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Payments Under Scrutiny: Polish Example

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Online gambling continues to thrive in Poland, despite the country’s strict regulatory framework. Virtual casinos and betting platforms still attract players with the promise of easy access and quick winnings. Yet, their operations would not be possible without the involvement of payment institutions that process transactions for entities operating outside the boundaries of the law. Behind the scenes lie not only questions about compliance with Poland’s Gambling Act, but also serious concerns about money laundering and the potential financing of criminal activity.

 

PSPs Legal Responsibility

The key question remains the legality of actions taken by payment institutions that handle transactions linked to illegal online gambling. Do they, even unintentionally, help such operations thrive? Under Polish law, payment service providers are required to monitor and limit high-risk transactions. In practice, this means that every deposit or withdrawal connected to unlicensed gambling activity should be treated as a red flag. Special attention is also given to transactions made through popular mobile payment systems such as BLIK. While BLIK itself is not a payment institution under Polish law, the banks and financial operators using it are and it is they who bear responsibility for preventing the flow of funds that may support illegal gambling activities.

 

Clear Legal Framework, Limited Excuses

Polish law leaves little room for speculation here. The register of domains used to offer illegal gambling, the ban on processing payments for unlicensed operators, and the penalties outlined in the Fiscal Penal Code and Criminal Code set clear boundaries of responsibility.

The Anti-Money Laundering Act (AML) and the EU Regulation 2023/1113 require payment institutions to actively monitor transactions, block suspicious transfers, and cut off risky relationships. Guidance issued by the Polish Financial Supervision Authority (KNF/UKNF) and the National Risk Assessment, along with its sectoral annex, describes typical abuse schemes and makes it clear that payments directed toward online gambling should be treated as a major warning signal. In practice, this means that financial channels supporting illegal gambling must be identified and shut down before the funds return to players as so-called “winnings.”

And this principle is now being actively enforced. Recently, the Financial Supervision Authority (UKNF) went a step further, issuing a sector-wide warning urging payment service providers to block financial flows to unlicensed operators. In response, Polish payment providers have begun withdrawing support for illegal gambling sites and removing payment options such as BLIK from unlicensed platforms.

 

The Hardest to Detect: The Intermediary Role

The flow of funds into illegal online gambling can take many forms, depending on the relationships between the parties involved in the transaction. The most difficult to detect, however, is the scenario in which a payment institution acts only as an intermediary within a larger payment chain transferring money between other financial service providers without directly serving the payer or the recipient. Even in such cases, the institution is not exempt from its obligation to continuously monitor and analyse all transactions.

Depending on the type of payment, it should apply different verification methods, all aimed at determining whether executing a transfer on behalf of another provider could, in practice, end up funding entities that organize illegal online gambling. The institution must obtain information from the ordering provider about the recipient, determine whether it is engaged in gambling related activity, and verify its legal status. If red flags arise during the analysis such as missing data in the payment chain, a domain listed in the official register, or the absence of the website from the list of legal operators the transaction should be paused or rejected and properly escalated. This includes raising the risk level, notifying the relevant authorities, or even terminating cooperation. When dealing with correspondent relationships involving other institutions, including those based within the European Union, heightened caution is essential.

 

Grey Market Fuelled by Inaction

Illegal online gambling would not exist without the support of the payment system. Although the law clearly defines the obligations of financial institutions, in practice it is often these very institutions that knowingly or not enable the flow of money into illegal online gambling. This is why effective identification and blocking of such transactions is crucial, especially within complex payment chains where tracing the connections can be most difficult. Every transfer made in support of illegal online gambling represents not only a legal risk but also real support for the shadow economy that thrives on the lack of vigilance within the financial sector.

This article was supplied by:

Marek Plota

Founding Attorney at RM Legal & Gaming In Poland •

Marek is a founder and a head of the legal team at RM Legal Law Firm and Gaming In Poland, jointly providing multidisciplinary and multijurisdictional support for leading international gambling operators in the Polish, European Union, and African markets. His gambling practice includes regulatory support at the pre and post-licensing stage, IT, and taxation services, as well as the unique service of performing a function of a gambling representative. RM Legal is the only law firm in Poland representing offshore companies operating legally in the Polish gambling market. Apart from gambling Marek specializes in corporate commercial law and international investment projects.

The post Payments Under Scrutiny: Polish Example appeared first on European Gaming Industry News.

Compliance Updates

Spelinspektionen Continues its Work Against Illegal Gambling in the Second Quarter of 2026

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During the second quarter of 2026, the Swedish Gambling Authority continued its work against operators suspected of offering games without a Swedish license.

New regulatory cases were initiated and several operators corrected themselves during the processing, which means that the regulatory cases were closed without further action. This shows how important it is for the Swedish Gambling Authority to identify operators suspected of offering games without a Swedish license at an early stage and initiate supervision against them.

During the quarter, the Authority also worked on an in-depth analysis of marketing for unlicensed gambling. The analysis shows that marketing continues to be a central part of how unlicensed operators reach Swedish players. Therefore, it is important that the Swedish Gambling Authority also takes action against those who promote participation in illegal gambling.

