Regulatory structure of the iGaming industry

1) Picture of the world: regulatory models

State monopoly - the right to conduct gambling belongs to the state/lottery operator; online may be limited. Pros: harm control, predictable fiscal returns. Cons: limited competition, weak innovativeness.
Open competitive market - licensing of private operators with strict standards (responsible play, AML, data protection). Pros: competition, choice for the player, innovation. Cons: difficulty of supervision, risk of aggressive marketing.
Hybrid model - monopoly on individual verticals (for example, lotteries) + private betting/casino licenses; regional permits and cross-licensing.

2) Hierarchy of regulatory subjects

Legislator - determines the basic principles (admissibility of online games, tax base, responsibility).
Regulator/supervisory authority - issues licenses, conducts inspections, establishes technical standards, maintains registers of prohibited domains/operators.
Financial intelligence (FIU) - control of AML/CTF, reporting on suspicious transactions.
Ombudsman/consumer protection authority - dispute resolution, returns, mediation.
Data regulator (DPA) - compliance with GDPR/local data laws.

3) Licensing: types and perimeter

3. 1 License categories

B2C (operator): casino, betting, live studios, poker, bingo, virtual sports.
B2B (provider): content studios, aggregators, platforms, PSP, KYC/AML providers.
Vendor/personal: Key Persons, certification of sites and equipment (for ground/studios).

3. 2 Key elements of the application

Source of Funds/Wealth.
Policies and procedures (AML, RG, advertising, data protection, incidents).
Technical architecture and hosting (geolocation, logging, DR/BCP).
Agreements with providers (games, PSP, KYC) and SLA.
Financial guarantees/provisions, insurance, payment security.

3. 3 License maintenance

Periodic reporting (finance, RG metrics, complaints, incidents).
Changes in control/structure - preliminary approval of the regulator.
Annual/periodic audits: financial, information security/those, compliance with standards.

4) Responsible Gambling (RG)

Player tools: deposit/loss/time limits, reality checks, timeouts, self-exclusion (local and national registries).
Behavior monitoring: triggers of harmful patterns, proactive communication, "soft" and "hard" interventions.
Advertising restrictions: 18 +/21 + target, prohibition of images aimed at minors, frequency limits, risk designation.
Personnel training: identification of signs of dependence, escalation of cases.
RG reporting: KPIs of compliance with limits, share of self-exclusions, effectiveness of interventions.

5) AML/CTF and sanctions compliance

Risk-Based Approach: Risk Assessment Policy by Geo/Payment Method/Customer Type.
KYC/CDD/EDD: verification of identity, address, age; In-depth inspection of RAP/sanctions lists.
Transactional monitoring: thresholds, velocity rules, atypical patterns, locks and SAR/STR messages.
Travel Rule/online analytics (for crypto): checking sources, wallet providers, monitoring mixing services.
Provider management: KYC/AML vendor audits, decision logs, match quality testing.

6) Data protection and privacy

GDPR/local analogues: legality of processing, minimization, storage "as intended," DPIA for high-risk operations.
Data subject rights: access, correction, erasure, portability; response time and verification process.
Security: encryption at rest/in transit, PAN/PII tokenization, access control, logging.
Data Residency: storage and processing within the required jurisdictions.
Incidents: Response plan and notification to regulator/users on time.

7) Advertising, affiliates and promo

Transparency rules: T&C offers, wagering, limits, time windows and geo-targeting.
Affiliates: contracts with RG/AML/advertising responsibilities; audit of creatives; channel "stop-list" tool.
Self-Exclusion Respect: Prohibits the retargeting of excluded players.
Influencers/streams: advertising labeling, time and audience restrictions, prohibition of misleading statements.

8) Technical standards and certification

Random number generators (RNGs) and RTPs are independent laboratories.
Integrations and hosting: penetration tests, vulnerabilities, patch policy, end-to-end logging and tracing.
Release lifecycle: staging pipelines, version fixing, SBOM, artifact signing, change control.
Observability: SLO metrics, synthetic deposit/CCL/withdrawal checks, storage of logs for audit.
DR/BCP: RTO/RPO targets, regular restore tests.

9) Taxation and fiscal reporting

Tax base: most often GGR (bets - wins - bonus adjustments); sales tax/rates are encountered.
Division by vertical: bets, casino, poker, bingo - different tax rates.
Localization of payments: VAT on commission/services, taxes on marketing and advertising, fees to regulators.
Reporting: frequency (month/quarter), product details, bonus/jackpot adjustment log.

