Payment Providers and Crypto On-Ramps in Gambling: When the PSP Needs a Licence Too

Payment companies serving the gambling sector sit at the intersection of two regulatory regimes: financial services regulation, which governs the payment activity itself, and gambling regulation, which increasingly reaches suppliers. Crypto on-ramps add a third layer. This guide explains when a payment provider needs which licence and where the exposure lies.

Financial services authorisation

Any company that executes payment transactions, issues e-money or provides acquiring services for gambling merchants in the EU needs authorisation as a payment institution or electronic money institution under PSD2 and the e-money framework, or must operate as an agent of an authorised institution. Unlicensed collection of player funds by a gambling intermediary is a payment services breach independent of gambling law.

Crypto-asset service providers

Providers that exchange crypto for fiat, custody players’ crypto or operate on-ramps for gambling operators must be authorised as crypto-asset service providers under MiCA when serving EU customers, with transitional periods that have now largely ended. MiCA brings capital, governance, AML and travel-rule obligations, and gambling operators integrating crypto payments should verify their provider’s MiCA status.

Gambling-specific supplier licences

Some gambling regulators require payment providers to hold a gambling-sector licence or registration. Romania’s Class 2 licence explicitly covers payment processors serving licensed operators. Brazil requires payments to flow through Brazilian-authorised institutions. Ontario registers certain payment providers as gaming-related suppliers. Malta and the UK do not license PSPs as such but scrutinise the operator’s payment arrangements, and the MGA requires disclosure of payment providers.

AML obligations

Payment institutions are obliged entities under AML law and must apply enhanced due diligence to gambling merchants, verify their licensing in each market served, monitor transactions and report suspicions. Processing payments for an operator that is unlicensed in a market is a recognised AML and regulatory risk, and several markets, including Poland and the Netherlands, impose specific obligations to block payments to blacklisted operators.

Card-scheme rules

Card networks classify gambling under specific merchant category codes, require registration of gambling merchants for cross-border acquiring, impose fines for miscoding and prohibit processing for unlicensed gambling in markets where it is illegal. Acquirers pass these obligations to merchants and PSPs contractually.

Practical implications

PSPs should maintain a gambling merchant policy covering licence verification per market, geo-blocking evidence, MCC compliance and ongoing monitoring. Operators should confirm their PSPs’ authorisations and understand which party carries which obligation in each market.

Our compliance and AML practice advises payment and crypto providers on serving the gambling sector, and operators on payment-provider due diligence.