How the casino is audited before obtaining a license

Before issuing a license, the regulator (and/or accredited auditors) check not only the "papers," but also how the operator's processes and technologies are arranged: game honesty, data security, payments, player protection and incident preparedness. Below is a practical map of the audit: what they look for, in what order, what artifacts are asked for and what errors are most often found.

General logic of pre-license audit

1. Pre-screen/dossier: ownership structure, beneficiaries, sources of funds, key persons (fit & proper).

2. Technical branch: RNG certification/mathematician and platforms, logs, telemetry, version control.

3. Operating branch: AML/KYC/KYT, Responsible Gaming, payments, advertising/affiliates, support.

4. Security and privacy: information security, access management, incident response plan, DPIA.

5. Finance and reporting: segregation of client funds, accounting for GGR/net, control of conclusions.

6. Interviews and walkthrough: demonstration of processes "live," selective runs of cases.

7. Remediation: elimination of comments, repeated tests, final conclusion.

What they check: by directions

1) Legal due diligence and corporate governance

Transparency of the structure, origin of funds, sanctions/RAP checks.

Purpose of Key Functions: Compliance Officer, MLRO, InfoSec Lead, RG Lead, payment controller.

Politicians: AML/KYC/KYT, RG, information security/privacy, marketing/advertising, risk management, change-management.

Artifacts: organizational structure, register of beneficiaries, CV of key persons, policies and regulations of 1-2 levels, register of risks.

2) Game integrity: RNG, RTP and version control

Certification of RNG and mathematical models of slots/tables/live games.

RTP thresholds/corridors, publication of theoretical returns, fact monitoring.

Release & change management: build hashes, environment control, banning "hot" math edits.

Logging: unchangeable logs of rounds/bets/payments and technical events.

Artifacts: laboratory certificates, a list of games with versions and hashes, math. models, deploy scheme, examples of RTP logs/reports.

3) Platform and reliability

Architecture, redundancy, monitoring, alerts, SLO/SLI.

Load tests, fault tolerance, anti-fraud and anti-bots.

Integration with content providers and payment gateways: test acts, SLA.

Artifacts: architectural diagrams, BCP/DR plan, load test results, list of integrations and acts.

4) Information security and privacy

Access control (RBAC/ABAC), MFA, secret management, administrative activity log.

Vulnerabilities and patch management, penetration tests, static/dynamic analysis.

Data encryption at rest/in transit, data classes, DPIA/PIA.

IR (incident response) procedures: classification, SLA, notifications, post-mortems.

Artifacts: information security policy, pentest results, scanner reports, access matrix, incident log (impersonal).

5) AML/KYC/KYT and payments

Identification procedures, verification of age and personality before withdrawal (often before the game).

Transaction monitoring (KYT): limits, thresholds, escalation scenarios, reporting on suspicious transactions.

Segregation of client funds, register of conclusions, control of chargebacks/returns.

Crypto policy (if applicable): chain analysis, addressable risks, off-ramp.

Artifacts: KYC/EDD playbook, screenshots of procedures, KYT reports, client account registers, contracts with payment providers.

6) Responsible Gaming (RG)

Deposit/rate/time limits, timeouts, self-exclusion (including inter-operator registers, where available).

Behavioral monitoring: harm triggers (deposit acceleration, night sessions, "losing spiral"), intervention scenarios.

Communications: warnings, help section, support training, case documentation.

Artifacts: RG tool screencasts, intervention log (impersonal), RG KPI and training reports.

7) Advertising, bonuses and affiliates

Anti-mislead: prohibition of "guaranteed winnings," clear T & Cs (vager, games contribution, timing, max bet, withdrawal limits).

Age targeting 18 +/21 +; blacklists of sites and look-alike restrictions.

Affiliate control: contracts, pre-approval of creatives, traffic tracking and complaints.

Artifacts: bonus rules, creative catalogs, approvals process, partner register, advertising monitoring reports.

8) Support and dispute resolution

Response SLA, multi-channel, escalation to Ombudsman/ADR (if provided).

RG/AML scripts, claims log, FCR/CSAT/NPS metrics.

Artifacts: support regulations, knowledge base, ticket uploads (impersonal), ADR reports.

What the process looks like: time line "by week"

Weeks − 8... − 4: Pre-audit - gap analysis, artifact collection, version fixing, internal tests, fixes.

