Key Moments:
- Records show the Dutch Gambling Authority (Ksa) issued formal data demands to banks and payment providers from 2012 to 2022.
- Unibet payments and related transactions became a key focus during the company’s unlicensed activity in the Netherlands.
- Ksa used Dutch administrative law to compel cooperation and access to business records from banks and payment processors.
Regulator’s Strategic Use of Payment Data
Recently released documents reveal that the Dutch Gambling Authority (Ksa) spent years requesting information from banks and payment service providers. Moreover, these requests often included strict deadlines. In many cases, recipients were instructed not to inform external parties. Overall, these actions formed part of a long-term effort to combat unlicensed online gambling in the Netherlands.
The information comes from a public-records disclosure (Woo request 19162), which details Ksa communications from 2012 through 2022. Since the Ksa had limited power to directly target offshore operators, it instead tracked money flows. As a result, the regulator focused on the systems Dutch players used to move funds.
Focus on Unlicensed Transactions and Operators
Within its internal records, the Ksa repeatedly targeted payment rails, especially iDEAL, the dominant Dutch online banking method. For example, banks were asked for transaction data, while payment processors were required to provide contract and transaction documentation. This applied to unlicensed operators serving Dutch residents. In particular, Ksa scrutiny intensified during the period when Unibet operated without a proper license.
Additionally, records show that the regulator later contacted Worldpay. It requested contracts and communications linked to Unibet.eu. It also sought a summary of iDEAL transactions made by Dutch users over a specified timeframe.
Coordination with Domestic Payment Providers
The regulator’s efforts began even before its 2018 demands to banks. In September 2017, letter exchanges show that Ksa summoned payment service providers DialXS and Cardgate to a review meeting. The meeting occurred under a cooperation agreement, and Ksa requested different attendees due to ongoing legal issues involving certain representatives.
Legal Framework Supporting Enforcement
The authority for these requests comes from Dutch administrative law. In the Netherlands, supervisors have broad powers to collect business records. Consequently, companies must assist regulators. For example, Article 5:17 of the General Administrative Law Act (Awb) allows access to records. Meanwhile, Article 5:20 requires cooperation. Together, these laws place banks and payment firms at the center of tracking illegal gambling activity.
Changing Role of Compliance in the Dutch Market
Since the legal online gambling market launched in 2021, the Ksa has adopted a tougher stance on enforcement and penalties. As a result, payment service providers now play a bigger role in regulation. Indeed, regulatory policy increasingly targets payment methods themselves. For instance, the Ksa issues compliance notices and formal requests tied to “payment instruments.” Therefore, the regulator signals a clear priority: monitoring transactions, reporting suspicious activity, and blocking unauthorized payments.
| Entity | Role in Ksa Investigation | Requested Data or Action |
|---|---|---|
| Banks | Financial intermediaries holding transaction trails | Transaction data for Dutch customers using iDEAL |
| Payment Service Providers (PSPs) | Processors for online gambling transactions | Contractual and transactional information; participation in meetings |
| Unibet | Unlicensed operator under regulatory scrutiny | Transactions and correspondence involving Dutch customers |
- Author
Daniel Williams
