Payment Providers and Banks in Poland: Obligations to Block Illegal Gambling Transactions

Poland’s enforcement of its gambling laws relies heavily on the financial system. Since 2017, payment service providers have been legally required to cut off money flows to unlicensed gambling sites, making them front-line enforcers alongside internet providers. This guide explains the obligations, the penalties and the practical consequences for payment institutions and operators.

The statutory obligation

Under the Gambling Act, a payment service provider may not provide payment services on a website using a domain entered in the register of prohibited domains. The obligation attaches from the moment of entry, and the register is published online, so providers are expected to monitor it and implement blocking within a short window. The obligation covers domestic and foreign providers offering services to Polish users.

What blocking means in practice

Providers must refuse to execute payments to and from listed domains and to merchants identified as operating them. This requires linking merchant records to domains, monitoring new register entries and screening transactions, which is technically demanding for acquirers, e-money institutions and wallets that serve international gambling merchants. Card schemes’ own rules on gambling merchant category codes and cross-border acquiring add a further layer.

Penalties

A provider that breaches the prohibition faces an administrative penalty imposed by the customs and tax administration, calculated as a multiple of the value of the payment services provided, and individuals responsible may face fiscal-penal liability for facilitating illegal gambling. Reputational and licensing consequences with the Polish Financial Supervision Authority can follow.

Overlap with AML obligations

Payment providers are obliged institutions under Polish AML law. Transactions connected with illegal gambling are a recognised money-laundering risk, and providers are expected to identify gambling merchants, assess their licensing status and report suspicious activity. Gambling merchants without appropriate licences for the markets they serve are, from an AML perspective, high-risk customers requiring enhanced measures or offboarding.

Consequences for licensed operators

Licensed Polish bookmakers benefit from payment blocking against offshore competitors, but they also need to ensure their own domains and merchant records are clean and that their payment partners understand their licensed status. Operators licensed in other EU states that do not target Poland should confirm their domains are not listed and maintain geo-blocking evidence for their providers.

Practical steps for providers

Implement automated monitoring of the register, maintain a gambling merchant inventory with licence verification, apply enhanced due diligence to gambling clients, and document the blocking process for inspection.

Our compliance and AML practice advises payment institutions and operators on gambling-related obligations under Polish law.