Interview with a license lawyer

A license is not a "tick paper," but a company's lifestyle: corporate governance, risk policy, player protection, transparent financial flows and technical discipline. We talked to a practicing gambling lawyer (a generalized interview) about what regulators really check and how not to drown in requirements.

1) How the path to the license begins

Question: Where does the project start - with jurisdiction or with documents?

Lawyer: From goals and geography. Define markets (EU/UK/LatAm/Africa/US states), business model (B2C/B2B/white-label/turn-key) and process maturity. Then we make a gap analysis for the selected modes (MGA, UKGC, Curacao/CGA, Colorado/New Jersey, etc.). Already after - corporate assembly: ownership structure, directors, key functions (AML, RG, compliance, CISO/IB), banking relations.

2) Fit & Proper: Who are you for the regulator

Q: What do beneficiaries and directors look at?

Lawyer: Reputation, sources of funds (SoF/SoW), lack of convictions and sanctions, relevant experience, transparent ownership structure (without "black boxes"), real control of the board of directors. Plus - politically significant persons (PEP), conflict of interest, tax integrity.

3) A set of policies without which the application will not be accepted

Q: What are the "reference" documents?

Lawyer:

AML/CFT + KYC/EDD/PEP/sanctions, SoF/SoW triggers, transaction monitoring.
Responsible Gambling (RG): deposit/loss/time limits, timeouts, self-exclusion, reality checks, intervention ladder, harm metrics.
InfoBase/IB: access management, admin log, KMS/secret rotation, incidents.
Incident Management and BCP/DRP, Change Log, RTO/RPO.
Outsourcing and critical vendors, audit rights and SLAs.
Advertising and affiliates, age marking, offer rules and stop list.
Complaints and ADR/mediation, timing and channels.
Data protection (GDPR/local), DPIA/rights of subjects, data retention.

4) Technical standards and audits

Question: What usually breaks applications for "technology"?

Lawyer: Lack of holistic logs (bets/wins/balances/limits/access), weak versioning and release scheme, no separation of environments, unobvious reporting on RTP/game mathematics, unformed integrations with providers. A number of jurisdictions require approved test labs, ISO-like practices, and readiness for data center/cloud inspections.

5) AML/KYC and finmonitoring

Q. What is considered a "minimum sufficient" AML loop?

Lawyer: Risk stratification of clients, EDD triggers (amounts, night horizons, behavioral anomalies), SoF/SoW for high-risk, sanction/PEP screening with revalidation, transaction monitoring (velocity, geo, methods), decision and escalation log, front line training, independent selective reviews.

6) RG and design ethics

Q: Where do lawyers interfere with the product?

Lawyer: In places where UX can cause harm: aggressive timers, darkened bonus conditions, autospins without restrictions, promo for RG signals. We require clear conditions in 2-3 lines, available limits and quick self-exclusion, as well as "friction with purpose" at the checkout at risk.

7) Advertising, affiliates and creatives

Question: Why so many sanctions for marketing?

Lawyer: Because the operator is responsible for the promises of partners. We need a register of affiliates, pre-moderation of creatives, geo and age filters, a ban on misleading offers, a traffic audit log and a "quick stop" procedure. In UK/EC, there are strict rules for advertising formulations and triggers.

8) Payments, stablecoins and Travel Rule

Question: Are crypto payments realistic?

Lawyer: Yes, if allowed locally and built into the AML frame: it/off-ramp with licensed providers, risk scoring of addresses, sanctions lists, fresh wallet policy, transparent ETA/commissions. For "custodial" translations - compliance with the Travel Rule. RG policies are the same for all methods.

9) White-label, turn-key and distribution of responsibilities

Q: Where are the boundaries of responsibility between platform and brand?

Lawyer: By contract and law, the operator/licensee is always extreme. White-label can share responsibilities, but the regulator is interested in actual control: who manages risks, who keeps magazines, who pays taxes and reports GGR. In the contract - SLA, audit rights, RACI matrix, incident plan.

