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The role of compliance departments in iGaming companies
Introduction: why business
In iGaming, compliance is not "insurance," but an operating system. It depends on it: licenses and access to markets, access to payment providers, speed of player onboarding, brand protection and P&L sustainability. A strong department turns regulatory requirements into repeatable processes, "policies as code" and understandable KPIs.
Compliance area of responsibility (what exactly is "theirs")
1. Licensing and Regulatory Relations
Preparation of applications (B2C/B2B), registry support, timely reports and responses to requests.
2. AML/KYC/sanctions/PEP
CDD/EDD, SoF/SoW, transaction monitoring, SAR/STR, rescreening policies.
3. Responsible Gaming (RG)
Limits/self-exclusion/reality check, behavioral triggers, reporting and training.
4. Advertising/Marketing & Affiliates
Verification of creatives, time slots, anti-juvenile rules, partner audits.
5. Payments and payment providers
Due diligence PSP, method whitelists, "return to source," incident procedures.
6. Data protection and privacy
DPIA, storage/access, DSAR responses, secure logs.
7. Internal audits and training
Inspection plan, control of corrective actions, courses for support/marketing/product.
8. Incident Management
From RG/AML anomalies to data breaches and complaints: triage, communications, retrospectives.
Where compliance is "sewn" into the player's funnel
Before registration: geo-filters, age barriers, permissible advertising channels.
Onboarding: KYC, sanctions/PEP, risk scoring, RG primary limits.
Play/deposits: RT transaction monitoring, behavioral alerts, bonus control.
Conclusion: SoF, rescreening, "return to source," SLA/communications.
Support: ADR/Ombudsman, artifact storage, transparent responses.
Function Organization - Structure and Roles
Core-team
Head of Compliance / MLRO (Money Laundering Reporting Officer)- Licensing Lead / Regulatory Affairs
- AML/KYC Lead + Transaction Dimensions
- RG Lead + Behavioral Analytics
- Marketing Compliance Manager (Ads/Affiliates)
- Data Privacy Officer (together with Jurassic and safety)
- Compliance Operations (reports, portals, SLA)
RACI (simplified)
Responsible: Compliance for policies/controls, Product for implementation in product.
Accountable: CCO/MLRO.
Consulted: Legal, Payments, Security, Data.
Informed: Marketing, CS, Finance, BI, Exec.
Processes - Policy to Action
1. Policies as code
Rules (age, timeslots, limits, warning texts, AML thresholds) are stored as configs/rules (JSON/Rego) with country versions.
2. Data marts and e-filing
Automatic reports GGR/RTP/RG/AML, e-signature, acceptance receipts.
3. Alarming and playbooks
"Soft pause" of payments during AML trigger, auto-pause of campaign in case of advertising violation, escalation in Slack/Jira.
4. Audit trails
Immutable event logs (timestamps, signatures), export of artifacts for ADR/regulator.
Interaction with teams (how not to "slow down" the business)
Product: joint prioritization of RG/AML features, test scenarios, "definition of done" with a compliance checklist.
Marketing: pre-moderation of creatives, black lists of markers, provable 18 + target, time slot matrix.
Payments/finance: control white-list PSP, "return to source" rules, monitor of disputed transactions.
CS/support: response macros by KYC/SoF/EDD, SLA, escalation to AML/RG.
Security/IT: access management, encryption, incident response plan.
Tools and stack
CUS/sanctions/REP: multi-provider orchestration, retrai, fallback.
Transaction Monitoring: rule-engine + anomaly-detectors.
RG-SDK: limits/pauses/reality check, integration with self-exclusion registries.
Ad Compliance: CV/OCR lens for disclaimers, library of prohibited attributes, target settings log.
GRC/Case management: incident dossier, SAR/STR templates, control of corrective measures.
Data & Logs: DWH/Lake, crypto signatures, retention control, RBAC accesses.
Metrics (KPI/OKR) for C-level
On-time filing ≥ 99% (regulatory reporting).
KYC TAT (average verification time in minutes).
False Positive Rate on sanctions/AML on target Detection Rate.
RG Coverage (% of players with active limits;% of successful nudes).
Minor Exposure → 0% (<18 reach in ads).
Complaint SLA (median closure of claims).
Audit readiness (time for a full package of artifacts - hours, not weeks).
Maturity model (self-rated 0-3)
0 - Hell handbrake: Excel reports, policies in PDF.
1 - Basic automation: e-filing, partly "policies as code."
2 - Streaming control: RT alerts, multi-provider KYC, RG-SDK.
3 - Compa-by-design: full orchestration, explainable models, integration with registries/platforms, auto-verification of creatives.
Hiring and profiles
MLRO/Head of Compliance: licenses, regs, risk matrices, SAR/STR.
Data compliance analyst: SQL/Python, knowledge of AML/marketing data, features for detectors.
RG specialist: behavioral models, UX communications, working with cases of vulnerability.
Marketing Compliance: platform policies, creative lint, affiliates.
Licensing/Reg Affairs: applications, portals, roadmaps by country.
Privacy/GDPR: DPIA, DSAR, processing contracts.
Budget and ROI (where to spend, what to expect)
Top-3 investments: KYC orchestration, Transaction Monitoring, RG-SDK/Ad-lint.
Economic effect: fewer fines/bans/chargeback, higher approval of payments, cheaper acquiring, more stable LTV.
Intangible: access to premium inventory, loyalty of regulators/banks, fewer PR crises.
Common mistakes and how to avoid them
1. Compliance is connected "last" - before release. → Include it in the sprint plan.
2. One provider for all KYC. → Router providers and fallback.
3. Excel reports and manual logs. → Data marts, immutable logs, e-signatures.
4. Opaque communication with the player (why SoF?). → Templates, statuses, SLA, "voice tone."
5. Identical creatives "for the whole of Europe." → Localization of rules, time slots and disclaimers by country.
6. No post-incident retro. → Retrospective, CAPA plan, measurable effect.
Implementation Roadmap (T-12 → T-0)
T-12...T-9: GAP analysis by market, risk matrix, provider selection, data/log architecture.
T-9...T-6: Policies like code, KYC orchestration, basic transaction monitoring, RG-SDK v1, pre-moderation of ads.
T-6...T-3: Auto e-filing, anomaly-detectors AML/RG, ad-lint, playbooks of incidents.
T-3...T-1: UAT reg scripts, team training, tabletop exercises, setting up KPIs.
T-0: Production, monthly retro, quarterly audit sprints.
Checklists (short)
Before market launch
- License/register, SLA of the regulator, report format.
- AML/KYC/RG/Ads policies as code, localization.
- PSP whitelists, "return to source," documents to banks.
- RG-SDK in applications, integration with self-exclusion registers.
- Creative lint and time slots, affiliate contracts.
Operation day
- All e-filed, alert reports are processed in SLA.
- KYC TAT in the "green zone."
- Zero impressions <18 and self-excluded hits in CRM.
- SAR/STR cases are closed for reg deadlines, logs are signed.
The compliance department is a bridge between law and product. When it works as an engineering function - with data, automation, clear SLAs and metrics - the company gets more markets, sustainable payments, predictable campaigns and regulatory confidence. Make compliance part of the architecture: policies like code, data streams, playbooks and explainable decisions. Then the requirements will turn into a competitive advantage, and not a brake on growth.