Executive Summary
Many offshore crypto casinos (e.g., Roobet, Gamdom, BC.Game, Rainbet) embed a “Buy Crypto” widget from third-party on-ramps (MoonPay, Transak, Mercuryo, Swapped). Functionally, this serves as a payment option for gambling deposits: the user funds with fiat (card/transfer), the on-ramp converts to crypto, and the assets are auto-delivered to the casino’s wallet and credited to the player. In substance, the on-ramp acts as a de facto PayFac for the casino.
How the Flow Works (and Why It’s “Payment” in Substance)
- Card/fiat entry via on-ramp checkout (MoonPay et al.). On-ramps market themselves as embeddable “on-ramps,” and some act as merchant of record for the fiat sale.
- Purpose is gambling, not investment. Casinos explicitly instruct users to “Buy Crypto” inside the cashier to fund play; Roobet’s help center confirms an integrated “Buy Crypto” tab. Gamdom advertises MoonPay as a partnered exchange. BC.Game guides note MoonPay availability.
- Direct delivery to casino custody. Platform guides and partner flows show purchases or swaps completing into the casino deposit address (including via Swapped Connect on Roobet). This defeats any notion that users are “investing” in crypto; it’s a deposit rail.
Regulatory Consequences
- UK: Unlicensed gambling is illegal regardless of operator location. Facilitating payments to such sites risks being seen as facilitating unlawful gambling. The UKGC reiterates that GB consumers must not be serviced without a UK licence; recent enforcement and media reporting highlight continuing payment access to unlicensed sites (Source: Gambling Commission).
- EU (PSD2 & AML): While crypto purchase itself may sit outside PSD2, card-funded on-ramping embedded in a gambling cashier replicates a regulated payment function (deposit taking for gambling). At minimum, it triggers VASPs’ AML/CFT obligations (licensing/registration, Travel Rule where applicable) and heightens high-risk sector expectations (Source: FATF).
- Card-scheme policy (MCC 7995): Gambling deposits should be coded under MCC 7995 to enable issuer controls and regulatory blocks. When a casino substitutes a “Buy Crypto” on-ramp to sidestep 7995, it creates scheme-evasion risk for all counterparties (Source CommerceGate).
- On-ramp policies: On-ramps’ own terms typically restrict or heighten controls for gambling and illegal activity. Embedding an on-ramp directly in a casino cashier for deposit purposes may conflict with those policies.
Compliance Position (Assessment)
Where an on-ramp is embedded in the cashier and delivers crypto directly to the casino, the on-ramp and the casino together perform a substituted payment service for gambling—i.e., a de facto payment processor arrangement—exposing parties to:
- UK risk of facilitating unlicensed gambling.
- EU AML/VASP expectations (licensing/registration; Travel Rule; enhanced due diligence for high-risk merchants).
- Card-scheme scrutiny for effective MCC 7995 circumvention via a crypto purchase veneer (Source: CommerceGate).
Recommendations
- Regulators: Treat integrated on-ramps that auto-deliver to casino wallets as payment facilitation for gambling; require equivalent controls to MCC 7995 (issuer blocks, affordability, RG/self-exclusion checks) and geo-enforcement.
- On-ramps: Enforce AUPs—prohibit merchant-controlled auto-delivery to unlicensed casinos; require merchant licensing proof and MCC-equivalent risk flags; implement Travel Rule & counterparty due diligence on destination wallets.
- Banks/Issuers/Acquirers: Flag patterns where card-to-crypto purchases regularly resolve to known casino wallets; apply enhanced screening and decline logic for flows that replicate gambling deposits without MCC 7995 tagging.
- Affiliates/Platforms: Disclose clearly that “Buy Crypto” in the cashier funds gambling, not investment; otherwise risk unfair-commercial-practice scrutiny.
This analysis is intended to help supervisors, PSPs, and VASPs align controls with the real-world effect of integrated on-ramping in crypto gambling ecosystems.
