Online Casino Licensing Overview

1) Why do I need a license and what does it give

• reduces legal risks (fines, blocking domains/payments);
• opens access to banking/PSP channels and verified content providers;
• increases the confidence of players and partners;
• sets RG/AML and technical security standards, forming a predictable operating model.

2) Control models

Open market: competition of private operators under the supervision of the regulator (high requirements, high reputational returns).
Hybrid: monopoly/concessions on individual verticals (such as lotteries) and betting/casino licenses.
Monopoly: state operator; private B2C access is limited.
Federal/regional model: USA, Canada, etc. - licensing by state/province.

3) License types and roles

B2C (operator): the right to offer games to end users (casino, slots, live, poker, bingo, virtual sports).
B2B (provider): platform, aggregators, studios, live studios, payment and KYC providers.
Personal/Key Positions: Directors, Key Persons, MLRO/AMLO, DPO, RG Responsible Person.
Certification of sites/studios (for live/ground part).

4) Key regulatory domains (high-level overview)

Europe: national regulators (UKGC, MGA, SRIJ, KSA, DGOJ, etc.), strict RG/AML and advertising rules, emphasis on GDPR and GGR tax.
Caribbean and Offshore: available input requirements for global B2C/B2B, but different levels of recognition by markets/suppliers.
North America: Provincial/state licenses, high entry threshold, strong technical standards, and auditing.
Asia/LatAm/Africa: a mosaic of regimes from strict to prohibitive; often need local partners, strict marketing/payment rules.

5) Requirements for the applicant (due diligence core)

Beneficiaries and finance: transparent ownership structure, Source of Funds/Wealth, proven business reputation.
Policies and procedures: AML/CTF, Responsible Gaming, advertising, data protection/incidents, complaints, conflicts of interest.
Organizational structure: assigned Key Persons (MLRO/AMLO, DPO, RG-Lead), described roles and responsibilities.
IT architecture: service schema, encryption, logging, monitoring, DR/BCP, change and release control.
Contracts: game providers/aggregators, PSP, CCM/sanction screeners, hosting, auditors/laboratories.
Financial guarantees: provisions for payments, insurance (where required).

6) Technical standards and infrastructure

Deliveries and releases: staging pipelines, change control, artifacts (SBOM, signatures), change log.
Observability: end-to-end logs/metrics/trails, synthetic checks of key paths ("deposit/CCL/output"), storage of logs for audit.
Security: encryption in transit/at-rest, network segmentation, secret management, PAM/SSO/MFA, regular penetration tests/vulnerability scans.
Gaming software: RNG/RTP certification from accredited laboratories; equity and reporting controls.

Hosting/Residence DR Storage Region and Mirror Requirements

7) AML/KYC and sanctions compliance

Risk-Based Approach: Customer/Channel/Geography Assessment; In-Depth Validation (EDD) triggers.
KYC: age/identity/address; periodic re-CCR/trigger KYC.
Sanctions/REP: onboarding and transaction screening, decision log.
Transaction monitoring: limits, velocity rules, atypical behavior; STR/SAR on suspicion.
Crypto/on-chain: Travel Rule-compatibility, analytics providers, wallet policy.

8) Responsible Gaming (RG) and advertising

Player tools: deposit/loss/time limits, timeouts, reality checks, self-exclusion (including national registries).
Behavioral monitoring: risk triggers and intervention protocols.
Advertising/affiliates: age barriers, prohibition of misleading creatives, transparent T&C promos; affiliate contracts with RG/AML responsibilities.

9) Taxation and fees (in general terms)

Base: more often GGR (bets − wins − adjustments of bonuses/jackpots); sales tax/rates occur.
Verticals: Different bets for casino/betting/poker/bingo.
Additional: VAT on services/commissions, regulatory fees, deductions for Responsible Gaming/funds.
Reporting: frequency and form according to the rules of jurisdiction, reconciliations with game logs/payments.

10) Choice of jurisdiction: comparison criteria

Target Markets/Marketing: Can your region/language/payment methods be legally targeted?
Timeline and complexity: review duration, due diligence and audit scope.
Hosting/data requirements: residency, local auditors/laboratories.
Cost of ownership: fees, annual payments, operational requirements.
Reputation and access: PSP/bank recognition, aggregator/studio attitudes, license weight for partners.
Multilicensing: how easy it is to expand into neighboring markets (passporting/local tolerances).

