Email 2/2
Unregulated online casinos that target UK customers without a licence from the UK Gambling Commission (UKGC) are committing a criminal offence under UK law—and so are those who facilitate their operations (like advertisers, payment processors, or affiliates). It is not merely frowned upon; it is illegal.
• 1. Operating Without a Licence – Illegal – see attached the call recording from UKGC
Under the Gambling Act 2005, it is a criminal offence to provide remote gambling services to people in the UK without a licence from the UK Gambling Commission. Specifically:
• Section 33(1): "A person commits an offence if he provides facilities for gambling… unless he is authorised by a licence."
This applies even if the operator is based overseas but markets or makes services available to UK residents.
• 2. Marketing or Promoting Illegal Gambling – Also Illegal – I have emails spamming me with marketing.
Section 330 and 331 of the Gambling Act prohibit advertising unlawful gambling. This includes affiliates, influencers, or anyone promoting these sites in the UK.
• 3. Facilitating Transactions to Illegal Gambling Sites – Serious Compliance Risk
Firms subject to AML regulations (e.g. payment processors, banks) risk violating the Proceeds of Crime Act 2002 if they knowingly facilitate payments related to unlicensed gambling, which could be considered criminal property.
Relevant information
Quote from Visa within media articles, however, lauded the impact of its Integrity Risk Programme, which is a set of guidelines and requirements for its partnered payment acquirers to connect to its network.
The card issuing giant stated: "Visa is committed to maintaining the integrity of our payment system. We do not tolerate the use of our network and products for illegal activity, and we are vigilant in our efforts to deter illegal activity on our network.
"The Visa Integrity Risk Programme establishes a set of ecosystem controls, requirements and capabilities that seek to deter, detect and remediate noncompliant transactions across our network"
• https://www.theguardian.com/society/2025/mar/09/mastercard-and-visa-linked-to-gambling-sites-accused-of-scamming-uk-customers#:~:text=Mastercard%20and%20Visa%20are%20processing,previous%20pledge%20to%20do%20so.
• https://www.pymnts.com/credit-cards/2025/mastercard-visa-pledge-vigilance-following-gambling-investigation/
• https://www.gamblingcommission.gov.uk/public-and-players/guide/gambling-using-a-credit-card
• https://www.ukbookmakers.org.uk/2025/03/uk-gambling-commission-pledges-to-probe-links-between-visa-mastercard-and-illegal-betting/
FOS cases that are relevant
• DRN 4443965 – The rules explain disputes can be initiated under that condition if the authorisation request contained an incorrect MCC. Subject to certification that, and an explanation of why, the authorisation request would have been declined if valid data had been provided. There is nothing in the rules restricting such a claim being raised against a merchant providing gambling services. To defend such a claim, the acquirer would need to show why the dispute was invalid - such as showing the authorisation didn’t contain invalid data.
• DRN 4400536 - The visa chargeback rules / specifically dispute condition "12.7 invalid data" - allow for chargebacks in relation to transactions where authorisation has been obtained using invalid or incorrect data. In cases where an unlicensed gambling business has taken payment using the incorrect MCC on a visa credit or debit card that has the gambling MCC block applied to it - this code applies for the chargeback.
DRN-3077317 - although not directly linked to my circumstances please see screenshot that if items are miscoded then Visa and FOS would expect a chargeback, no exclusions for Gambling this should be coded 7995 but has not been - Lloyds not raising made them liable circa £20k
DRN-4516953 - Focuses on scam casinos so non licensed, same as mine - Revolut liable circa £170,000.