6
Distinct load factors
19
Markets served
5
Service lines
100%
Operator-side
02The operating reality
02
What a gaming operator actually carries. Gaming and betting operators sit on one of the heaviest transaction-monitoring loads of any regulated sector: fast, frequent and anonymous at the point of play. The compliance programme has to reverse that.
Every element of that load has to resolve into a defensible decision: monitor, escalate, file or exit. Suspicious-activity reporting is where the whole programme converges, and the financial-intelligence function is where the programme is judged. Regulators treat gaming as high-risk by default. The burden of proof sits with the operator, not the player.
R/01
High-velocity, low-friction flow
Deposits, wagers, cash-outs and withdrawals move in seconds, often in small tickets that aggregate into large positions. Structuring and smurfing hide inside normal play patterns.
R/02
Cash and cash-equivalents at the cage
Land-based casinos handle physical cash, chips, tickets and vouchers. Chip-walking, minimal-play buy-ins and refund abuse are classic laundering typologies an examiner expects you to detect.
R/03
Player onboarding at scale
Thousands of accounts open remotely with weak friction. Identity verification, age checks, sanctions and PEP screening and beneficial-ownership checks on corporate or agent accounts all have to hold up.
R/04
Source of funds and source of wealth
High-roller and VIP play draws scrutiny. When a player deposits sums that do not fit a plausible profile, the operator is expected to have asked, recorded and escalated.
R/05
Sanctions and geo-risk exposure
Cross-border play, payment-service intermediaries, VPN masking and crypto rails pull sanctioned jurisdictions and sanctioned persons into the flow. Screening has to run at onboarding and continuously against live lists.
R/06
Payment-channel complexity
Cards, e-wallets, vouchers, bank transfers and increasingly crypto each carry their own laundering and sanctions risk, and each needs its own monitoring logic.
03The examination surface
What an examiner tests for
When a gaming regulator or its financial-intelligence counterpart inspects, this is what they open. An examiner does not test whether you have a policy. They test whether the programme runs, and whether the records prove it ran.
03.1
Risk assessment. A documented, current business-wide risk assessment that actually reflects your products, channels, player geographies and payment rails, not a template.
03.2
Player due diligence. CDD and EDD that trigger on the right thresholds and risk signals, with age verification, sanctions and PEP screening, and a real record of who was checked and when.
03.3
Source of funds / wealth. Evidence that SoF and SoW were requested, assessed and documented for elevated-risk and high-value players, before play continued.
03.4
Transaction monitoring. Monitoring rules tuned to gaming typologies (structuring, chip-walking, minimal-play, refund abuse, rapid deposit-withdrawal), with alert handling that is timely and evidenced.
03.5
Sanctions screening. Screening at onboarding and on an ongoing basis against current lists, with defensible match-resolution and no silent list-decay.
03.6
SAR/STR pipeline. A financial-intelligence function that escalates, decides and files on time, with the reasoning preserved.
03.7
MLRO and governance. A named, competent MLRO with authority and resource, board-level oversight, and a clear escalation path.
03.8
Training and record-keeping. Staff who can recognise the typologies, and records retained and retrievable to the standard the framework requires.
04The work
Five service lines. We map to whichever the operator needs, and we can run the function, not just design it.
S/01
Licensing and new-regime programme build
We build the compliance that sits behind the application.
Standing up the full AML, sanctions and player due-diligence programme behind a new or pending gaming or betting licence: risk assessment, policies, monitoring logic, screening design, MLRO framework and the evidence pack the regulator inspects. Lawyers file the application. We build the compliance that sits behind it.
S/02
Remediation
The programme after the finding.
Rebuilding a programme after an enforcement action, a regulatory finding or a failed audit: closing the gaps, re-papering the controls, clearing alert and SAR backlogs, and putting the function back on a footing that survives the next inspection.
S/03
Outsourced and bridge MLRO, with a managed FIU function
The programme as a live function.
Acting as your outsourced or bridge MLRO where the framework permits, and running the managed financial-intelligence function: alert triage, escalation, source-of-funds review, and SAR/STR decisioning, senior-only, conflict-free.
S/04
Independent AML audit
The reviewer, not the seller.
The independent review the framework requires, done by the reviewer and not the seller: testing the programme against the current rules and against real examiner expectations, with findings you can act on.
