How Web3 affects licensing and compliance
Full story
Web3 turns platforms into a combination of application and protocol. Money, assets, tickets and statuses live on the blockchain; the player interacts through custodial and non-custodial wallets, and the logic of some processes is in smart contracts. This increases transparency and reduces transaction costs, but complicates licensing and compliance: the regulator needs to control not only the "site and provider," but also online behavior, liquidity bridges, tokenomics and integration with DeFi.
1) What changes in licensing
1. The scope of the license is expanding. In addition to the "operator/provider of games," roles appear: the issuer of tokens, the provider of wallets, the operator of the NFT marketplace, the validator of online draws, the organizer of DAO votes.
2. The scope of responsibility is shifting to on-chain contracts. Not only services are licensed, but also their "code-as-rules": token contracts, jackpot payments, VRF/oracle providers, provably fair provider schemes.
3. Geo and access. Web3 accelerates cross-border payments, so regulators insist on geo-gating, sanctions filters and provable traffic segmentation.
4. New "related subjects." Analytical providers of on-chain risks, custodial partners, stablecoin issuers - all of them fall into the audit zone.
2) KYC/AML in Web3: from "checked passport" to "estimated address"
The key shift is to check not only the person, but also the behavior of the wallet/network of transactions.
Combined model: classic KYC (personality, age) + address risk scoring (address history, connections with dark pools/mixers, participation in laundering schemes).
Travel Rule in the crypto circuit: for transfers between custodial providers - exchange of information about the sender/recipient; for non-custodial - owner "binding" scripts when entering the licensed perimeter.
"Source of funds" online: analysis of the origin of assets, segmentation of "clean/gray/prohibited" flows, automatic triggers enhanced due diligence.
Default observability: conversion logs (fiat↔kripto), limits, velocity check, sanction lists, real-time reaction to suspicious patterns.
3) Tokens, NFT and risk classification
Utility vs. Security. Any economic model should avoid promises of returns and "profit-sharing pools" without an appropriate regulatory shell.
NFT utility without "invest promises." Access, status, ticket, membership - yes; "income-cher" and profit guarantees - no (without special mode).
Stablecoins and calculations. Requirements for reserves, reporting, issuers and payment providers; additional monitoring in cross-chain bridges.
Game economics. "Burn/upgrade," emission limits, anti-inflation rules - and all this is documented for the auditor.
4) "Fairly Fair" and RNG in Practice
Web3 allows you to check honesty:- VRF/oracles. Randomness is confirmed by cryptography and independent sources; providers, keys and rotation rules are fixed in the license.
- Open draw logs. Hashes/Sid values, inputs and results are checked on the circuit or in a public journal.
- Certification. Even with an onchain accident, the regulator requires an audit of algorithms, monitoring of manipulations and an incident response plan.
5) DAO and management: "code is law..." but with legal address
Boundaries of responsibility. Delegates/multisig keepers, operating company, ecosystem fund - all this is described in the charter and in the license.
Voting policies. Conflicts of interest, quorums, "cool-down" on critical decisions, logs of changes to smart contracts.
Commercial DAO activities. If DAO affects tokenomics/reward pools - Treasury level AML/KYC procedures are required.
6) Privacy and data
PII minimization. The less personal data on the circuit, the better; everything is sensitive - offchain with encryption.
Pseudonymity ≠ anonymity. The operator must be able to link the account and address in the licensed perimeter (age, geo, sanctions).
Right to remove. Data is not erased on the chain - therefore, personal fields cannot be written to online metadata; Use hashes/aliases and reference schemes.
7) Geo-gating and responsible access
Geo/age before connecting wallet. Blocking of prohibited jurisdictions before on-chain operations.
Responsible Gaming в Web3. Deposit/time limits, "pause," self-exclusion, and this applies to the account and related addresses.
Risk adaptation. If the address is high risk - reduced limits, prohibition of bonuses, manual verification.
8) Compliance architecture for the Web3 operator
Solution Layers:- Access Layer: landing page, age/geo-filter, sanctions, device-fingerprint.
- Wallet Layer: custodial and non-custodial integrations, linking an address to an account.
- Risk & AML Layer: online scanner, graph analysis of connections, Travel Rule-gateway, alerts.
- Game & Fairness Layer: VRF/oracles, "provably fair," RNG provider audit.
- Treasury & Payouts: Stablecoins, Fiat Gateways, Recipient Registry and Limits.
- Data & Privacy: offchain-PII, encryption, tokenization, retention policies.
- Governance & Audit: decision logs, contract versioning, reports for the regulator.
Key integrations: online analytics provider, KYC/IDV, VRF provider, payment partners, stablecoin treasury, geo-gate and sanctions list providers.
9) Implementation Roadmap (90-180 days)
Phase 1 - Basis (0-30 days)
Map of roles and licenses, risk policies, register of contracts.
Geo/age-gating to wallet connection.
Basic KYC + online scoring of addresses, sanction filters.
Phase 2 - Integrity and Payments (30-90 days)
Connection of VRF/oracles, public verifiers "provably fair."
Treasury: stablecoins, limits, payment logging.
Travel Rule procedures for custodial flows.
Phase 3 - Scale and Audit (90-180 days)
Audit of smart contracts, incident response and key company processes.
DAO-frame (if necessary): quorums, multisig, fund reporting.
Full reports for the regulator: online risks, moderation, RG metrics.
10) Product compliance and "health" metrics
AML/KYC: share of addresses with passed risk scoring, time to resolution, incidents/1k transactions.
Fairness: Proportion of games with verified randomness, complaints/replays, VRF latency.
Payments: deviations/chargeback, average withdrawal time, share of stablecoins.
RG: Percentage of users with active limits/pauses, night marathons, intervention rate.
Privacy: PII incidents, pen test results, compliance with retention policies.
Audit/management: closed audit recommendations, vulnerability response time, transparency of DAO solutions.
11) Checklist for operator
- Roles (operator, token issuer, marketplace, VRF provider) are described and covered by license/contracts.
- Geo/age-gating + sanctions before entering the online circuit.
- KYC + address risk scoring, Travel Rule for custodial translations.
- "Provably fair" documented: provider, keys, QA procedures.
- Treasury: Limits, multisig, stablecoins, tranche logs.
- Token policy/NFT: utility without promises of income, caps/" burning, "upgrades.
- Privacy by design: offchain-PII, encryption, prohibition of personal data in online metadata.
- RG loop: limits, pauses, self-exclusion - associated with addresses.
- Response plan: onchain incidents, contract vulnerabilities, key company.
- Reporting and logging: audit trails, contract versions, reasons for decisions.
12) Typical errors and how to avoid them
"Web3 means anonymous." No, it isn't. Do address linking and risk scoring.
Recording personal data on the circuit. Do not - use offchain/hashes.
No tokenomics limits. Leads to inflation and claims of the regulator.
No VRF/RNG audit. Loss of trust and risks of license revocation.
Ignore Travel Rule/Sanctions. Blocking providers and payment gateways.
There is no incident plan. Errors in contracts "freeze" - we need folback and emergency procedures.
Web3 is a chance to make licensed products more transparent and safer, but only if the operator builds online observability, complies with KYC/AML with targeted risk scoring, documents provably fair, keeps tokenomics within the utility, respects privacy and implements geo/age filters to online activities. Those who are able to combine innovation with compliance discipline will have a sustainable advantage and the trust of regulators, partners and players.