Weeks − 3... − 2: Doc-review - auditors request policies/logs/contracts, media demonstration is prepared.

Week − 1: Tech-walkthrough - showing platform, logs, monitoring; selective data extraction.

Week 0: On-site/remote audit - Key Functions interviews, sampling/traceability tests, additional data requests.

Week + 1: Auditor's report - list of nonconformities (MAJOR/MINOR/OBS), recommendations.

Weeks + 2... + 6: Remediation - corrective actions, samples, confirmations; final conclusion.

What exactly will be asked to show: "list at the door"

Logs of rounds/bets/payments (samples, ticket-ID retrievals).

Change-management: applications, approval chains, release notes.

Access matrix and admin activity log.

BCP/DR plans + results of exercises (table-top/technical).

KYT rules and reports on trips/escalations.

Personnel training records (RG/AML/IS) and offsets.

Advertising creatives, T&C bonuses, register of affiliates.

Test cases with which the system is "probed"

RNG/RTP: verification of compliance with the certified version in the sale, reconciliation of the RTP report for the period.

RG: limit setting, exceeding the limit, timeout, self-exclusion → blocking and communication check.

KYC: undocumented onboarding → rejection; re-verification at output; EDD for "high risk."

Payments: deposits/outputs with thresholds → triggering of AML triggers; returns; chargebacks.

IB: attempt to enter without MFA; escalation of rights; reading logs; IR response to "simulated" leakage.

Marketing: selective audit of creatives for mislead/" almost won"; verification of target audiences.

Typical comments and how to close them

Paper compliance: RG/AML tools are on paper, but not in the product → implement in UX, train support, show cases.

Weak change-control: releases without approval/tests → introduce a release matrix, prohibition of "hot-fix mathematics."

Logs without immutability: no hashes/retention → WORM storage/archives, storage policies.

Access holes: general accounts, no MFA → implement SSO/MFA, personal accounts, access revisions.

Non-obvious bonus T&C: hidden limits/fuzzy contribution of games → rewrite the rules, make calculators in UI.

IR/BCP "for show": no exercises, no post-mortems → drizzle calendar, reporting and improvements.

Checklists (save)

Check list of artifacts at the beginning of the audit

Register of beneficiaries and fit & proper.
AML/KYC/KYT, RG, information security/privacy, advertising/affiliates, change-management policies.
RNG/RTP certificates + list of games with versions/hashes.
Architectural diagrams, BCP/DR, penetration test and scanning reports.
Access Matrix, Admin Activity Log, SSO/MFA.
Round/bet/pay logs (samples), RTP reports, GGR reports/taxes.
Support procedures, complaint/ADR registers, SLA/CSAT metrics.
Promotional creatives, T&C bonuses, affiliate registry and approvals.
Personnel training reports (RG/AML/IS).

Checklist of the product itself

Limits/timeouts/self-exclusion work and are reflected in the UI.
KYC/EDD/ECDD are built into the deposit/output flow.
Versioning and disabling "hot" math edits.
Payment SLAs and segregation of funds are respected.
Anti-fraud/anti-bots are active and logged.
Transparent bonus T&C and wagering calculators.
Incident Management: Duty, RACI, Drill, Post Mortems.

How to prepare: 6 tips to get through the first time

1. Make an internal mock audit on checklists with a "red team" of compliance and engineers.

2. Block releases 1-2 weeks before the audit (freeze) and document everything that has already been rolled out.

3. Prepare a demo environment with "battle" logs (impersonal) and traces.

4. Practice Key Functions: short, specific answers, process visit maps, ready-made links/screenshots.

5. Show the culture of IR/BCP: exercise calendar, incident parsing, improvements.

6. Close the "quick victories": MFA/SSO, WORM logs, understandable bonus T&C, vager calculator, visible RG buttons.

What after the audit

You will receive a report with the classification of inconsistencies and recommendations. Make a plan of actions: deadlines, responsible, metrics of success. After remediation - confirm corrections with artifacts (screenshots, policies, logs, test reports) and, if necessary, pass a second random check.

A successful pre-license audit is not to "pass the test," but to prove sustainability: honest mathematics and version control, real RG/AML processes, a secure platform, transparent payments and marketing discipline. If these elements are built into the product and culture, licensing turns from stress to formality - and the trust of players and partners becomes your long-term asset.