S/05
Sanctions, export-control and integrity due diligence
Screening that holds.
Sanctions and integrity screening across players, agents, payment intermediaries and counterparties, including Travel Rule handling where crypto rails touch the operation.
We sell no software. We take no commission. We are the reviewer, not the seller.
05Coverage
Across all 19 markets
The gaming and gambling sector is served across all 19 markets, on the same operator-side basis. Where a market licenses gaming the supervisor differs, and the programme is built to that supervisor's expectation. Concrete anchors from the verified regulator map:
UAE
The General Commercial Gaming Regulatory Authority (GCGRA), the federal gaming supervisor. Register
Ghana
The Gaming Commission of Ghana (GCG). Register
Kenya
The Betting Control and Licensing Board (BCLB), alongside the Gambling Regulatory Authority. Register
South Africa
Nine Provincial Licensing Authorities (for example the Gauteng Gambling Board and the Western Cape Gambling and Racing Board) under the National Gambling Board, with the Financial Intelligence Centre as the AML supervisor. Register
Kazakhstan
The Committee for Regulation of Gambling Business and Lottery Activities, under the Ministry of Tourism and Sports. Register
Georgia
The Revenue Service, a legal entity of public law under the Ministry of Finance.
Uzbekistan
The National Agency for Prospective Projects (NAPP). Register
Nigeria
State gaming authorities (for example the Lagos State Lotteries and Gaming Authority) and the National Lottery Regulatory Commission.
Egypt
The Ministry of Tourism and Antiquities.
Kyrgyzstan
The Service for Regulation and Supervision of the Financial Market (Finnadzor / Gosfinnadzor). Register
Supervisor names are current per our regulator brief. We confirm the live framework and its requirements at scoping. No deadline is asserted here without a verified source.
Markets / 19
AzerbaijanRESTRICTED
BahrainPROHIBITED
EgyptMOTA
GeorgiaREVENUE SERVICE
GhanaGCG
JordanPROHIBITED
KazakhstanGAMBLING REGULATION COMMITTEE
KenyaBCLB / GRA
KuwaitPROHIBITED
KyrgyzstanFINNADZOR
NigeriaSTATE AUTHORITIES / NLRC
OmanPROHIBITED
PakistanPROHIBITED
QatarPROHIBITED
Saudi ArabiaPROHIBITED
South AfricaPLAs / NGB / FIC
TurkeySTATE MONOPOLY
UAEGCGRA
UzbekistanNAPP
Even coverage. 19 markets. One programme, calibrated per supervisor.
06Honest scope
Where the activity is prohibited or limited
We do not pretend a market is open when it is not. In several of our markets, gambling is prohibited or tightly restricted. Saying no where a market is closed is part of being the reviewer, not the seller.
Prohibited
In Bahrain, Jordan, Kuwait, Oman, Qatar, Saudi Arabia and Pakistan, gambling is prohibited under penal law: an enforcement matter, not a licensed activity. There is no gaming licence to sit behind, and no gaming AML programme to run.
Closed: Azerbaijan
Gambling has been prohibited on the mainland since 1998, with narrow exceptions: the state lottery and sports-betting monopoly, and casinos permitted only on designated Caspian islands under a 2025 law.
Closed: Turkey
Private casinos and unlicensed betting are prohibited, and only state monopoly entities (lottery and state sports betting, supervised by the Ministry of Treasury and Finance) operate.
Where it shifts
Where gaming is closed, the relevant financial-crime exposure usually shifts to the payment, banking and VASP operators that touch gaming flows from elsewhere. That work sits under our other sector programmes.
07Market x sector
The sector page tells you what we build. The market pages tell you who examines it. A handful of the gaming combinations:
08Proof
PartnershipLocal partnersSigned partnership with an AIFC firm licensed by the AFSA. Licensed local legal standing paired with our operator-side build.Partners →
Published workBriefing seriesThe Black Sea briefings, published continuously: a standing series on frontier and Gulf financial-crime regulation.Briefings →
CredentialsCAMS / ICACredentialed practitioners, CAMS and ICA qualified, with front-line KYC and financial-intelligence experience on the team.The firm →
Tell us the operator, the market and the state of the licence.
We come back with a fixed scope and a costed plan within 48 hours. Fixed fee. No hourly billing. Senior-only, operator-side, conflict-free.