Torrent Gear

Role of legal advisors in casino licensing

1) Why you need a legal adviser at all

Licensing is not one form, but a project with legal, technical and operational dependencies. Legal consultant:

translates regulatory requirements into specific policies and processes;
Reduces the risk of returns and delays
helps build compliance proofness (KYC/AML/RG, data, security);
coordinates suppliers (platform, content, PSP, CCM/onchain analytics);
prepares you for interviews and inspections of the regulator and for requests "on signal."

The result is faster to go-live, fewer hidden alterations and an understandable roadmap for further licenses.

2) Consultant roles in licensing phases

Stage 0 - Precoping and Strategy

Map of markets and jurisdictions; product perimeter vs. rules (slots/live/rates/crypto).

Financial model of fees/taxes/audits; assessment of timing and risks.

Platform/RNG/Game Certification Plan; selecting white-label/turn-key/own stack.

Stage 1 - Package Preparation

Collection and legalization of constituent documents, ownership structure, UBO.

Fit & proper questionnaires (directors/beneficiaries), references, recommendations, CV.

Development/update of policies: KYC/AML/sanctions, Responsible Gambling, complaints/ADR, marketing, GDPR/ePrivacy, information security/retention.

Draft contracts with PSP/crypto processing, studios/aggregators, hosting, CCM/online providers.

Legal review of user documents: offer, privacy policy, cookies, bonus rules, 18 + disclosures.

Stage 2 - Feed and Q&A

Electronic application submission, control of checklists, answers and deadlines.

Answers to the regulator's RFI, preparation for interviews, briefings for C-level.

"Repackaging" of materials on comments: editing policies, schemes, contracts.

Phase 3 - Technical Audit and Go-Live

Laboratory coordination (RNG/games/platform), WORM logs, RBAC/MFA, geo-block, marketing filters 18 +.

Check ADR/Ombudsman, SLA support, AML/RG case management.

Final letters to the regulator, launch recommendations and post-licensing reporting.

Stage 4 - maintenance after license

Regular reports/renewals, policy updates and certifications.

Maintaining complex cases (disputes, complaints, incidents, new markets).

Due diligence during M&A, license migration, adding verticals.

3) What exactly does the consultant (deliverables)

Jurisdiction selection matrix with TTA/timing/risks.

Full package of documents and forms; checklist "what to sign and where to assure."

KYC/AML/RG/Marketing/Privacy/Security policies with procedures and letter templates.

Contracts: PSP/crypto, content, hosting, DPA/SLA, affiliates, ADR.

Certification roadmap and evidence list for tech audit.

Interview scripts fit & proper, Q&A bank to the regulator.

Reporting plan and deadlines for the year ahead (taxes, regulator, ADR, audit).

4) RACI and KPI: how to organize work correctly

RACI (example):

Responsible: legal consultant (package, Q&A, contracts), compliance manager (policies in sales).
Accountable: CEO/MLRO/DPO for Data Veracity and Actual Execution.
Consulted: CTO/Head of Product (architecture/integration/logs), CFO (capital/segregation of funds).
Informed: Board/investors.

KPI (example):

Number of returns/before regulator requests per package unit.
Time to conditional approval and to go-live vs. benchmarks.
The percentage of evidence points is closed "the first time."
No criticisms in the technical audit.
Passing marketing moderations (Google/Meta/publishers) without blocks.

5) How to choose a consultant: checklist

Real cases by your jurisdiction and products (B2C/B2B crypto/VASP).
Team: lawyers + ex-regulator/auditor/Sec & Data.
Understanding the technical stack (platform, KYC/AML, onchein screening, ADR).
Out-of-the-box policy and contract templates for your model.
Clear scope, schedule, format of interaction with the regulator.
Professional liability insurance/conflict-check; compliance with anti-corruption standards.
PSP/content provider reviews (how their packages are perceived).

6) Cost and payment models

Fixed fee for package preparation and submission (by jurisdiction/license type).

Time & Materials for Q&A, edits, audit support.

Subscription/retainer for post-licensing, policy updates, new markets.

Success fee - reasonably limited (for stages, not for "obtaining a license at any cost").

Tip: ask estimate TCO: state fees, laboratories, translations/apostille, local agents, escrow, ADR, KYC/AML providers.

7) Typical mistakes without a consultant (and how to avoid them)

Incomplete UBO structure and weak SoW/SoF → tightening or failure.

Policies "on paper" without implementation in the product (RG limits are hidden, there are no logs).

Unaccounted marketing rules (risk-free, lack of 18 +, hidden bonus conditions) → cabinet bans.

Lack of geo-blocking/VPN control and lists of prohibited countries.

Mixing controller/processor roles and no DPA/SLA.

Underestimation of technical audit: no WORM logs, RBAC/MFA, DR/BCP, pentest reports.

8) Practical cases (schematic)

MVP startup (cross-border): the consultant assembled a package for "affordable" jurisdiction, leveled AML/RG policies, achieved pre-approval of creatives from → go-live platforms in 10 weeks.

Crypto-first operator: VASP procedures, Travel Rule, on-chain screening are issued; the requirements for custom are relaxed due to the non-custodial wallet architecture → approval without a second circle.

Migration from white-label to its own license: a plan for transferring data and re-certificates, notifications to players, a "double" reporting period for → regulators without downtime and payment blocks.

9) What stays on your side (even with a consultant)

Truthfulness of information, transparent ownership structure and origin of funds.

Actual policy enforcement (KYC/AML/RG) in product and processes.

Marketing and geo solutions: who you attract, where you show how you disclose bonuses.

Infrastructure security and log quality. Consultant can specify but enable - your dev/sec command.

10) 90 Day Roadmap (example)

0-30 days: choice of jurisdiction and model; KYC/fit & proper collection; drafts of policies; PSP/KYC/content pre-contracts.

30-60 days: package finalization; application; preparation for interviews; start of laboratory certifications.

60-90 days: responses to RFI; technical audit fixes; inclusion of RG/AML cases in the food; preparation of ADRs and marketing guides; reporting plan and SOP.

11) Mini-FAQ

Does the consultant guarantee the license?

No, it isn't. It reduces risks and speeds up the process, but the decision is up to the regulator. Caution with "guarantors for fix."

Can I get by with templates from the Internet?

Risky: without reference to your architecture/geo/suppliers, the regulator will quickly detect inconsistencies.

Need a local lawyer in the country of license?

Often - yes. Optimal: lead consultant + local counsel for assurances and communication with authorities.

How to measure the quality of work?

Look at the KPI from section 4, the number of edits from the regulator, the timing and the absence of critical flags in the audit.

A legal consultant is a licensing orchestrator: he combines legal norms, technical requirements and operational processes into a single project proven for the regulator. A correctly selected and built consultant gives three wins:

1. predictable timing and budget, 2. fewer failures and "alterations," 3. readiness to scale (new markets, verticals, payments).

Invest in expertise at the start - and get a license that works as an asset, not as paper.