iGaming Compliance & AML Consultancy

Turn compliance requirements into day-to-day decisions

An iGaming compliance framework needs to do more than describe the law. It should tell teams what information to collect, which warning signs to investigate, who can make decisions and how those decisions are recorded. The controls must fit the product, customer base, payment methods, licence conditions and jurisdictions in which the business operates.

iGaming Firm helps operators and suppliers review their arrangements, identify gaps and organise implementation. We can support AML and customer due diligence procedures, governance documents, training, reporting templates and remediation plans. Our work can sit within a licence application, a platform migration, an acquisition or an ongoing compliance programme.

Start with the business-wide risk assessment

A useful risk assessment explains how the business could be exposed to money laundering, terrorist financing and other relevant financial crime risks. It should examine the customer profile, products, distribution channels, geography, payment methods, third parties and the way transactions move through the operation. It should also distinguish the risk before controls from the risk remaining after them.

An online casino with high-volume affiliate acquisition and crypto payments may have a different risk profile from a B2B game supplier with a small number of corporate customers. A generic policy shared across both businesses can miss the important differences. We help teams document the reasoning behind risk ratings and connect identified risks to specific controls and review actions.

The FATF's gaming and gambling risk material is a useful input for understanding sector vulnerabilities. It should inform a business-specific assessment rather than be treated as a substitute for local law or a finished company policy.

KYC and customer due diligence

Customer due diligence is a process, not a single identity check. It can involve identifying and verifying the customer, understanding relevant circumstances, assessing risk and maintaining current information. The timing, evidence and escalation requirements depend on the applicable regime. A universal deposit threshold copied from another operator is not a reliable foundation for a procedure.

We can help define the onboarding journey, acceptable evidence, handling of failed checks, duplicate account review and circumstances requiring further information. The procedure should explain how the platform prevents activity when a required check remains outstanding. It should also distinguish identification, age verification, AML assessment and safer gambling processes so that passing one check is not mistaken for satisfying every obligation.

For B2B relationships, due diligence may focus on the counterparty's ownership, regulatory status, business activity, management and source of commercial risk. The information requested should be proportionate to the relationship and securely handled.

Enhanced due diligence, PEPs and source of funds

Higher-risk situations can require a deeper review. A practical enhanced due diligence process identifies who can request additional information, which evidence is useful, what approval is needed and how ongoing monitoring should change. Politically exposed person screening and sanctions screening should be treated as distinct controls with clear procedures for reviewing possible matches.

Source of funds concerns the origin of money used in a particular relationship or transaction. Source of wealth concerns how an individual accumulated their overall wealth. A document request should be connected to the question the business is trying to resolve. Repeatedly asking for more files without explaining the relevant gap can produce a large record with little decision-making value.

We help create review templates that capture the customer's explanation, supporting information, inconsistencies, follow-up actions and decision rationale. The goal is an auditable assessment, with escalation when the available evidence does not resolve the concern.

Transaction monitoring and investigation workflows

Monitoring needs to reflect actual customer behaviour and product mechanics. Unusual patterns can include rapid movement of funds with limited play, activity inconsistent with the known profile, multiple linked accounts, unexplained third-party payments or unexpected changes in withdrawal behaviour. A signal warrants investigation; it is not, by itself, proof of criminal activity.

A monitoring workflow should specify who receives an alert, how it is prioritised, what information is reviewed and how the outcome is recorded. It should also explain when account restrictions or specialist escalation are considered and who can authorise them. We can help connect the written procedure with the platform's available data and the resources of the operations team.

For crypto casino operations, wallet and transaction intelligence can form part of the evidence. Blockchain visibility does not establish the identity of every person behind a transfer or the legitimacy of the funds. Technical findings need to be assessed alongside customer information and the wider account activity.

Suspicion reporting and the MLRO function

The framework should give staff a clear internal route for raising concerns and identify the person responsible for reviewing them. External reporting obligations, thresholds, timing and confidentiality restrictions must follow the applicable law. Staff should understand that escalating a concern internally and deciding whether a report is required externally are different steps.

We can help prepare escalation forms, decision logs, training and management reporting. Where an MLRO or other approved role is required, the appointment, authority, independence and access to information need to be assessed for the particular regime. A consultancy engagement does not itself appoint us to a regulated role or transfer the operator's responsibility.

For Malta-regulated work, the FIAU's current Implementing Procedures are a central reference. Part I and the relevant sector-specific Part II should be considered together, with current updates checked rather than relying on an old downloaded copy.

Safer gambling, complaints and wider compliance

AML controls are one part of a gaming compliance programme. Customer interaction, self-exclusion, complaints, advertising, game fairness and supplier oversight have their own objectives. A team should know which process applies, when concerns overlap and how information can be shared appropriately between functions.

We support responsibility matrices and procedures that connect those workstreams. For example, marketing suppression should be considered when an account becomes ineligible for promotions, and complaints should be examined for repeated operational problems. Our affiliate marketing service and legal services can help align partner obligations with the operator's controls.

Evidence, training and board reporting

A compliance calendar can organise policy reviews, regulatory returns, training, testing, audit actions and management reporting. Each item needs an owner, deadline and evidence of completion. Management information should show overdue actions and recurring problems, not only the number of checks performed.

Training should reflect roles. Customer support needs clear escalation cues; payments teams need transaction review procedures; affiliate managers need partner and promotion controls. We can help build training materials around realistic scenarios and maintain records that show the subject, audience and completion status.

AML record retention and GDPR

Financial crime records can contain sensitive information and extensive identity evidence. A retention schedule should identify the legal basis, applicable period, access restrictions and deletion process for each category. The fact that some records must be retained does not justify keeping every piece of player information indefinitely.

Our GDPR and data protection service connects retention, access controls, supplier arrangements and rights requests with the compliance programme. This is particularly useful when a customer asks for deletion while the business still has a specific record-keeping obligation.

How we scope a compliance project

A focused gap review can begin with your licence, target markets, existing policies, team structure and a summary of known issues. We then identify priority gaps, propose deliverables and agree who will implement each action. A fuller project may include policy development, workflow design, training, sample-file review and management reporting.

Can one AML policy cover every jurisdiction?

A common group framework can be useful, but local obligations and licence conditions still need to be mapped. Procedures should explain any differences in responsibilities, timing, records and reporting channels.

Will a KYC provider make the business compliant?

A provider can support defined checks. The business still needs to decide how the tool is configured, how results are interpreted, how exceptions are handled and whether the wider process meets its obligations.

This page provides general information and describes potential advisory support. It is not a legal opinion on a particular business, product or market. Scope and any specialist local advice are agreed for each engagement.