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Online gambling continues to thrive in Poland, despite the country’s strict regulatory framework. Virtual casinos and betting platforms still attract players with the promise of easy access and quick winnings. Yet, their operations would not be possible without the involvement of payment institutions that process transactions for entities operating outside the boundaries of the law. Behind the scenes lie not only questions about compliance with Poland’s Gambling Act, but also serious concerns about money laundering and the potential financing of criminal activity.

PSPs Legal Responsibility

The key question remains the legality of actions taken by payment institutions that handle transactions linked to illegal online gambling. Do they, even unintentionally, help such operations thrive? Under Polish law, payment service providers are required to monitor and limit high-risk transactions. In practice, this means that every deposit or withdrawal connected to unlicensed gambling activity should be treated as a red flag. Special attention is also given to transactions made through popular mobile payment systems such as BLIK. While BLIK itself is not a payment institution under Polish law, the banks and financial operators using it are and it is they who bear responsibility for preventing the flow of funds that may support illegal gambling activities.

Clear Legal Framework, Limited Excuses

Polish law leaves little room for speculation here. The register of domains used to offer illegal gambling, the ban on processing payments for unlicensed operators, and the penalties outlined in the Fiscal Penal Code and Criminal Code set clear boundaries of responsibility.

The Anti-Money Laundering Act (AML) and the EU Regulation 2023/1113 require payment institutions to actively monitor transactions, block suspicious transfers, and cut off risky relationships. Guidance issued by the Polish Financial Supervision Authority (KNF/UKNF) and the National Risk Assessment, along with its sectoral annex, describes typical abuse schemes and makes it clear that payments directed toward online gambling should be treated as a major warning signal. In practice, this means that financial channels supporting illegal gambling must be identified and shut down before the funds return to players as so-called “winnings.”

And this principle is now being actively enforced. Recently, the Financial Supervision Authority (UKNF) went a step further, issuing a sector-wide warning urging payment service providers to block financial flows to unlicensed operators. In response, Polish payment providers have begun withdrawing support for illegal gambling sites and removing payment options such as BLIK from unlicensed platforms.

The Hardest to Detect: The Intermediary Role

The flow of funds into illegal online gambling can take many forms, depending on the relationships between the parties involved in the transaction. The most difficult to detect, however, is the scenario in which a payment institution acts only as an intermediary within a larger payment chain transferring money between other financial service providers without directly serving the payer or the recipient. Even in such cases, the institution is not exempt from its obligation to continuously monitor and analyse all transactions.

Depending on the type of payment, it should apply different verification methods, all aimed at determining whether executing a transfer on behalf of another provider could, in practice, end up funding entities that organize illegal online gambling. The institution must obtain information from the ordering provider about the recipient, determine whether it is engaged in gambling related activity, and verify its legal status. If red flags arise during the analysis such as missing data in the payment chain, a domain listed in the official register, or the absence of the website from the list of legal operators the transaction should be paused or rejected and properly escalated. This includes raising the risk level, notifying the relevant authorities, or even terminating cooperation. When dealing with correspondent relationships involving other institutions, including those based within the European Union, heightened caution is essential.

Grey Market Fuelled by Inaction

Illegal online gambling would not exist without the support of the payment system. Although the law clearly defines the obligations of financial institutions, in practice it is often these very institutions that knowingly or not enable the flow of money into illegal online gambling. This is why effective identification and blocking of such transactions is crucial, especially within complex payment chains where tracing the connections can be most difficult. Every transfer made in support of illegal online gambling represents not only a legal risk but also real support for the shadow economy that thrives on the lack of vigilance within the financial sector.

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