The Commission’s ban on credit cards extends to payments for gambling made by credit card through any money service business (MSB).
Licence condition 6.1.2 prevents gambling operators from accepting payments by credit card either directly or through any MSB (such as an e-wallet or other fintech and electronic money institutions enabling e-money transfers) which allows credit cards deposits.
One of our key intentions in banning gambling with credit cards was to maximise the levels of friction during the process of accessing and using borrowed funds for gambling, in order to reduce the risk of consumers experiencing harm from gambling with borrowed money.
It is important for operators to ensure that the credit card ban cannot be easily circumvented by simply topping up an e-wallet or online money transfer account directly from a credit card, where those funds could then be used for gambling with very little friction in the transactional process.
We explained in the credit cards consultation and in our responses that this would mean that operators could not accept any payment through an MSB unless the MSB has prevented the use of credit cards for gambling through their services. This includes, for example, circumstances where an MSB allows its customers to transfer funds from a credit card into a wallet or account which could then be used by the customer to make gambling deposits.
Operators are therefore reminded that they must take the following course of action before accepting customer payments via any MSB (including through any card payment instruments issued by those MSBs to its customers):
- operators must satisfy themselves that customers of that MSB cannot fund their e-accounts or e-wallets with credit card deposits and then use those funds for gambling.
- operators will need to reject all payments made through such MSBs that have not developed a ‘block’ to prevent credit card deposits being used for gambling through their e-account or e-wallet facilities.
Originally posted on 10 June 2020 and updated 12 October 2020.
Posted on 10 June 2020