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What Stricter Oversight Means for Gambling Operators

Emma Shilling. eGaming outlook.
Emma Shilling

For legitimate online gambling operators, simply meeting minimum compliance standards no longer cuts it. Regulators are raising the bar, and operators must keep pace to remain licensed and avoid costly penalties.

 

As oversight becomes more stringent across key jurisdictions and regulations are updated to reflect international AML best practices, operators face growing pressure to go beyond basic legal or technical compliance. At the same time, demonstrating robust responsible gambling practices is now essential to running a credible and competitive business.

 

There is a clear shift toward proactive, player-centric approaches that prioritise consumer protection and social responsibility. The most forward-thinking operators embed safer gambling into their core business strategies, not just to meet regulatory requirements, but to align with the expectations of customers, regulators, and other stakeholders.

 

Existing Measures

 

Operators are acutely aware of the potential risks associated with money laundering, terrorist financing, and problem gambling. In response, they have adopted a range of compliance measures and best practices to address these threats. Additionally, responsible gambling is an industry-wide priority, with operators implementing a variety of initiatives to safeguard their customers.


 Compliance

safeguarding

Enhanced Due Diligence (EDD)

 

EDD plays a vital role in the customer onboarding process, particularly for high-risk customers. Operators perform more in-depth examinations of customer activities and backgrounds to identify and mitigate risks associated with money laundering and terrorist financing.

Self-exclusion Tools

 

Self-exclusion tools allow players to voluntarily exclude themselves from gambling activities for a specified period. This helps players who may be struggling with gambling addiction to take control of their behaviour.

Risk-based Approach

 

A risk-based approach to AML and CFT compliance involves assessing the risks of money laundering and terrorist financing within the business and developing tailored measures to mitigate these risks. This method allows operators to focus their resources on areas of higher risk and enhances the overall effectiveness of their compliance efforts.

Responsible Gambling Education and Resources

 

Online gambling operators are providing educational materials and resources on responsible gambling, including tips for maintaining control, recognising the signs of problem gambling, and seeking help if needed. This ensures that players have access to information that can assist them in making informed decisions and adopting healthy gambling habits.

Ongoing Transaction Monitoring

 

Continuous transaction monitoring enables operators to identify suspicious activities in real-time. This involves flagging unusual transaction patterns, large transactions, or transactions involving high-risk jurisdictions.

Age and Identity Verification

 

To prevent underage gambling, operators are adopting strict age and identity verification processes. This ensures that only individuals of legal gambling age can access the platform and participate in gambling activities. Robust age and identity checks also contribute to the overall integrity of the online gambling industry.

Information Sharing and Collaboration

 

Cooperation and information sharing between online gambling operators, regulators, and law enforcement agencies are becoming more common. This collaboration helps to improve the overall efficiency and effectiveness of AML/ CFT/ CPF efforts in the online gambling industry.

Reality Checks and Reminders

 

Many online gambling platforms are implementing reality checks and reminders to inform players about the time spent gambling and the amount of money they have won or lost. This helps players maintain awareness of their gambling habits and make informed decisions.

Employee Training and Awareness

 

Comprehensive AML/CFT/CPF training programs are essential for online gambling operators. Regular training and awareness initiatives help employees understand their roles in maintaining compliance and detecting suspicious activities.

Deposit and Loss Limits

 

Customisable deposit and loss limits enable players to set personal boundaries on the amount they can deposit or lose within a specific timeframe. This encourages responsible gambling habits and prevents excessive losses.

Source of Funds and Source of Wealth Checks

 

Verifying the source of funds and source of wealth for customers, particularly for high-risk or high-value transactions, is crucial in preventing the use of illicit funds in online gambling.

Time-based Limits

 

Time-based limits allow players to set restrictions on the amount of time they can spend gambling in a single session or over a specific period. This can help prevent excessive gambling and encourage healthier habits.


Support for Problem Gamblers

 

Online gambling operators are increasingly working with organisations that specialise in providing support and resources for individuals struggling with gambling addiction. This collaboration ensures that players have access to professional help when needed and demonstrates the industry's commitment to safeguarding its customers.


Recent Developments

 

Key bodies including the UK Gambling Commission (“UKGC”), Malta Gaming Authority (“MGA”) and Isle of Man Gambling Supervision Commission (“GSC”) have introduced or reinforced several important initiatives.

 

The UKGC continues to advance its Markers of Harm framework, expecting operators to use behavioural indicators such as changes in spend, frequency, time patterns, VIP status or distress signals to flag customers at risk of harm. Its Customer Interaction Guidance (SR Code 3.4.3), effective 31 October 2023, explicitly requires licensees to monitor and act on Markers of Harm.

 

Whether the introduction of prescriptive rules will prove fit for purpose remains to be seen. Many industry experts and veterans warn that such restrictions could be rejected by consumers, potentially driving them toward unregulated black-market alternatives.

 

The MGA has indeed strengthened its AML protocols, updated suspicious transaction reporting timelines, and reinforced internal control expectations for licensees under its AML/CFT supervisory framework.