11) Algorithm for obtaining a license (roadmap)

Stage 0 - Pre-preparation

1. Identify markets and verticals → 2) select jurisdiction (s) → 3) conduct gap analysis on requirements.

Phase 1 - Document Package

Corporate documents, ownership structure, CV/references for Key Persons.
Policies (AML/RG/advertising/data/incidents), contracts with providers.
IT architecture, DR/BCP plans, pentest/scan reports.
Financial plan, reserves, confirmation of sources of funds.

Stage 2 - Technical Control and Testing

Game software certification (where required).
Checking hosting/logs/monitoring/relay cycle.
Test scenarios RG/AML/sanctions, synthetic transactions.

Phase 3 - Review and Communication

Responses to regulator requests, policy/process adjustments.
If necessary - Key Persons interviews.

Stage 4 - Receiving and Commissioning

Publishing mandatory information, launching reporting monitoring, setting up relationships with PSP/aggregators.
Periodic Audit and Regulatory Reporting Plan.

12) Compliance Management Model (Operating)

Роли: Head of Compliance, MLRO/AMLO, DPO, RG-Lead, Security Lead, Release/Platform/SRE.
Cycle: requirements registers → policies/procedures → those/operational controls → KPI monitoring → internal audit → improvements.
Evidence-first artifacts: release logs, SBOM/signatures, vulnerability reports, RG/AML logs, DR test reports, laboratory reports.

13) Frequent errors and risks

Incorrect targeting of "gray" markets with a license - the risk of fines/blocking.
Weak control of affiliates and advertising → complaints, sanctions, reputational losses.
Lack of "live" procedures: Policies written but not enforced (no logs/proofs).
Insufficient data protection and logging of access to PII/PAN.
Lack of a plan for software migrations/updates to meet the requirements of the regulator.

14) Vendor management and supply chain

Supplier Dewdiligens (games, PSP, KYC): certificates, SLAs, audit reports.
Contracts with RG/AML/data responsibilities and review rights.
Continuity plan: backup providers, failover scripts, webhooks check (HMAC, idempotency).

15) White-label, skin and own license

White-label/skin: quick start, lower audit/team costs; restrictions of marketing/providers/jurisdictions, dependence on the owner of the "umbrella."

Own B2C license: brand/portfolio/marketing control, better capitalization; higher entry threshold/transaction costs.
B2B license: path for platforms/studios/aggregators; separate requirements for secure SDLC and integrations.

16) Readiness checklists

Definition of Ready

• Target markets and verticals selected; jurisdiction is fit for purpose.
• Key Persons are assigned, roles and responsibilities are defined.
• AML/RG/Ad/Data/Incident policies are designed and maintained.
• IT architecture described: encryption, releases, monitoring, DR/BCP.
• Provider/lab/hosting contracts are ready.
• Finance documents (SoF/SoW/reserves) collected.

Definition of Done (after license issue)

• Included regulatory reporting and RG/AML KPIs; there are those responsible.
• Limits/self-exclusion/sanction screening are set up, logs are kept.
• Confirmed evidence-first artifacts (releases, SBOM, pentests, DR tests).
• Affiliate/advertising control, creative/channel whitelisting.
• Annual/periodic audit and policy review plan.

17) Crucial tree (simplified)

1. Where do you plan to legally sell? → choose the jurisdiction recognized by the target PSP/banks.
2. Need a quick start or control/capitalization? → white-label/skin vs own B2C.
3. Is there internal strength in compliance/infrastructure? → outsourcing of individual functions (DPO/MLRO, SOC) or hiring.
4. Need a multi-market strategy? → design multi-licensing (extension map, local data and advertising requirements).

18) Brief glossary

GGR - gross revenue from the game (bets − wins − adjustments).
RG - Responsible Gaming.
MLRO/AMLO is responsible for AML/finmonitoring.
DPO is a data protection officer.
SoF/SoW - source of funds/condition.
RNG/RTP - random number generator/return to the player.
DR/BCP - Disaster Recovery/Continuity Plan.

Summary

Online casino licensing is not a one-time tick, but an operational discipline: transparent owners, live RG/AML policies, secure infrastructure, trusted vendors, and verifiable artifacts. Choose jurisdiction for target markets and the ecosystem of providers, prepare an "evidence-first" package and build processes like code - this way you will reduce risks, speed up output and strengthen the trust of regulators, partners and players.