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How UK casino licensing works

1) What licenses are there and who needs them

B2C (player operators)

Remote Casino - slots, roulette, card games, live casinos, etc.

(They often take Remote Betting/Bingo together if the product is multi-vertical.)

B2B (Content/Platform Providers)

Remote Gambling Software - development and delivery of gaming software, RNG/client builds, content aggregation.

Host/Supplier with remote infrastructure - if you give operators a platform/servers/vendor services.

Personal licenses

PML (Personal Management License) - for responsible persons: CEO/MD, compliance, MLRO/AML, finance, marketing, IT/InfoSec.

PFL (Personal Functional License) - for individual personnel categories in the ground segment; online PML is more often enough.

💡 white label. Even when using someone else's platform/content, the obligation to comply with LCCP/RTS lies with the B2C licensee.

2) UKGC basic logic

1. Point-of-Consumption: taxes and duties are tied to the player's place (UK market → UK rules).

2. Risk-based approach: the higher the risks (deposit volumes, behavior, traffic channels), the deeper the checks and controls.

3. Continuous supervision: license is not a "sticker," but constant work: reporting, audits, corrections.

3) What is checked when submitting an application

3. 1. Fit & Proper (purity of beneficiaries and management)

Ownership structure, sources of funds, background of directors and PML holders.

Conflict of interest policies, corporate governance, board/committee responsibility.

3. 2. Financial sustainability

Capital/reserves, solvency, holding model, PSP/bank contracts.

Stress scenario plans (BCP/DR), insurance/guarantees.

3. 3. Policies and Procedures

KYC/AML/CTF: identification, PEP/sanctions, SoF/SoW by triggers, transaction monitoring, SAR/STR order.

Responsible Gambling: deposit/time/loss limits, reality checks, self-exclusion (GAMSTOP integration), behavioral triggers (race to lose, bet spikes, night game).

Marketing and affiliates: age filters, prohibition of misleading language, partner management.

Incident management and reporting: roles, SLA, logging, regulator notifications.

3. 4. Technical Architecture (RTS/Security)

RNG/RTP control and certification, release management (change management), unchangeable logs, anti-fraud.

Data protection (encryption, access control, SIEM), log storage, B2B provider control.

Infrastructure reliability: backup, DDoS protection, BCP/DR plans and exercises.

4) Step-by-step licensing process (high-level)

1. Gap-assessment. We compare current policies/technologies with LCCP/RTS, close gaps.

2. Dossier preparation. Beneficiaries, PML candidates, KYC/AML/RG/marketing policies, architecture, PSP/provider contracts.

3. Application. Forms, accompanying documents, payment of fees.

4. Verification and interviews. Clarifying questions on sources of funds, PML roles, procedures, equipment.

5. Technical check. Confirmation of content certification, logging, security, integrations (including GAMSTOP).

6. Solution and conditions. Prescriptions for adjusting processes before/after start-up are possible.

7. Launch and supervision. Regular reporting, external/internal audits, policy updates, incident reports.

💡 Important: the timing and scope of clarifications depend on the complexity of the structure, geography, verticals and history of the beneficiaries.

5) What is mandatory for "online" in the UK

Age/identity confirmed prior to admission to the game.

GAMSTOP: A player who has enabled self-exclusion must not have access; synchronization and fair validation are mandatory.

Honest defaults and transparent UI: prohibition of "dark patterns," clear bonus conditions, understandable probabilities/restrictions.

Reporting and logs: financial/operational reports, log preservation, supervisory access to data.

Affiliate control: verification of partners, a library of approved creatives, a ban on "cloaking" and deceptive landings.

Responsible advertising: age/behavioral filters, risk warnings, no promises of "earnings."

6) Compliance architecture (reference model)

Layer 1 - Player and Payments:

IDV + liveness → RER/sanctions → risk scoring of AML → SoF/SoW triggers → limits/self-exception → SCA/3DS at PSP.

Layer 2 - Data and Safety:

Encryption at rest/transit → RBAC/zero-trust → SIEM + UEBA → DLP → backups/DR (exercises) → vulnerabilities/pen tests.

Layer 3 - Content and Releases:

RNG/RTP certification → version control → unchangeable logs → environment separation → independent validation of builds.

Layer 4 - RG Analytics:

Behavior triggers (betting frequency, spikes, night sessions) → escalation routes → messages/pauses/freezes.

Layer 5 - Marketing & Affiliates:

Partner verification → copyright pre-moderation → white channels → campaign log and "approval trail."

Layer 6 - Reporting and Supervision:

Financial/GGR → SAR/STR → Compliance KPIs → regular external/internal audits.

7) KPI of "live" compliance after obtaining a license

RG Adherence: Proportion of sessions with triggered reality checks/limits.

Affordability/SoF Coverage:% of large deposits with a confirmed source of funds.

False-negative AML: Proportion of missed suspicious transactions (retrospective).

Incident MTTR: the average time from detection to closure of a compliance incident.

Affiliate Clean Share: the share of traffic from trusted partners without violations.

Change Compliance:% of releases certified/validated without returns.

8) Frequent errors of applicants

1. Underestimating the role of PML. A formal appointment without real authority is a signal to the regulator.

2. Weak SoF/SoW procedures. "Actual blindness" to sources of large deposits.

3. Marketing "on the edge." Promises of "fast money," aggressive rate defaults, dark UX patterns.

4. Unmanaged affiliates. Lack of verification and creative logs/traffic sources.

5. Fuzzy logs and releases. No immutable journals, mixed media, no independent validation.

6. No DR/BCP plan. No drill, RTO/RPO not confirmed by metrics.

9) Training Roadmap (90-day template)

Weeks 1-3: LCCP/RTS gap audit, PML assignment, organizational design, AML/RG risk map.

Weeks 4-6: full KYC/AML/RG/Marketing/Incident policies; selection of certification laboratories; contracts with PSP/B2B.

Weeks 7-9: technical controls (logs, SIEM, RBAC, DR exercises), GAMSTOP integration, release procedures and unchangeable logs.

Weeks 10-12: dossier collection, internal IOC audit, application filing, preparation for clarifying questions.

10) The bottom line

Licensing in the UK is about the architecture of trust: player protection, money purity, transparent technique and honest marketing. A strong compliance skeleton not only increases the chances of obtaining a UKGC license, but also improves business metrics: conversion to deposits (through trust), access to top payment providers and LTV sustainability. The "processes first - then paper" approach works best here: when data, logs and product correspond to policies, audit turns from risk to formality.