that requires documented justification.

Game integrity and bonus abuse signals tied into AML review

While game integrity and bonus abuse are primarily fraud concerns, certain patterns warrant AML review. Coordinated play across multiple accounts, bonus harvesting followed by rapid cash-out, or exploitation of game vulnerabilities might indicate organized fraud or money laundering.

Your procedures should integrate fraud detection signals into AML alert triage, document when gaming integrity concerns trigger enhanced due diligence, and specify escalation paths for cases involving multiple accounts or suspected criminal activity.

Third-party payments and account transfers

Players sometimes attempt to deposit using third-party payment methods or transfer account balances between players. Both practices introduce money laundering risk. Your controls must prohibit or strictly limit third-party payments, verify payment method ownership at onboarding, detect and investigate account transfer attempts, and document decisions to allow exceptions.

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What gaming auditors look for

Gaming license audits focus on whether your AML program is designed appropriately and working effectively. Auditors review:

MLRO appointment and authority

Evidence that you've appointed a qualified MLRO, that they have appropriate access to information, and that they report to senior management or board level.

Risk assessment currency

Your current risk assessment covering player types, game offerings, geographic markets, payment methods, and distribution channels, with explanations of how risks have changed since the last assessment

Policy implementation evidence

Proof that documented procedures are actually followed, including samples of player onboarding decisions, transaction alert investigations, enhanced due diligence cases, and suspicious activity reports.

Training delivery and testing

Records showing that staff understand their AML obligations, including training attendance, test results, and evidence that training content addresses gaming-specific risks.

Monitoring effectiveness

Analysis of alert generation rates, investigation outcomes, false positive rates, and whether monitoring scenarios are tuned appropriately to detect suspicious activity without overwhelming investigators

Suspicious activity reporting

Documentation of STR decisions, including cases where you investigated activity but determined no report was necessary, showing that you're actively assessing risk rather than just filing reports

Auditors expect to see continuous program operation, not just compliance at the time of audit. Monthly evidence production is critical

Payment processing challenges for gaming operators

Banks and payment processors view gaming as high risk. They require extensive due diligence before processing gaming transactions, and they monitor your account activity for signs of AML control failures.

To obtain and maintain payment relationships, you must demonstrate:

Strong compliance officer oversight - Qualified MLRO with documented authority and regular reporting to management
Player risk controls - Automated risk scoring, enhanced due diligence procedures, and affordability assessment frameworks
Transaction monitoring - Gaming-specific scenarios, documented alert investigations, and evidence of suspicious activity detection
Fraud prevention integration - Controls showing you detect and prevent fraudulent activity that could indicate money laundering
Regulatory good standing - Current license status, recent audit results, and confirmation of no outstanding compliance violations

Payment partners may request monthly or quarterly compliance reporting as a condition of maintaining your account. Our service includes the evidence production and reporting that satisfies these requirements

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