Role of AML/KYC compliance in different licenses
Why does a player need to understand AML/KYC
AML/KYC is a verification of identity, address, payment methods and, if necessary, source of funds/wealth. The severity of the rules determines when the depth will be asked to be verified, how quickly the payments will go and what will happen with the "red flags." Different licenses have different levels of requirements and control.
Brief map of jurisdictions and severity level
What will really be checked
Base KYC (usually before first output):
When EDD is possible:
Source of funds/wealth (SoF/SoW):
Important license differences (more)
UKGC (UK)
Strict risk-oriented compliance, mandatory updating of risk assessments and procedures.
Increased focus on "customer interaction": if the customer's behavior does not match the acceptable risk profile, the operator must work through the validation/restriction scenarios.
MGA/Malta
Implementing Procedures Part II - Remote Gaming is binding: CDD/EDD, PEP, conversion of relationships with agents/outsourcers, suspicious activity reports, MLRO credentials.
Gibraltar
AML Code of Practice for remote gambling interprets the requirements of the Gambling Act and the Proceeds of Crime Act; the regulator relies on the FATF methodology and publishes industry risk assessments.
Isle of Man/Alderney
Industry codes/guidelines for e-gaming: what and when to collect, how to document risk assessments, how to submit SARs to FIU.
Alderney publishes separate AML/CFT guides and Internal Controls System requirements.
Curaçao (LOK, from 24. 12. 2024)
The new law replaced the old system of "master licenses," introducing more transparent oversight and raising KYC/AML and consumer protection standards. Details on online gaming and reform goals have been published by the regulator.
Important feature for Australia players
In Australia, online casinos offering slot machines are banned by Interactive Gambling Act 2001; ACMA regularly requires communication providers to block illegal offshore sites and publishes blocking lists. This means that access to individual offshore operators may suddenly disappear, and consumer protection may be weaker.
What this means in practice:
What a "normal" process looks like for a player
1. Registration and basic KYC
Immediately after registration or before the first withdrawal: they will request a document with a photo, address, confirmation of the payment method. In UKGC/MGA/Gibraltar/Maine/Alderney, this is the standard before access to full functionality.
2. Monitoring and possible EDD
With an increase in deposits/winnings, fast turnovers, a "non-standard" payment scheme or PEP indicators, they will ask for SoF/SoW (extracts, contracts, tax forms). For Malta, the order of EDD/inability to complete CDD is directly in IP Part II.
3. Payments
They check the coincidence of the name and payment method, they can ask for a second selfie check in case of a large withdrawal. In jurisdictions with high oversight, operators are required to adjust limits or suspend play if SoF is not confirmed.
Player checklist: how to quickly understand the "level" of compliance
We check the license and regulatory authority of the operator's website and in the register (UKGC/MGA/Gibraltar/O-in Maine/Alderney/Curacao LOK).
We read the AML/KYC section: are there any explicit references to CDD/EDD, SAR/MLRO, PEP checks, source of funds. (This is strictly standard for Malta.)
Test withdrawal of a small amount\\before the game with large bets.
We prepare a package of documents in advance: ID, address, payment confirmation, statement for 3-6 months.
We monitor ACMA notifications (the risk of blocking offshore sites if you play from Australia).
Frequent questions
Why is KYC sometimes asked for before the first deposit?
In hard licenses, the operator is obliged to cut off minors/sanctioned persons and "high risk" before the relationship begins.
Can the SoF verification account be frozen?
Yes I did. In Malta/UKGC/Gibraltar/Isle of Man/Alderney, with red flags, this is normal practice: until the documents are confirmed, the operator has no right to move on.
Curaçao is "not that" Curaçao anymore?
With the introduction of LOK (24. 12. 2024) the regime has noticeably intensified: the new law replaced the old model of master licenses, and the regulator outlined goals for a safer and more transparent environment. The practice is still being formed, but the requirements for KYC/AML have been tightened.
Conclusion
For an Australian player, licence difference = difference in defence, payout rate and depth of checks. UKGC/MGA/Gibraltar/Maine/Alderney - high AML/KYC standard and predictable procedures. Curaçao (LOK) is a new, tougher regime, but it needs time for a complete "run-in." Consider the risks of ASMA and confirm the sources of funds in advance - this saves weeks on conclusions and reduces the likelihood of blocking.
The material is informational and is not legal advice.
AML/KYC is a verification of identity, address, payment methods and, if necessary, source of funds/wealth. The severity of the rules determines when the depth will be asked to be verified, how quickly the payments will go and what will happen with the "red flags." Different licenses have different levels of requirements and control.
Brief map of jurisdictions and severity level
| Jurisdiction | General Strictness | What's Typical |
|---|---|---|
| UKGC (UK) | Very high | Strict risk assessment and "customer interaction," updated risk lists; enhanced checks on behavioral indicators and transaction profile. |
| MGA/Malta | High | Mandatory, legally binding Implementing Procedures Part II for remote-gaming: CDD/EDD, PEP checks, suspicious transaction reporting. |
| Gibraltar | High | AML/CFT Code for remote gambling as an interpretive guide to proceeds of crime laws; risk-based approach. |
| Isle of Man/Alderney | High | Industry AML codes and guidelines for online operators; Separate Regulatory Guides for SAR, CDD/EDD. |
| Curacao (LOK) | Medium → growing | The new LOK law has been in effect since 24. 12. 2024: transition from "master licenses" to full regulation, strengthening requirements for CCM/AML. |
What will really be checked
Base KYC (usually before first output):
- document with photo (passport/ID/in/out);
- Proof of address (invoice/bank statement ≤3 months)
- confirmation of ownership by payment method (wallet/card screen with disguise).
