What It Is
Cross-border payments refer to financial transactions where the payer and the recipient are based in different countries. For gambling operators, this includes customer deposits and withdrawals, affiliate and supplier payments, and intercompany transfers across regulated markets. These payments can involve traditional bank transfers, card schemes, e-wallets, or newer digital assets like stablecoins.
Due to the sensitive nature of gambling-related transactions, cross-border payments are subject to intense regulatory oversight, including financial sanctions, anti-money laundering (AML) rules, and data localisation laws. Operators often face higher scrutiny from payment service providers (PSPs), card issuers, and correspondent banks, many of whom treat gambling as a high-risk industry.
Why It Matters to Gambling Executives
Cross-border payments sit at the intersection of business growth and regulatory exposure. Expanding into new markets means managing diverse payment preferences and regulatory regimes. In Europe, for example, operators must comply with both national gaming laws and broader EU financial rules, such as the Payment Services Directive (PSD2) and the AML Directive. Outside Europe, each market introduces new variables, from capital controls in Africa to foreign exchange constraints in Latin America.
Operators must also navigate high rejection rates from traditional banking channels, especially when dealing with US-facing traffic or unlicensed markets. This has led to increased reliance on non-bank financial institutions and alternative PSPs. However, using these channels may introduce additional operational and reputational risk, particularly if they are not regulated to the same standard as banks.
Finally, cross-border flows are a key focus of financial regulators and tax authorities. Any failure to properly track, report, or explain these transactions can trigger audits, fines, or licence conditions. Missteps in this area can also damage relationships with acquiring banks and PSPs, potentially cutting off access to payment infrastructure altogether.
Key Considerations
- Licensing Alignment
Ensure the jurisdictional reach of your gambling licences aligns with your payment flow. Mismatches between payment origin, licence scope, and player location may expose the business to enforcement. - Partner Due Diligence
Review the regulatory status and compliance track record of cross-border PSPs, especially those offering services in non-bank rails or high-risk geographies. - Currency and FX Controls
Understand whether local laws restrict currency conversion, repatriation of profits, or the use of non-local payment providers. This is particularly important in markets like India, Brazil, and parts of Africa. - AML and Transparency
Implement strong procedures to detect suspicious transaction patterns, particularly in markets where source of funds and customer identity are harder to verify. - Operational Friction
Be aware of practical delays in settlement times, transaction reversals, or fund freezing — especially where card schemes or banks flag gambling codes.
TGB Note
This topic is under active discussion in the TGB Payments and Compliance Group, which is sharing benchmarking data on PSP reliability and regulator tolerance across Tier 2 and Tier 3 markets.
Sources for Reference Only:
- Financial Action Task Force (FATF) Guidance on Virtual Assets and Cross-Border Payments
- European Commission: PSD2 and AMLD5 Regulations
- Bank for International Settlements (BIS): Cross-border payments frameworks
- UK Gambling Commission Financial Transactions Guidance
- Payments Association reports on high-risk sector processing
