Due diligence in the gambling industry requires systematic evaluation across multiple dimensions: licensing status, regulatory compliance history, financial health, operational integrity, and reputational risk. According to FATF Recommendations, proper due diligence is essential for mitigating money laundering and terrorist financing risks in the gambling sector.

This tool generates customized checklists based on your specific evaluation context—whether you're assessing a potential acquisition target, evaluating a B2B platform provider, or vetting an affiliate partner. For general compliance requirements, see our comprehensive Compliance Audit Checklist Generator.

Configure Due Diligence Scope

Select the evaluation context and focus areas to generate a customized checklist tailored to your specific needs.

Quick Presets:

Due Diligence Checklist

Generated for M&A evaluation

0 of 0 items completed (0%)

Disclaimer: This checklist provides a general framework for due diligence based on industry best practices. It is not exhaustive and should be supplemented by professional legal, financial, and regulatory advice specific to your transaction. The Gambling Industry Monitor assumes no liability for decisions made based on this tool.

Red Flag Indicators

Key warning signs that warrant enhanced scrutiny or may indicate elevated risk during due diligence.

Licensing & Regulatory Red Flags

  • ⚠ License revocation or suspension history — Previous enforcement action resulting in license loss indicates systemic compliance failures
  • ⚠ Operating in grey/black markets — Accepting players from jurisdictions where the operator lacks required authorization
  • ⚠ Sole reliance on low-tier licenses — Operating only under Curaçao or similar without pursuing Tier 1 jurisdictions despite revenue scale
  • ⚠ Beneficial ownership opacity — Unwillingness or inability to disclose ultimate beneficial owners and corporate structure

Financial Red Flags

  • ⚠ Player fund commingling — Failure to segregate player funds from operational accounts in compliance with license conditions
  • ⚠ Delayed player withdrawals pattern — Systematic payment delays beyond stated processing times indicating liquidity issues
  • ⚠ Unaudited financial statements — Absence of independent audits for operators of material size
  • ⚠ High-risk payment processing — Reliance on payment processors with weak AML controls or poor industry reputation

Compliance & AML Red Flags

  • ⚠ Multiple regulatory fines — Pattern of enforcement actions across jurisdictions indicating systemic non-compliance
  • ⚠ Inadequate AML documentation — Missing or incomplete AML policies, procedures, and risk assessments
  • ⚠ Cryptocurrency-heavy without controls — Accepting crypto without corresponding enhanced due diligence measures
  • ⚠ VIP program without SOW/SOF — High-value player programs without source of wealth verification processes

Operational Red Flags

  • ⚠ High key person turnover — Frequent changes in compliance officer, MLRO, or senior management positions
  • ⚠ Data breach history — Previous security incidents involving player data compromise
  • ⚠ Negative player reviews pattern — Consistent complaints about unfair terms, withheld winnings, or unresponsive support
  • ⚠ ADR/complaint escalation rate — High proportion of disputes escalated to Alternative Dispute Resolution providers
Important: Red flags don't automatically disqualify an operator but should trigger enhanced due diligence. Document your assessment of each flag and the operator's response or remediation measures. For guidance on regulatory enforcement patterns, see our 2026 enforcement review.

Due Diligence Framework Reference

Standard due diligence categories and their typical scope by transaction type.

Due Diligence Category M&A Investment B2B Partner Affiliate
License Verification Critical Critical Critical Standard
Beneficial Ownership Critical Critical Critical Standard
Financial Statements Critical Critical Standard Basic
Compliance History Critical Critical Critical Standard
AML Framework Review Critical Standard Critical Basic
Technology & Security Critical Standard Critical Basic
Key Person Background Critical Critical Standard Basic
Responsible Gambling Critical Standard Standard Basic
Litigation History Critical Standard Standard Basic
Media/Reputation Scan Standard Standard Standard Standard

Information Sources

Effective due diligence requires accessing multiple authoritative sources:

  • Regulatory registries: UKGC Public Register, MGA Licensed Entities
  • Corporate registries: Companies House, Malta Business Registry, Gibraltar registry
  • Enforcement databases: Regulator published decisions and penalty notices
  • Financial filings: Audited accounts, annual reports, stock exchange filings
  • ADR providers: IBAS, eCOGRA, ADR entities for complaint history
  • Industry publications: Trade press coverage, conference participation

Regulatory Framework Guidance

Key regulatory standards that inform due diligence requirements:

Understanding Due Diligence in Gambling Transactions

Due diligence in the gambling industry has become increasingly rigorous as regulators worldwide impose stricter requirements on operators to vet their business relationships. The UK Gambling Commission's LCCP mandates that operators conduct due diligence on third parties "sufficient to establish their integrity and business probity."

Regulatory Context: Under FATF Recommendation 22, countries should require casinos to identify and verify customer identity and conduct ongoing due diligence. This extends to operator-level assessments when entering business relationships with other gambling entities. For deeper analysis of AML requirements, see our AML compliance guide.

M&A Due Diligence Considerations

Acquisitions in the gambling sector require particularly thorough due diligence due to regulatory approval requirements. Most tier-1 jurisdictions require change of control notifications and may conduct suitability assessments on new owners. The International Association of Gaming Regulators (IAGR) facilitates information sharing between regulators during such transactions.

Key M&A considerations include license transferability, material change notification requirements, and potential for regulatory conditions on the acquisition. Our M&A trends analysis provides context on recent industry consolidation patterns.

B2B Partner Evaluation

Platform providers, game suppliers, and payment processors require specific due diligence focus areas. Operators remain accountable for the compliance of their third-party providers, making thorough vetting essential. See our white label and B2B licensing guide for detailed regulatory requirements.

Affiliate Due Diligence

Affiliate marketing in gambling is subject to increasing regulatory scrutiny. Operators must ensure affiliates comply with advertising standards and do not target prohibited markets or vulnerable groups. Our affiliate regulation analysis covers compliance frameworks across major jurisdictions.

Using This Tool Effectively

This checklist generator provides a starting framework for due diligence but should be adapted to your specific circumstances:

  • Customize for risk: Higher-value transactions warrant more comprehensive review
  • Document thoroughly: Maintain records of all due diligence activities and findings
  • Engage specialists: Complex transactions require legal, financial, and regulatory expertise
  • Update regularly: Due diligence should be refreshed for ongoing relationships
  • Consider jurisdiction: Requirements vary significantly by regulatory authority

For related compliance planning tools, explore our licensing due diligence requirements guide, jurisdiction risk assessment tool, and licensing process flowchart.