Crypto Casino
Torrent Gear
How crypto casinos and blockchain platforms are licensed
- Gambling is licensed as gambling and crypto is licensed as financial services (VASP/virtual asset provider). In most jurisdictions, you need two compliance trajectories: gambling license + VASP registration/authorization (or equivalent).
Basic licensing models
1) "Two Caps": Gambling + VASP
Gambling license for B2C (operator) and/or B2B (platform/supplier).
VASP/crypto-registration for virtual asset turnover: deposit acceptance, conversion, wallets, merchant acquiring in crypto.
Realities: the same regulator rarely closes both directions; double reporting will be required.
2) "Gambling license with crypto persuasion"
The gambling regulator allows crypto payments when fulfilling AML/sanction and custody requirements, sometimes without a separate VASP status (if the crypt passes through a licensed PSP/acquirer).
Realities: easier to start, but dependent on external VASP/PSP.
3) Sandboxes and pilots
Special modes for innovation: limited player pool, turnover limits, enhanced monitoring, product iteration reports.
Realities: Fast MVP, but commercial scope limited.
What regulators check (must-have checklist)
A) AML/KYC and sanction filtering
KYC: customer identification (ID + Liveness), address (PoA), at risk - Source of Funds/Wealth.
Chain analytics by address: sanctions/mixers/hacks/" high-risk" tags.
Travel Rule: transfer of KYC data between VASPs for transfers above thresholds.
Non-residents and prohibited countries: geo-blocking, lists of RAP/sanctions.
B) Custody
Hot/warm/cold wallet policy, multi-signatures, output limits, drain-tx schedule.
Separation of client tools and operating (segregation), monthly reconciliation.
Incident-response procedures: keys, rotations, hacks, notifications.
C) Technical safety and audit
Smart-contract audit (if there is on-chain logic: tokens, jackpot pools, "provably fair").
External RNG/game engine certification, RTP manipulation protection.
Event logs with hashing and storage for dispute forensics.
D) Responsible Gaming (RG)
Self-exclusion, deposit/rate/time limits, cool-off, reality check.
Age verification and prohibition of vulnerable groups.
Fair marketing policies (no "guaranteed wins").
E) Advertising and Communications
Transparent T&C bonuses: vager, contribution of games, timing, cap to win.
Affiliate control (joint responsibility for compliance).
Jurisdictional "portraits" (landmark)
Malta (MGA): Mature gambling licence (B2C/B2B), crypto payments allowed when performing AMLs and collaborating with licensed VASP/PSPs. For tokenomics/utility - additional requirements of financial supervision.
Isle of Man/Alderney/Gibraltar: a guide to iGaming and fintech; crypto is possible through clear AML procedures, custody audit and risk assessment of providers.
Curaçao (new licensing model): transition to individual operator/supplier licenses and tightening due diligence; crypt is possible with compliance with AML and payment rules.
Baltic States (Estonia/Lithuania): high bar for VASP modes, chain analytics and reporting; for iGaming - separate permissions/licenses, crypto reception more often through VASP partners.
UK: Gambling licence requires strict AML and sources of funds; crypto payments as "high risk" - only through "white" providers and with additional checks.
EU as a whole (MiCA): unification of rules for crypto assets and service providers; token programs and stablecoins fall under separate frameworks.
Asia selectively (for example, the Philippines for offshore iGaming): models with crypto acceptance through approved payment providers and increased supervision of AML are possible.
"Provably fair," tokens and on-chain mechanics
Provably fair
Hash-commit-revil, public sides, player verification.
Requirement: independent validation and storage of logs; detailed description of the method in T & C.
Tokens/utility/loyalty
Utility tokens are often viewed as a loyalty program in the absence of security features.
If there are signs of a security/payment instrument, financial licenses and prospectus modes are connected.
Listings/ICO/IEO - only within applicable rules (whitepaper ≠ immunity).
Jackpots/pools on smart contracts
Code audit, upgrade rights (Proxy?), Pause-switch, MEV/frontal wound protection.
A clear "fork" of legal responsibility: who owns the keys, who is the operator of the contract.
Payments and conversion (on/off-ramp)
On-ramp: buying crypt for fiat; preference to licensed providers with KYC and limits.
Off-ramp: output of winnings to fiat; sanctions/high-risk countries - automatic blocks.
Stablecoins: additional due diligence of the issuer; individual restrictions in a number of countries.
PSP chains: document the route of money "from and to" (banking file), keep evidence of the purity of sources.
Compliance organization (practice)
Policies and Procedures:- AML program (CDD/EDD, triggers, screening, alert chains, SAR/STR reports).
- Travel Rule playbook: provider, thresholds, exclusions, SLAs, tests.
- Custody SOP: limits, roles, 4-eye, emergency access, accident tests.
- RG policies and support training.
- Incident response on cybersecurity and smart contract vulnerabilities.
- Chain analytics (screening of incoming/outgoing addresses).
- KYC orchestration (including liveness and document fraud).
- Logging on-chain/off-chain events with unchanging hash traces.
- Internal "risk limits" on withdrawal/deposits (account-level + session-level).
Common mistakes and how to avoid them
1. "Only a gambling licence - and enough is enough." No, it isn't. If you touch crypt, see VASP/Finnadzor and Travel Rule.
2. Custody "on the knee." Without multi-signature procedures, limits and accidents, this is a red flag for the regulator and banks.
3. No audit of smart contracts. Any on-chain product without audit and bug-bounty is a license and reputation risk.
4. Geo-mix of illegal markets. Cross-border targeting without geo-compliance and sanction filters = risk of blockages and penalties.
5. Foggy tokenomics. Opaque utility/security boundaries lead to claims of financial regulators.
6. No ADR/spore circuit. The licensed operator must have channels for escalating complaints and store logs.
Launch Roadmap (T-12 → T-0)
T-12...T-9: choice of jurisdiction and model (two caps or "via PSP-VASP"), preliminary GAP analysis, consultations.
T-9...T-6: preparation of AML/KYC/Travel Rule policies, custody design, choice of chain analytics, draft T & C/bonus policy.
T-6...T-3: submission for a gambling license and VASP/registration, start of RNG audits/smart contracts, PSP/on-off-ramp integration.
T-3...T-1: UAT compliance, sandbox pilot (if available), tabletop incident drills, reporting.
T-0: go-live with phased geo-disclosure, limits, strict monitoring and compliance KPI reports.
Short investor memo
Look not only at the "tax rate," but also at the clarity of the VASP regime, access to banks/PSP and the regulator's crypto practice.
Check the history of edits and the presence of "sandboxes" - this reduces the risk premium of the project.
Evaluate the sewers (legal payments, white providers, ADR, RG) - there are higher LTV and lower penalty tails.
Crypto casino licensing is a double circuit: gambling license + virtual asset mode. A successful launch requires strict AML/KYC, transparent custody, auditing of smart contracts and discipline in advertising and RG. In exchange, you get access to payment infrastructure, regulator confidence and predictable scale - exactly what turns the blockchain experiment into a sustainable iGaming business.