How license suspension or revocation works

Short: the difference between "suspension" and "recall"

License suspension is a temporary measure. The regulator restricts or completely blocks activities until violations are eliminated (usually with a clear list of conditions and a deadline).

License revocation is the final decision: the right to work is lost, the brand is obliged to stop accepting bets/games, conduct a "wind-down" (settlements with players, suppliers) and, as a rule, has no right to apply for a new license for N years.

Grounds: why they stop or revoke their license

1. Player protection (RG) - admission of minors, ignoring self-exclusion, no limits, systemic payment delays.

2. Game integrity - undeclared math changes, uncertified RNG/content, anomalous RTP without investigation.

3. Finance and payments - lack of segregation of customer funds, cash gaps, non-payment of winnings.

4. AML/KYC/KYT - systemic failures of onboarding, non-notification of suspicious transactions, sanctions/PEP risks without control.

5. Advertising and affiliates - misleading promises, targeting <18/21, violation of channel bans.

6. Information security/privacy - PII/payment data leak, lack of MFA/logs, concealment of the incident.

7. Reporting/cooperation - false information, non-compliance with the instructions, failure to appear for an audit.

Procedure: as it usually happens

1) Preliminary actions of the regulator

Notice/Letter of Concern: request documents, logs, explanations.

Interim measures: time limits (stop bonuses/new registrations/part of verticals).

Hearing: Key person hearings/interviews

2) Suspension decision

The conditions for recovery are formulated: what to fix, what audits to pass, by what time frame.

The blocking scale is determined: full stop or partial (for example, only live/bonuses/new clients).

Communication is entrusted to players and "ring-fence" client tools.

3) Decision to withdraw

An official notice is published (often - public statement).

A controlled "wind-down" is assigned with reports on settlement reorganization.

External administrator/monitor and mandatory independent audit are possible.

4) Appeals

There is a period for appeal (for example, 14-30 days) and the right to submit new evidence: eliminated violations, compensation to players, audit reports.

For the duration of the appeal, restrictions may remain (including full stop).

What the operator must do in the first 24-72 hours

0-24 hours

Stop accepting bets/games in the amount specified by the regulator; turn off marketing and affiliates.

Preserve logs in WORM storage; release freeze.

Communication to players: banner/letter with clear steps on conclusions and deadlines.

Ring-fence: separate customer funds, fix account balances.

24-48 hours

Launch a payment plan: schedule, channels, FAQ; set up a hotline.

Transfer the primary package to the regulator: incident maps, customer and balance registers, admin log, RTP/jackpot report.

Assign responsible persons (RACI): Compliance, MLRO, InfoSec, Finance, Support.

48-72 hours

External audit/forensics: pentests/log review, confirmation of segregation of funds.

Update public status: timing, progress, how to apply for withdrawal.

Prepare a remediation plan with deadlines and KPIs.

What will happen to players' money and content

Player funds

Must be segregated and available for withdrawal; on recall - full settlement.

The regulator sometimes requires an escrow/trust or "guarantee account" and daily reconciliations.

Jackpots/Bonuses

Jackpot payouts - strictly from pools; on recall - closing pools per protocol (pay/prorated return).

Bonus funds - according to the rules: either complete refusal, or conversion into real ones under the conditions fulfilled; it is important to be honest and transparent.

Content and providers

At the request of the regulator, suppliers can disable games; all changes are recorded in the version logs.

Final reports to providers and aggregators on GGR/royalties are performed.

Impact Matrix: Suspension vs Recall

Parameter	Suspension	Response
Status	Temporary measure	Final decision
Sales/Marketing	Stop/partial stop	Full stop
Players	Withdrawal allowed	Mandatory "wind-down" to zero
Content	Partial/complete shutdown	Total shutdown
Audits	Mandatory independent audit	Audit + remediation report
Return to work	Possible if conditions are met	Not possible (or after re-licensing in N years)

"Return to compliance": how to return after suspension

1. Root cause analysis: those/processes/people/data; post-mortem with facts and deadlines.

2. Corrective Actions: close MAJOR → MINOR, attach evidence (screenshots, test acts, new policies).

3. Independent audit: RNG/RTP, AML/KYC/KYT, IB/privacy, reporting.

4. Pilot and validation: canary period with telemetry to the regulatory hub.

5. Public communication: status for players/partners, compensation plan.

6. The regulator's decision: lifting the suspension or extending the restrictions.

"Wind-down": how to close correctly when recalling

Payment plan: deadlines, channels, period of "silent" accrual of bonuses = 0.

Calculation team: dedicated support line, daily progress report.

Debts to providers/aggregators: close on acts; in case of shortage - coordinate the schedule.

Data: store logs for 5-7 years (or according to the local norm); restrict access, transfer copies to the regulator.

Personnel: legal procedures, dismissals/relocation, knowledge transfer.

Infrastructure: disabling environments, revoking keys/certificates, de-publishing applications.

Check list "for refrigerator"

In case of suspension (Day-0)

Release freeze, WORM log lock
Stop Sales/Marketing/Affiliates
Banner/letter to players + FAQ on conclusions
Ring-fence of balances, reconciliation with banks
RACI assigned and war-room channels open
Primary package to regulator: logs, RTP, funds, admin logs

For the period of remediation

Root Causes and Action Plan with KPIs/Deadlines
External audit and reports (RNG/RTP, AML, IB, reporting)
Corrected policies and staff training
Canary unloading to the regulatory hub
Public Status and Payment Progress Updates

In case of recall

Wind-down plan: schedule, channels, who is responsible for what
Daily reports on payments and balances
Disable content and close jackpot pools
Closing royalties to providers/aggregators
Data archiving and retention, revocation of accesses
Final regulatory report and public statement

Frequent mistakes and their price

Tightening communication with players → a flurry of complaints, increased supervision, additional sanctions.

Lack of ring-fence → mixing of funds, risk of criminal claims.

Hiding an information security incident → increased privacy fines + reputational damage.

Hot edits without auditing during suspension → lock extension.

Delay in remediation → escalation to recall.

Mini-FAQ

Is it possible to accept deposits when suspended?

As a rule, no. Only returns/withdrawals and settlement of ongoing obligations are permitted.

What about active bonuses?

Most often - freezing/cancellation according to a transparent rule; upon withdrawal - termination of accruals, prioritization of real funds withdrawal.

If you eliminate violations in a week, will the regulator immediately lift the suspension?

The solution depends on audit and telemetry; limited restart with monitoring is possible.

Is it possible to "relicense" in another jurisdiction after revocation?

Problematic: Many regulators share information; revoking jurisdiction and partners will be taken into account in due diligence.

Suspension and revocation of a license is not "lightning from the sky," but a consequence of systemic failures in RG/AML, honesty of games, payments, information security or reporting. Sustainable operators design compliance by design: segregation of funds, certified content with version control, unchangeable logs, strict marketing and readiness for audit. Then even the suspension turns into a controlled pause with a quick "return to compliance," and not into the finale of the story.