Marketing for unlicensed gambling

Marketing today takes place through several different channels, including social media, influencers, banners, SMS, sponsored search results and other ways to drive traffic to gaming sites. In certain environments, such as gaming and social media platforms, there are particular risks as young players may be exposed to games outside the Swedish licensing system.

However, the majority of marketing for games is still for companies with a Swedish license, especially in established, traditional marketing channels. The Swedish Consumer Agency has the main responsibility for supervising the marketing of licensees, while the Swedish Gambling Authority is responsible for supervising the marketing of unlicensed operators.

“Marketing is one of several ways for consumers to access unlicensed gaming. Therefore, the work against promotion is an important part of our supervision. We see that clear information and early contact can lead to actors correcting themselves,” said Ewa Gabrielsson, investigator at the Swedish Gambling Authority.

The post Spelinspektionen Continues its Work Against Illegal Gambling in the Second Quarter of 2026 appeared first on EE Gaming | Global iGaming & Tech Intelligence Hub.

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Anne Marie Caulfield

Irish Gambling Regulator Threatens Prediction Market with High Court Action

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One of the largest prediction market websites has been threatened with court action if it does not geoblock Ireland, the head of the Irish gambling regulator has said.

Prediction markets are platforms where users can trade bets and gamble cryptocurrency on sports, the financial sector, politics and more, including events relating to the war in the Middle East, the existence of aliens, and tweets posted by Elon Musk.

Anne Marie Caulfield, who has been chief executive of the Gambling Regulatory Authority of Ireland (GRAI) since it began operations last year, said prediction markets amount to betting and therefore fall under her remit.

She said the GRAI enforcement team has already been active in the space, with one of the largest such markets already geoblocking on foot of “intervention” from the authority.

Speaking on RTÉ’s This Week radio programme, Ms Caulfield said a second “is in the process of doing so”.

She added: “And if they don’t, it’s open to us to go to the High Court.”

She said sites were withdrawn in Ireland in the “vast majority” of the almost 30 interventions the GRAI had made.

She added that this had happened as quickly as 35 minutes after the intervention.

Asked what the High Court action may look like, Ms Caulfield said: “In the instance where they don’t do so, we can go to the High Court and get a blocking order for access to the site, and also in relation to the funding involved.”

Pressed on whether that action had been threatened, she said: “We have issued warning letters, yes, to that effect.”

Ms Caulfield did not name the prediction markets involved.

However, users from Ireland are already prohibited from trading “event contracts” on the prediction market Kalshi, as per its membership agreement which also lists 55 other restricted countries.

One of the other main prediction markets, Polymarket, has seen restrictions in more than 30 countries including Belgium, Germany, Italy, France, the UK, and Poland – while it operates in the US with additional compliance measures.

In May, Tánaiste and Finance Minister Simon Harris said he would ask gardaí, regulators and government departments to examine “suspicious bets” made on Polymarket.

He raised “grave concerns” around a “Wild West” of unregulated betting on the platform, as he said it would be prudent to examine if there was money laundering occurring.

His comments came after reports highlighted a million dollars worth of betting on the outcome of the Dublin Central by-election, with hundreds of thousands of that volume placed on Gerry “The Monk” Hutch not to win a seat – which is what transpired.

There is no suggestion of wrongdoing on behalf of any candidate.

Mr Harris said: “What seems to be developing at a global scale and indeed a rapid pace now is a kind of Wild West where people are placing bets in the form of cryptocurrency in a secretive, murky and unregulated manner.”

The post Irish Gambling Regulator Threatens Prediction Market with High Court Action appeared first on EE Gaming | Global iGaming & Tech Intelligence Hub.

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Compliance Updates

The MGA Publishes Notice on Websites Impersonating Licensed Operators

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The Malta Gaming Authority (MGA) has observed a pattern of websites impersonating MGA-licensed operators and misleading consumers into believing that they are licensed, regulated or otherwise authorised by the Authority in accordance with the Gaming Act (Chapter 583 of the Laws of Malta) and the regulatory instruments issued thereunder.

In light of this, the MGA published a list of three websites impersonating licensed operators. The websites are:

• www.manekicasino.bet

• www.dragonaracasino.uk.com

• www.slot-hunter.at

“The MGA is hereby declaring that it has no connection with the above listed URLs and any other website, platform and/or entity impersonating the Authority and/or MGA-licensed operators. Any reference to the MGA and/or gaming licence/s said to be issued by it, as stated on these domains, are false and misleading,” the MGA noted.

“The MGA would like to remind consumers not to utilise services provided by an entity unless they have ascertained that the entity in question is duly authorised to provide such services by the Authority. Whereas MGA-licensed operators comply with strict legal requirements in the interest of consumers, the activities of unlicensed entities are unregulated, and do not provide the necessary safeguards delineated by virtue of the gaming regulatory framework, making transactions with such entities risky for consumers.”

The post The MGA Publishes Notice on Websites Impersonating Licensed Operators appeared first on EE Gaming | Global iGaming & Tech Intelligence Hub.

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