Inside iGaming’s toughest challenge: Cross-border compliance
As gaming companies expand across international markets, regulatory compliance has become one of the most demanding aspects of their operations. iGaming operators must navigate a mix of legal frameworks, licensing requirements and enforcement practices that differ not only from one region to another, but often between neighbouring jurisdictions within the same region.
The Financial Action Task Force (FATF) continues to warn that inconsistent regulation, especially in fast-growing markets, increases the risk of financial crime. Its 2025 update on virtual assets and service providers (VASPs) shows that many countries have yet to fully implement key AML requirements such as the Travel Rule and effective licensing systems, leaving gaps that expose operators to cross-border risks.
In Europe, regulators are trying to make rules more consistent across countries. The European Union’s new Anti-Money Laundering Authority (AMLA) and related laws are meant to improve supervision and cooperation between Member States. In Asia, however, the situation is more mixed, as each country has its own rules and tends to change them more often, sometimes without much warning.
A recent report by the Association of Certified Gaming Compliance Specialists (ACGCS) describes this as a “growing patchwork of regulatory requirements”, noting that major markets such as the United Kingdom, Australia and Macau have imposed record fines for AML breaches over the past year.
Speaking exclusively to SiGMA News, Sona Kirakosyan, Head of the Technical Monitoring and Compliance Unit at TotoGaming, outlined the most pressing challenges facing operators managing compliance across multiple jurisdictions, particularly in Asia, and explained how consistent operational alignment, jurisdiction-specific expertise, and strong communication across teams are essential to maintaining trust and regulatory integrity.
Operational alignment & staff competency across jurisdictions
Kirakosyan explained, “A critical yet often underestimated compliance challenge lies in ensuring that operational teams are well-informed and aligned across multiple regulatory environments.”
For operators active in different jurisdictions, she said, compliance must work hand-in-hand with front-line and client-facing departments such as sports and casino risk, customer support, marketing, and CRM to ensure teams operate in accordance with each jurisdiction’s specific requirements and clearly distinguish between differing regulatory obligations.
“When operating under multiple regulatory regimes, the same operational behaviour can have very different compliance implications depending on the jurisdiction,” she said.
Citing examples of how regulations can differ between markets, Kirakosyan explained that a marketing campaign meeting advertising standards in one country might violate bonus or inducement restrictions in another. She added that even a customer support response about withdrawal times or self-exclusion options could breach consumer protection or responsible gambling rules if not carefully worded, while a CRM-based retention strategy permitted in one jurisdiction might be considered unlawful customer incentivisation in another.
“The client-facing staff is the public face of the company, and their conduct directly shapes regulatory perception. Even minor lapses – a misstatement in live chat, an unapproved bonus communication, or an inconsistent responsible gaming message – can trigger regulatory scrutiny, fines, or licence reviews,” she said.
Kirakosyan added that this challenge becomes even more pronounced when a company operates across both European and Asian markets, where regulatory frameworks, enforcement approaches, and cultural expectations differ significantly. “European jurisdictions generally follow harmonised regulatory standards, supported by frameworks such as EU directives and GDPR, while Asian markets often present greater diversity, evolving rules, and differing enforcement practices.”
“As an international brand, TotoGaming effectively addresses these complexities by leveraging local expertise, maintaining a strong alignment between its Compliance and Operational teams, and implementing tailored, jurisdiction-specific guidance supported by ongoing training programmes,” she said.
“Ultimately, compliance is not just a regulatory function – it’s an operational culture. When operating across multiple jurisdictions, ensuring that every team member, especially those engaging with clients, understands and internalises that compliance obligations are not optional; it is essential to maintaining regulatory trust and protecting the company’s licence to operate.”
Limited licence passporting and high compliance costs
“In most cases, gambling licences cannot be passported between jurisdictions, requiring operators to obtain separate national authorisations for each market,” Kirakosyan said.
“This creates significant financial and administrative burdens, as every jurisdiction imposes its own licencing fees, documentation standards, audits, and ongoing compliance obligations.”
She noted that application packages are often complex and interdependent, with regulators requesting documents such as local bank guarantees or system certifications that can only be secured after licensing, leading to delays and added expenses.
“The cumulative cost of licence acquisition, renewal, local representation, and continuous audits can be substantial, especially for operators active across multiple regions.”
While the EU benefits from some regulatory alignment through AMLD and GDPR frameworks, Kirakosyan observed that Asian markets are far more fragmented, with standalone licensing regimes and limited consistency. “As a result, companies face higher operational costs and resource demands to maintain compliance across diverse and highly differentiated regulatory environments,” she said.
Regulatory changes & approval procedures
“Another major challenge for gambling operators is managing frequent jurisdictional changes and the inconsistent procedures for regulatory approvals across markets,” Kirakosyan continued.
“In many jurisdictions, rule changes can occur suddenly and with limited transition periods, forcing operators to adapt quickly at high cost.”
According to her, the complexity is further influenced by political and social factors, as gambling regulation often evolves in response to changing government priorities, public attitudes, or broader policy objectives.
“These dynamics can result in regulatory adjustments that are difficult to anticipate, adding uncertainty to long-term compliance and operational planning.”
She also noted that jurisdictions differ significantly in their openness to dialogue with industry participants. “While European regulators often maintain structured consultation processes to assess the impact of new measures, in many Asian markets, regulatory updates are implemented with minimal industry consultation or transparency, leaving operators with little opportunity to prepare or influence implementation timelines.”
Kirakosyan explained that operating in both Armenia and Romania, Totogaming faces such realities across markets. “For example, in Romania, despite being a European market, legislative changes are sometimes rolled out swiftly with limited opportunities for stakeholder feedback. While emergency ordinances or urgent regulatory updates may be necessary, restricted public consultation can create practical challenges. It is similar to releasing a software patch without thorough testing: immediate issues may be addressed, but new or larger complications and risks can emerge.”
Armenia’s position at the crossroads of Europe and Asia
Kirakosyan further reflected on how Armenia’s geographic position shapes its regulatory environment. “Armenia’s geographic positioning at the crossroads of Europe and Asia creates a unique dynamic in shaping its regulatory approach to online gaming. The country draws influence from both European and regional Asian practices, adopting international best practices while tailoring them to local market realities and cultural norms.”
“A notable similarity with many Asian jurisdictions is Armenia’s highly restrictive approach to gambling advertising. Under recent regulations, advertising is permitted only on the façades of gambling companies’ own premises and inside their offices, with full bans on television, radio, online, and outdoor promotion. While this socially cautious policy aims to reduce public exposure and encourage responsible gambling, it also limits operators’ ability to market legally and maintain competitiveness, positioning Armenia closer to Asian markets than to Europe’s more commercially open model.”
“At the same time, Armenia has implemented transparent licencing frameworks, AML standards, and player protection measures inspired by European jurisdictions. International best practices in Responsible Gambling such as self-exclusion tools, deposit limits, and session reminders are being adapted to local conditions. Data protection policies are increasingly aligned with GDPR principles, reflecting Armenia’s commitment to harmonising with European compliance standards, while adapting these practices locally to ensure they are practical for the Armenian market.”
Differences in gaming regulations, licencing rules, and enforcement across regions make compliance management complex. Operators must follow varying local requirements and adjust procedures to meet each jurisdiction’s laws and regulatory expectations.
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