Payment Blocking and AML: Why EU Gambling Transactions Fail

Understanding Payment Blocking in EU Gambling Markets

Payment blocking has emerged as one of the most effective enforcement tools used by European gambling regulators to combat unlicensed operators. When a country implements payment blocking, banks and payment service providers are required to refuse transactions to and from operators that appear on regulatory blacklists.

This mechanism creates a significant barrier for unlicensed operators, protecting consumers from unregulated gambling sites that lack responsible gambling measures, fair gaming guarantees, and dispute resolution mechanisms. However, it can also create confusion for players who don't understand why their transactions are being rejected.

As discussed in our overview of EU gambling laws, there is no single EU-wide gambling license. Each member state regulates its own market, which means payment blocking lists and enforcement approaches vary significantly by country.

How Payment Blocking Works

The payment blocking process typically follows this structure:

1. Regulator identifies unlicensed operators – National gambling authorities maintain databases of operators that illegally target their citizens
2. Blacklists are distributed to financial institutions – Banks, card issuers, and payment processors receive updated lists of blocked domains and payment identifiers
3. Transactions are screened – Payment systems check transactions against blacklists before processing
4. Blocked transactions are rejected – Payments to or from blacklisted operators are declined, with the customer often seeing generic "transaction declined" messages

Anti-Money Laundering (AML) Requirements in Gambling

Beyond payment blocking for unlicensed operators, Anti-Money Laundering regulations create another layer of transaction controls that can affect both deposits and withdrawals at licensed gambling sites.

The gambling industry is classified as a high-risk sector for money laundering due to the volume of transactions, the potential for cash handling, and the opportunity for criminal funds to be "cleaned" through gambling activity. As a result, EU gambling operators must implement robust AML programs that may cause transaction delays or rejections.

The EU AML Framework

The European Union's Anti-Money Laundering framework has been significantly strengthened in recent years. The EU Anti-Money Laundering Directives establish minimum standards that all member states must implement, though individual countries may apply stricter requirements.

A major development occurred on July 2025, when the Anti-Money Laundering Authority (AMLA) commenced operations in Frankfurt. This new EU-level supervisor directly oversees high-risk financial institutions and coordinates cross-border AML enforcement, with authority to impose fines of up to €10 million or 10% of annual turnover.

Know Your Customer (KYC) Verification

KYC verification is a critical component of AML compliance and the most common reason for withdrawal delays. Licensed operators must verify customer identity to prevent fraud, underage gambling, and money laundering.

Typical KYC documentation includes:

• Government-issued ID – passport, national ID card, or driver's license
• Proof of address – utility bill, bank statement, or official correspondence dated within 3 months
• Payment method verification – photos of cards used (with middle digits obscured), bank statements showing account holder name
• Source of funds – payslips, tax returns, or other documentation explaining where deposited funds originated

According to the Financial Action Task Force (FATF) Recommendations, these customer due diligence measures are essential for preventing money laundering and terrorist financing in the financial system, including gambling operations.

Common Reasons Gambling Transactions Fail

Understanding why transactions fail can help you resolve issues more quickly and avoid frustration. Transaction failures generally fall into several categories:

1. Operator Licensing Issues

The most common reason for payment blocking is that the operator lacks a valid license in your country. Even if an operator holds a license from Malta or Curaçao, this doesn't authorize them to operate in markets with their own licensing requirements.

Before depositing, always verify that your chosen operator is licensed by the relevant regulator in your jurisdiction. Our Country Index provides links to national regulator databases where you can check operator licensing status.

2. Bank Policies on Gambling

Some banks have internal policies restricting gambling transactions, regardless of operator licensing status. This may include:

• Complete blocks on gambling merchant category codes
• Limits on gambling transaction amounts per day, week, or month
• Requirements to opt-in for gambling transactions
• Automatic flagging of gambling transactions for review

If your bank blocks gambling transactions, you typically have options: contact your bank to adjust settings, use a different payment method, or switch to a bank with more permissive policies. However, never attempt to circumvent payment blocks by misrepresenting transaction purposes.

3. Self-Exclusion Registration

If you've previously registered with a national self-exclusion system, your transactions may be blocked as part of the exclusion mechanism. Systems like Germany's OASIS, Sweden's Spelpaus, and the Netherlands' Cruks are designed to prevent excluded individuals from accessing gambling services.

Self-exclusion is a responsible gambling tool, and these blocks should not be circumvented. If you believe you were registered in error, contact the relevant self-exclusion authority to resolve the issue.

4. Incomplete KYC Verification

Deposits may be accepted before full verification, but withdrawals typically require completed KYC. Common verification delays include:

• Documents submitted in the wrong format or poor quality
• Names on documents not matching account registration
• Expired identification documents
• Address documents older than 3 months
• Manual review backlogs during high-volume periods

5. Deposit Limits and Cooling-Off Periods

Many EU jurisdictions mandate deposit limits as responsible gambling measures. Germany, for example, imposes a €1,000 monthly deposit limit across all licensed operators. Transactions exceeding these limits will be rejected.

Additionally, some platforms implement cooling-off periods or reality checks that may temporarily block deposits to encourage responsible gambling behavior.