10) US and "patchwork" states

Q: How do states differ from EC/UK?

Lawyer: Each state has its own regulator and its own procedures, but everywhere - strict background check, local partnerships (casino skins), technical "perimeters" (geolocation, payment gateways), reporting and taxes. Timelines are longer, capital and personnel requirements are higher.

11) Timelines: what is real in terms of time

Question: How long does it take to complete?

Lawyer: Depends on readiness. On average: 8-20 weeks for assembly and "dry audit," then 2-6 months for consideration (faster in transitional modes, longer - with a complex structure or staff licensing). Critical: come with applied, not "shelf" documents.

12) Frequent errors of applicants

Question: What most often breaks cases?

Lawyer:

1. Policies without connection to a real operating system.

2. Weak tracing of SoF/SoW and fin flows.

3. No RG metrics, promo and RG signal conflict.

4. Lack of audit rights and SLAs with critical suppliers.

5. Unstable logs, no control of releases/accesses.

6. "Grey" advertising and unruly affiliates.

7. Underestimation of Data Protection (GDPR, local responsibilities).

13) Contracts that save in crisis

Question: What are the must-have provisions?

Lawyer:

SLA and penalties, RTO/RPO, incident notification.
Audit rights (on-site/remote), log access, telemetry export.
Compliance-clause: license compliance, prohibition of non-consensual suboutsourcing.
Data Processing Agreement (GDPR), storage locations, and sub-processors.
Change in control/termination at regulatory risks.
IP/matrix of responsibility for the mathematics of games, RTP reports, test labs.

14) Life after license: continuous compliance

Question: How not to "crumble" in six months?

Lawyer: Introduce compliance calendar: internal audits (quarter), policy updates, front line training, BCP/DRP tests, review of affiliates and creatives, incident retrospectives, GGR reporting, RG/AML-KPI monitoring, infrastructure change register. Communications with the regulator are proactive.

15) 90-Day License Preparation Roadmap

Weeks 1-3 - Diagnostics

Gap analysis for the selected jurisdiction.

Role map/key functions, ownership structure.

Draft copies politician of AML/RG/IB/аутсорсинг/реклама/жалобы.

Weeks 4-6 - Architecture and Contracts

Infrastructure charts, logs/retentions, releases, accesses.

Templates for contracts with providers: SLA, audit, DPA.

Registers: affiliates, incidents, complaints, releases.

Weeks 7-9 - Pilot and Training

AML/RG Pilot Monitoring, Decision Log.

Front/marketing/engineer training.

"Dry" technical audit and recording of comments.

Weeks 10-12 - Filing and Maintenance

Package finalization, submission, responses to regulator requests.

Post-launch inspection and reporting plan.

16) Applicant's checklist (B2C/B2B)

Transparent ownership structure, director/key function profiles.
AML/CFT/KYC/SoF/SoW, RG, IB policies, incidents, outsourcing, advertising/affiliates, complaints/ADRs, GDPR/DPA.
Architecture diagrams, logs and retention, releases/versioning, RBAC, KMS/secrets, BCP/DRP.
Provider contracts: SLAs, audit rights, DPAs, compliance obligations.
Registries: affiliates, incidents, complaints, releases; training plan.
Metrics showcases: AML/RG-KPI, SLO critical flow, GGR reporting.
Communication plan with regulator and contact lists 24/7.

17) Mini-FAQ from a lawyer

Is it possible to start on white-label and then switch to your own license? Yes I did. Put in the contract data/log migration, reporting compatibility and audit rights.

Is ISO 27001 needed? Often optional, but greatly accelerates the "technical block."

How much to store logs? Jurisdiction specific: 5-10 year benchmark for financial/gaming events.

How often to train staff? Basic - onboarding + every 6-12 months and after serious incidents.

Successful licensing is not a "magic lawyer," but a coincidence of three disciplines: transparent financial flows and AML/RG processes, technical architecture with logs and access control, operating culture (SLA, reporting, training). Come to the regulator with working practices, not presentations - and the license turns from a risk to a competitive advantage.