10) Supervision and enforcement action

Regulator tools: fines, suspension/revocation of a license, blocking of domains/IP/payment channels, public warnings.
Audit triggers: consumer complaints, ad limit overruns, RG/data incidents, late reporting.
Voluntary agreements/remediation plans: reduced penalties with rapid remediation and demonstrable process improvement.

11) Borderline/grey markets and cross-jurisdictions

The principle of "active targeting": the presence of local marketing/payment methods/localization can be interpreted as market activity.
Risks: block lists, fines, blacklists of the license holder in other countries, complication of banking/PSP relations.
Risk mitigation: geo-blockages, exclusion of local PSPs, rejection of local advertising, clear T & Cs about inaccessible markets.

12) Ethical standards and ESG

Transparency: clear odds of winning, honest mechanics of bonuses, lack of "dark patterns."

Protection of vulnerable groups: age verification, restrictions on frequency and amounts, access to assistance resources.
ESG reporting: contribution to local communities/sports, Responsible Gaming programs, environmental footprint of infrastructure.

13) RegTech/LegalTech: How to Automate Compliance

KYC/AML stack: verification providers, sanction screeners, behavioral models, velocity rules.
Policy-as-Code: encryption, network policies, disabling unsigned images, access control - as code.
Evidence-first: automatic collection of audit artifacts (release logs, SBOM, vulnerability reports, RG metrics).

Market Requirements Catalog - Jurisdiction → Rules → Owner → Update Date Matrix

14) Operational compliance model (for operator)

• Head of Compliance - policy owner, contact with regulators.
• MLRO/AMLO - financial monitoring, STR/SAR, personnel training.
• DPO - privacy, DPIA, responses to data subjects.
• Responsible Gaming Lead - RG tools, reporting and training.
• Security/Platform/SRE - technical controls, logs, incidents, DR.

1. Requirements and Risk Registers → 2) Policies/Procedures → 3) Controls (Technical/Operational) → 4) KPI Monitoring/Artifacts → 5) Internal Audit/Retro → 6) Improvements.

15) Artifacts and checklists for readiness

• RG/AML/CTF policies, advertising/affiliates, data protection, information security, incidents, DR/BCP.
• Descriptions of architecture, hosting locations and data lineage.
• Registers: sanctions, self-exclusions, complaints, security incidents.
• Contracts and SLAs with providers (PSP/KYC/content), laboratory reports, pentest protocols.
• Financial reports (GGR, tax base), bonus/adjusted win logs.

• Age/geo-locks and deposit limits are included and tested.
• CCM/PEP/sanctions - onboarding and periodically (re-KYC/trigger-based).
• Webhooks PSP/KYC - subscribed (HMAC), idempotent, there are DLQs.
• OTel metrics and the RG/AML event log are saved with the desired retention.
• SBOM/image signatures, "enforce" admission policies, DR tests conducted.

16) External Audit Process (Outline)

1. Gap analysis: reconciliation of jurisdiction requirements with current policies/controls.
2. Remediation plan: timing, responsibilities, risks.
3. Preparation of evidence: sampling logs/reports, screenshots, test protocols.
4. Interviews and demonstrations: showing RG/AML/KYC contours, release pipelines, DR exercises.
5. Report and improvements: closing comments, updating registers and procedures.

17) Fast "starter" checklist for new market

• Jurisdiction allows online gaming in target verticals.
• License holder, owners, Key Persons defined; assembled KYC/SoW/SoF.
• Selected license type (B2C/B2B/both), prepared package of documents.
• RG/AML/Ad/Data policies are formed; DPO/MLRO assigned.
• Hosting and data streams meet residency requirements.
• Tax model and reporting (GGR/turnover, vertical rates) are clear and automated.
• Contracted with certified PSP/KYC/laboratories; SLAs and reports are defined.
• Geo-locks and prohibited area/method catalogs are included.
• Audit artifacts and KPI monitoring (RG, AML, complaints, incidents) are configured.
• The plan of incidents and communications with the regulator is approved.

Summary

The regulatory structure of iGaming is not "paper for paper's sake," but a system of interconnected rules: licenses and taxes, player and data protection, AML/sanctions, advertising and technical standards. Successful operators turn requirements into processes and code: measurable RG metrics, automated KYC/AML controls, transparent release cycle, observability, and audit artifacts. This approach reduces risks, accelerates market entry and builds sustained confidence among players and regulators.