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Q&A | FullCircl Talks KYC, AML, and the UK Gambling Act

For industries like iGaming the future is rooted in sustained, data-driven compliance. KYC and financial vulnerability checks are now critical to iGaming operators,…

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Arwen Heredia
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For industries like iGaming the future is rooted in sustained, data-driven compliance. KYC and financial vulnerability checks are now critical to iGaming operators, supporting regulatory compliance, risk mitigation, and responsible gambling. With regulations tightening, operators are rushing to meet new requirements while maintaining player trust and engagement.

FullCircl, a RegTech platform designed to help companies in regulated industries streamline compliance and customer onboarding, weighs in on the importance of balancing regulatory requirements with user experience. 

Why is conducting KYC and financial vulnerability checks critical for iGaming operators?

Know Your Customer (KYC), Anti-Money Laundering (AML), and identity verification processes are no longer just a nice-to-have in the iGaming industry—they are essential elements of regulatory compliance. While IDV ensures that a player’s identity can be verified and mitigates the risk of fraud and money laundering, gambling operators are now under increasing pressure to ensure safer gambling environments, driven by growing awareness and stricter rules around responsible gambling.

The introduction of financial vulnerability checks allows operators to gain visibility into players’ financial health, helping to identify problematic gambling behaviours before they escalate. By doing so, operators not only comply with existing and new regulations, but also safeguard players and build trust. In the long run, this approach strengthens their reputation by showing a genuine commitment to player welfare.

Can you explain the specific regulatory requirements under the UK Gambling Act Review related to financial vulnerability checks?

The UK Gambling Act, initially announced in 2020 and subject to various delays, introduces stricter financial vulnerability checks to better protect players. Operators in the United Kingdom are now required to monitor public records, such as County Court Judgements (CCJs), Individual Voluntary Agreements (IVAs), High Court Judgements (HCJs), Debt Relief Orders (DROs), and Administration Orders (AOs), to flag financial vulnerable individuals. This forms part of the initial compliance framework for identifying problem gamblers.

Currently, all operators with presence in the UK are required to trigger these checks on any player depositing £500 in a rolling 30-day period. A second stage of implementation is set to roll out in February 2025, where financial thresholds will be reduced to £125 net deposits in a rolling 30-day period.

On top of this, a pilot phase for enhanced financial vulnerability checks is currently underway, set to end in March 2025, which requires operators to trigger a request for a comprehensive financial risk assessment to include credit performance data and aggregated current account turnover. 

How do these checks help operators identify and protect financially vulnerable players engaging in gaming activities?

Financial vulnerability checks give operators crucial insights into a player’s financial background by analysing key markers of harm. Once identified as financially vulnerable and at risk of problem gambling, operators can identify potential risks early, ensuring that vulnerable players are flagged for further review.

By analysing these indicators of abuse, operators can tailor their approach to support players before they develop a serious gambling addiction, reducing the likelihood of further harm. This proactive approach to monitoring players helps operators balance compliance with safer gambling initiatives whilst building trust with their players.

What are some of the biggest challenges iGaming companies face in implementing KYC checks during the onboarding process?

One of the main challenges operators face is striking the right balance between regulatory compliance and player experience. Players today expect quick, seamless onboarding with minimal friction, as forthcoming research from FullCircl shows that an average consumer expects an onboarding process to take a maximum of 12 minutes. 

However, meeting these expectations while ensuring compliance is a delicate task. Operators must collect, verify, and process sensitive player information efficiently without compromising on security. The speed of onboarding is critical not just for players, but also for operators, as fast verification improves conversion rates and ensures a positive user experience from the start.

How does FullCircl’s KYC and AML solutions streamline the onboarding and pre-account compliance processes for operators?

FullCircl simplifies KYC and AML processes by offering real-time orchestration through a single access point. Operators work with our onboarding team to drag and drop services into a custom workflow, tailoring the onboarding and identity verification journey to their specific needs.

FullCircl’s solution integrates multiple global data sources, providing operators with instant access to the essential information required to verify players. This seamless orchestration ensures that onboarding is both fast and fully compliant, allowing operators to meet regulatory demands while maintaining a frictionless user experience.

What are the potential consequences for operators who fail to implement thorough KYC checks during the onboarding process?

Failure to implement robust KYC checks has severe consequences for operators. Non-compliance with regulations can result in hefty fines, as well as reputational damage that erodes player trust. Additionally, operators may expose themselves to risk such as money laundering, fraud, or bonus abuse.

Recent years have seen several high-profile fines for non-compliance, including earlier this year, Gamesys being fined £6m for AML failings and brands within the Kindred group being fined £7.1m for social responsibility and AML failings. These penalties highlight the importance of conducting thorough checks, not just to avoid financial penalties, but to protect players and uphold the integrity of their business and the industry.

How does FullCircl’s solution ensure that the onboarding process remains seamless for players while maintaining compliance with regulations?

FullCircl’s solutions aggregate real-time data from multiple sources, ensuring smooth onboarding without sacrificing compliance. Key features include failover and waterfall to improve match rates, automatic document verification with facial comparison, and ongoing monitoring, making identity verification quicker and smarter.

A single API integration allows operators to manage their compliance stack through one unified workflow, eliminating the need for multiple systems or manual intervention. This ensures that players can enjoy a seamless onboarding experience while operators maintain full compliance. 

How can pre-account checks reduce the risk of onboarding high-risk or potentially fraudulent players for iGaming operators?

Pre-account checks are critical in filtering out high-risk players before they gain access to gaming services. These checks identify politically exposed persons (PEPs) and scan global sanctions lists, reducing the risk of onboarding individuals linked to financial crimes.

Email validation helps prevent bonus abuse, while advanced ID verification with facial recognition ensures that only legitimate players are onboarded. By combining these services into one seamless workflow, operators build stronger defences against fraud and illicit activities, creating a safer environment for all players.

Currently, operators are not required to perform financial vulnerability pre-account openings and must only check a player if they exceed the threshold. While this helps the player experience, it also poses the question as to whether problem gambling rates will see a decline , as players can currently move to different operators if they are given deposit limits or safer gambling reviews at other businesses.

Looking ahead, how do you see KYC and financial vulnerability checks evolving in response to future regulatory changes in other jurisdictions?

The UK Gambling Act Review serves as a model for other regions looking to implement stricter regulations. In fact, we’re already seeing new regulatory frameworks emerge in other markets—such as the upcoming Latam regulations. These changes suggest a global shift towards more stringent compliance protocols in the iGaming sector.

The rapid rise of sports betting and online gambling in the U.S. adds further complexity, given that regulations vary by state. However, with growing concerns around gambling addiction (as evidenced by the increase in hotline calls), it’s clear that more comprehensive regulations are on the horizon. Operators need to stay agile, as adopting robust KYC and financial vulnerability processes will become even more critical across jurisdictions.

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