 

Similarly, the GSC has strengthened its oversight regime in recent years, with a clear emphasis on AML, CTF, and overall regulatory enforcement. This shift has included more frequent and detailed on-site inspections, particularly targeting licensees’ risk assessments, customer due diligence, and ongoing monitoring practices.

 

Alongside enforcement, the GSC has pursued broader legislative reforms to enhance its investigatory powers and align with upcoming international standards, particularly in preparation for the 2026 MONEYVAL evaluation. Proposed reforms include expanded authority to examine beneficial owners and share information with domestic authorities under the newly introduced Permitted Disclosures Order.

 

The European Gaming and Betting Association (“EGBA”) is promoting greater alignment in regulatory standards across EU jurisdictions. Its latest report highlights how member operators are aligning with best practices in areas such as risk assessment, customer due diligence, and suspicious transaction reporting.

 

In 2026 the EGBA plans to update its AML guidelines to include a minimum set of required documents and expand guidance on payment flows, outsourcing, and sports integrity in preparation for the incoming EU AML Regulation and oversight role of the new European Anti-Money Laundering Authority.

 

Consequences of Compliance Failures

 

Enforcement activity across Q1 and Q2 2025 has continued to demonstrate the serious consequences of non-compliance, with regulators issuing substantial penalties and, in some cases, revoking licences entirely.

 

One UK-licensed operator was fined over £2 million by the UKGC for significant failures in its anti-money laundering (AML) and social responsibility controls. Issues included poor risk assessments, weak monitoring of customer behaviour, and inadequate source-of-funds checks. As part of the enforcement outcome, the operator was required to commission an independent external audit and strengthen its monitoring processes, including improvements to oversight systems.

 

Another UK operator received a £1.4 million fine for failing to identify and act on high-risk customer behaviour. The UK GC highlighted shortcomings such as insufficient affordability checks, limited customer interaction, and a lack of documented decision-making in response to potentially vulnerable players.

 

In Malta, the MGA revoked the licences of multiple remote operators in the first half of 2025 due to repeated regulatory breaches. These included non-payment of licence fees, weak internal governance, and ongoing failures in player protection obligations.

 

Similarly, the GSC has revoked several licences this year and carried out high-profile enforcement actions, citing a range of deficiencies from catastrophic AML failings to broader systemic compliance issues, including inadequate insufficient oversight and weak monitoring controls. These actions signal a firmer regulatory stance and growing intolerance for non-compliance.

 

These cases illustrate a consistent regulatory focus on real-world execution rather than just policy presence. Regulators have made it clear that operators must not only have frameworks in place but also demonstrate active monitoring, clear accountability, and timely intervention. There is an emphasis on the need for ongoing improvement, risk-based thinking, and a measurable commitment to player welfare.

 

Practical Application

 

Recent cases illustrate how regulatory expectations are being applied both through good practice and in response to operational failings.

 

One operator introduced a tiered risk-scoring model to assess affordability, categorising customers as low, medium, or high risk based on factors like deposit levels and play frequency. The model combined automated checks for lower-risk individuals with progressively detailed reviews, such as source-of-funds verification for higher-risk cases. The regulator reviewed and recognised this framework as best practice due to its proportionality and clear implementation.

 

By contrast, another operator failed to respond to escalating risk indicators in player behaviour. This resulted in a regulatory warning and mandatory retraining for customer-facing staff.

 

Technology is a key asset in remaining compliant, but well-designed, risk-based approaches are human designed and supported by knowledgeable and well-trained staff. Regulators are placing greater emphasis on solutions that demonstrate not only technical capability but also practical, day-to-day effectiveness and accountability.

 

Embedding Responsibility into Gambling Strategy

 

Compliance is shifting towards proactive, technology-driven oversight for real-time results, with regulators expecting operators to prevent harm before it occurs. Increasingly, this includes the use of artificial intelligence (“AI”) and machine learning to analyse real-time behavioural data and flag risks such as changes in deposit patterns or play duration.

 

Operators are also adopting predictive analytics to identify future risk based on historical behaviour, enabling earlier and more targeted interventions. Regulators are encouraging these tools to support timely, preventative action.

 

While not a replacement for human oversight, AI and machine learning provide scalable support for managing complex customer behaviours and help meet growing expectations for risk-based, tailored engagement.

 

At the same time, there is mounting pressure on operators to go beyond minimum compliance. Regulators and stakeholders are calling for greater transparency and for safer gambling to be embedded into everyday business practices. Operators who engage in voluntary codes of conduct and lead harm prevention efforts demonstrate a broader commitment to ethical practice and long-term player welfare.

 

Compliance and responsible gambling are essential to maintaining trust and ensuring long-term success, particularly for legitimate operators aiming for a listing, trade sale, or future M&A activity. Increasingly, operators are expected to go beyond basic legal or technical compliance and demonstrate a proactive, values-driven approach to governance and player protection.

 

There is a growing focus on proactive, player-focused approaches that emphasise consumer protection and social responsibility. The most forward- thinking operators now integrate compliance and safer gambling into their core business strategies not just to meet regulatory expectations but to build lasting credibility with customers, authorities and other stakeholders.

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