Building an AML program for iGaming operators
A practical framework for AML, source-of-funds and EDD that satisfies acquiring banks and regulators alike.
Anti-money-laundering programs are no longer optional for iGaming operators seeking sustainable acquiring. Banks underwrite the program as much as the merchant.
What acquirers actually look for
Acquiring banks evaluate three pillars before approving an iGaming MID: customer due diligence, transaction monitoring, and governance. Each pillar maps to documented procedures and named responsible officers.
- A documented CDD policy with tiered KYC thresholds
- Real-time transaction monitoring rules with alert workflows
- An MLRO (or equivalent) with authority to file SARs
- Annual independent audit of controls
Source of funds, in practice
Source-of-funds verification is where most operators fail underwriting. The bar is risk-based — high-deposit players need documentary proof, not affirmations. Build a tiered SoF policy that triggers on cumulative deposits, single deposit size, and behavioral anomalies.
Working with Aquablue8
We review your AML program before submission and coach the controls to a bankable standard. Most operators close 3–5 gaps before we route the file to acquiring partners.