6. Technical and Processing Issues

Not all failed transactions relate to compliance. Technical issues include:

• Insufficient funds or credit limit reached
• Card expired or reported lost/stolen
• 3D Secure authentication failures
• Payment processor downtime
• Currency conversion issues
• Incorrect payment details entered

Payment Blocking by Country

The implementation and enforcement of payment blocking varies significantly across EU member states. Here's an overview of approaches in key markets:

Germany

Germany operates one of the EU's most comprehensive payment blocking systems under the Interstate Treaty on Gambling (GlüStV). The GGL (Gemeinsame Glücksspielbehörde) maintains blacklists and coordinates with payment providers to block unlicensed operators.

German payment blocking extends to all financial institutions, including banks, credit card companies, and e-wallets. The country also enforces strict deposit limits of €1,000 per month across all licensed operators, tracked through a central cross-operator system.

Netherlands

The Dutch gambling regulator KSA (Kansspelautoriteit) significantly enhanced its payment blocking capabilities in 2026. Dutch banks and payment processors are now required to actively identify and block transactions to unlicensed gambling operators.

The Netherlands also implements strict advertising controls, requiring affiliates to prove 95% of their audience is 24 years or older and prohibiting the use of celebrities, athletes, or influencers in gambling promotions.

France

While France restricts online casino games (with a liberalization bill pending), licensed sports betting and poker operators are permitted. The ANJ (Autorité Nationale des Jeux) coordinates with French banks to block payments to operators offering prohibited products.

Italy

Italy's ADM (Agenzia delle Dogane e dei Monopoli) maintains extensive blacklists of unlicensed operators. The country's new nine-year online gambling licenses (effective 2026) cost €7 million each—the highest in the EU—creating significant barriers for new market entrants.

Spain

Spain's DGOJ (Dirección General de Ordenación del Juego) works with Spanish financial institutions to block payments to unlicensed operators. The country has a well-developed licensed market with comprehensive responsible gambling requirements.

Cryptocurrency and Payment Blocking

Some players attempt to use cryptocurrency to circumvent payment blocking. However, this approach carries significant risks and does not exempt transactions from regulatory requirements.

As explained in our cryptocurrency gambling guide, licensed operators accepting crypto must still comply with full AML/KYC requirements. The European Union's Markets in Crypto-Assets (MiCA) Regulation extends financial services regulations to cryptocurrency, including requirements for crypto-asset service providers.

Using cryptocurrency to access unlicensed operators exposes you to:

• Legal risk: You may violate local gambling laws by using unlicensed services
• No consumer protection: Disputes with unlicensed operators cannot be resolved through regulatory channels
• No fair gaming guarantees: Games may not be tested or certified for fairness
• No responsible gambling tools: Self-exclusion and deposit limits may not be available
• Potential asset seizure: Authorities may pursue recovery of funds used for illegal gambling

Resolving Transaction Issues

If you're experiencing transaction failures with a licensed operator, follow these steps to resolve the issue:

Step 1: Verify Operator Licensing

Confirm the operator holds a valid license in your jurisdiction by checking the relevant regulator's website. Our Country Index provides links to national gambling authority databases.

Step 2: Complete KYC Verification

Ensure your account is fully verified before attempting withdrawals. Submit high-quality, legible documents and ensure all names match exactly across documents and your account registration.

Step 3: Contact the Operator

Reach out to the operator's customer support with your transaction reference number. Request specific information about why the transaction failed and what steps are needed to resolve it.

Step 4: Contact Your Bank/Payment Provider

If the operator confirms no issues on their end, contact your bank or payment provider. Ask specifically about:

• Whether your account has gambling transaction restrictions
• If the specific merchant is blocked
• Whether you've exceeded any transaction limits
• If additional verification is required

Step 5: Consider Alternative Payment Methods

If your primary payment method is blocked, licensed operators typically offer multiple alternatives including:

• Bank transfer (direct wire transfer)
• Prepaid cards (Paysafecard, etc.)
• E-wallets (where permitted)
• Alternative card providers

Step 6: File a Complaint

If you believe a licensed operator is unfairly blocking your withdrawal, you can file a complaint with the relevant gambling regulator. According to the European Commission's Online Dispute Resolution platform, EU consumers have rights to pursue cross-border disputes with businesses.

Future Developments in EU Payment Regulation

The landscape of payment blocking and AML compliance continues to evolve. Key developments to watch include:

• AMLA enforcement: As the Anti-Money Laundering Authority becomes fully operational, expect increased coordination of AML enforcement across member states
• Enhanced payment blocking: More countries are likely to implement comprehensive payment blocking systems
• Cryptocurrency regulation: MiCA implementation will create clearer rules for crypto payment processing in gambling
• Open banking: New payment technologies may create both opportunities and compliance challenges for gambling operators

Responsible Gambling Resources

Payment issues can sometimes indicate problematic gambling behavior. If you're finding yourself frequently blocked by deposit limits or experiencing financial stress from gambling, help is available.

The Gambling Therapy organization provides free, confidential support for gambling-related problems, including online chat, forums, and self-help resources available in multiple languages.

Additionally, the BeGambleAware platform offers practical tools for managing gambling behavior, including budget trackers and self-assessment questionnaires.

For information about self-exclusion options in your country, see our comprehensive Self-Exclusion Systems Across EU Countries guide.

Last Updated: December 2025