⚠️ Germany🇩🇪: the payment chain has become the main mechanism for regulating online gambling

⚠️ Germany🇩🇪: the payment chain has become the main mechanism for regulating online gambling

Casinos and betting platforms rely on a broad financial infrastructure, including payment systems, banks, e-wallets, acquiring banks, payment processors, open banking providers, crypto platforms, and other ecosystem participants. Each of these actors can act as a control point, meaning that payment systems are no longer neutral channels within the online gambling ecosystem.

🌐 Regulatory framework: under German legislation, payment blocking (Zahlungsunterbindung) is considered one of the tools used to combat unauthorized gambling offerings, alongside measures such as blocking illegal applications or services. In practice, the financial infrastructure forms part of the enforcement and supervisory framework.

🌐 “Whitelist”: the Joint Gambling Authority (GGL) maintains an official list of operators authorized under the 2021“State Gambling Act”. However, in practice, inclusion on this list does not fully resolve the challenges of identifying and controlling activities targeting the German market.

🌐 Regulatory burden: payment systems must determine whether merchants hold licenses, whether their activities target prohibited markets and whether transaction flows create risks related to money laundering, fraud or consumer protection.

🌐 Risks for licensed gambling operators: erroneous payment blocking may result in partners, technology providers or consumers being subject to disputed classifications.

🌐 Beyond blocking measures: under Article 284 of the German Criminal Code (StGB), unauthorized gambling operations may constitute a criminal offense punishable by imprisonment. For individuals participating in illegal gambling, Article 285 provides for penalties of up to 180 daily fines or imprisonment of up to 6 months.

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