When EDD is possible:
- growing deposits/winnings;
- unusual payment schemes;
- PPE/sanctions indicators;
- inconsistencies in data or an attempt to play through high-risk payment channels.
- UKGC and other regulators require operators to update the risk assessment as "Emurging Risks" arise and interact with the customer when there is evidence of harm/laundering.
Source of funds/wealth (SoF/SoW):
- salary (certificate/extract), income from business/freelance (contracts, extracts), sale of assets (contracts), inheritance (notarial papers) - a clear trace of the movement of money. In Malta, the order and "inability to complete CDDs" are explicitly described in mandatory procedures.
Important license differences (more)
UKGC (UK)
Strict risk-oriented compliance, mandatory updating of risk assessments and procedures.
Increased focus on "customer interaction": if the customer's behavior does not match the acceptable risk profile, the operator must work through the validation/restriction scenarios.
MGA/Malta
Implementing Procedures Part II - Remote Gaming is binding: CDD/EDD, PEP, conversion of relationships with agents/outsourcers, suspicious activity reports, MLRO credentials.
Gibraltar
AML Code of Practice for remote gambling interprets the requirements of the Gambling Act and the Proceeds of Crime Act; the regulator relies on the FATF methodology and publishes industry risk assessments.
Isle of Man/Alderney
Industry codes/guidelines for e-gaming: what and when to collect, how to document risk assessments, how to submit SARs to FIU.
Alderney publishes separate AML/CFT guides and Internal Controls System requirements.
Curaçao (LOK, from 24. 12. 2024)
The new law replaced the old system of "master licenses," introducing more transparent oversight and raising KYC/AML and consumer protection standards. Details on online gaming and reform goals have been published by the regulator.
Important feature for Australia players
In Australia, online casinos offering slot machines are banned by Interactive Gambling Act 2001; ACMA regularly requires communication providers to block illegal offshore sites and publishes blocking lists. This means that access to individual offshore operators may suddenly disappear, and consumer protection may be weaker.
What this means in practice:
- if playing on an offshore site, look at the licence level (UKGC/MGA/Gibraltar/O-in-Maine/Alderney - higher protection; Curacao LOK - noticeably better than the old model, but still forms practice);
- take into account the risk of ASMA blockages and possible delays/disputes on payments from unregulated operators.
What a "normal" process looks like for a player
1. Registration and basic KYC
Immediately after registration or before the first withdrawal: they will request a document with a photo, address, confirmation of the payment method. In UKGC/MGA/Gibraltar/Maine/Alderney, this is the standard before access to full functionality.
2. Monitoring and possible EDD
With an increase in deposits/winnings, fast turnovers, a "non-standard" payment scheme or PEP indicators, they will ask for SoF/SoW (extracts, contracts, tax forms). For Malta, the order of EDD/inability to complete CDD is directly in IP Part II.
3. Payments
They check the coincidence of the name and payment method, they can ask for a second selfie check in case of a large withdrawal. In jurisdictions with high oversight, operators are required to adjust limits or suspend play if SoF is not confirmed.
Player checklist: how to quickly understand the "level" of compliance
We check the license and regulatory authority of the operator's website and in the register (UKGC/MGA/Gibraltar/O-in Maine/Alderney/Curacao LOK).
We read the AML/KYC section: are there any explicit references to CDD/EDD, SAR/MLRO, PEP checks, source of funds. (This is strictly standard for Malta.)
Test withdrawal of a small amount\\before the game with large bets.
We prepare a package of documents in advance: ID, address, payment confirmation, statement for 3-6 months.
We monitor ACMA notifications (the risk of blocking offshore sites if you play from Australia).
Frequent questions
Why is KYC sometimes asked for before the first deposit?
In hard licenses, the operator is obliged to cut off minors/sanctioned persons and "high risk" before the relationship begins.
Can the SoF verification account be frozen?
Yes I did. In Malta/UKGC/Gibraltar/Isle of Man/Alderney, with red flags, this is normal practice: until the documents are confirmed, the operator has no right to move on.
Curaçao is "not that" Curaçao anymore?
With the introduction of LOK (24. 12. 2024) the regime has noticeably intensified: the new law replaced the old model of master licenses, and the regulator outlined goals for a safer and more transparent environment. The practice is still being formed, but the requirements for KYC/AML have been tightened.
Conclusion
For an Australian player, licence difference = difference in defence, payout rate and depth of checks. UKGC/MGA/Gibraltar/Maine/Alderney - high AML/KYC standard and predictable procedures. Curaçao (LOK) is a new, tougher regime, but it needs time for a complete "run-in." Consider the risks of ASMA and confirm the sources of funds in advance - this saves weeks on conclusions and reduces the likelihood of blocking.
The material is informational and is not legal advice.
