Since passing in 2006, the Unlawful Internet Gambling Enforcement Act has had a major impact on the world of online gaming in the US and beyond. History of the UIGEA tocThe Unlawful Internet Gambling Enforcement Act (UIGEA) is an anti-gambling law that passed Congress on September 30, 2006.
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The online gambling industry is really quite a marvel when you think about it. All the way back in the mid-1990s, when the Internet was barely in people’s homes, and many still didn’t quite understand what it could be used for, a group of folks realized that they could create software that would allow you to gamble without having to leave your home. Now, to do that, you would have to be able to put real money into your digital account. This would turn out to be one of the biggest leaps of faith that any individual would make – sending your personal banking information over a wire to an unknown source to pay for your gambling.
The next major reforms to state gaming regulations occurred in the 1970s, as a budget crisis hit every state in the union. Relaxed lottery, pari-mutuel, and casino laws swept the country, from the new gambling Mecca of Atlantic City to tribal gaming’s origins at the end of that decade. 8 A SAR is required if a casino knows, suspects, or has reason to suspect that the transaction (or a pattern of transactions of which the transaction is a part) is intended or conducted as part of a plan to violate or evade any Federal law or regulation or to avoid any transaction reporting requirement under Federal law or regulation. Because the $10,000 per gaming day CTR threshold is part of the Bank Secrecy Act, a criminal may seek to evade being recorded on a CTR by breaking a transaction over $10,000 into multiple smaller transactions, which is known as structuring. Single and multiple currency transactions in excess of $10,000 (in a single Gaming Day) are reported to.
Of course, we all know what has happened with online payments over the last 20 years. Today, people pay online for basically everything, and it has become second nature for us to have our banking information stored on these sites. However, even though the online gambling industry can be credited with being one of the earliest adopters of online payment processing, in certain areas it has faced a more uphill battle than any other industry. This page will give you an outline of the industry – what payment processing looks like today, as well as links to details about many of the companies in the space looking to help you make your real money deposits.
US-Friendly Deposit Methods
When we talk about all the deposit options that are available in the online gambling industry today, the easiest way to separate them is by region. Specifically, as a result of the UIGEA bill, we split our deposit methods into two groups – US-friendly and non-US-friendly. Now, many of the methods you see on the US list are, of course, still available in other countries.
Despite all the challenges that have been faced in the online gambling industry in the United States, it is still a huge business with millions of dollars of deposits being taken in daily. Americans do have to put up with the risk on the operator going out of business, which at times can dissuade them from making large deposits. Operators, on the other hand, must pay processing fees that are significantly higher than in other countries given the complexity of trying to process cards from American banks in light of the law.
If you click on any of the links below, you will be taken to a page outlining the details of that deposit method.
Cryptocurrency
Over the last few years, there has been a major shift in the way money changes hands online. Back in 2009, a new and decentralized form of currency came to prominence called cryptocurrency. This highly secure ledger-based method of paying for goods and services took off with the first currency, Bitcoin. Today, there are hundreds of coins available on the market. The online gambling industry was one of the first to fully embrace this new technology, especially for processing US deposits. However, these digital currencies are also a commodity and have faced highly volatile valuations over the years. Below is a list of many of the more popular cryptocurrency deposit options.
BCH Gambling Sites
Litecoin Gambling Sites
Non-US Payment Methods
The rest of the world has had a much easier time with online gambling transactions. A lot of this, especially in Europe, comes from much stricter regulation of the industry, which has forced operators and payment processing companies to comply and be licensed to do business. Although the licensing process can be costly and cumbersome, once a site is licensed it’s going to be paying far less in processing fees than those taking action in the US.
Of course, there are many more currencies to worry about in regions like Europe, and that means that deposit options can also be tailored to a specific country. As you can see from the list below, there is no shortage of deposit methods available for online gamblers outside the US, and we have provided details on all of these.
A Brief History of Depositing Money at Real Money Gambling Sites
Back in the 1990s, there was only one deposit method for players to choose from at online casinos and sportsbooks (that is all that existed back then, by the way). Credit cards were a product that most people had in their wallets, and since people were able to make electronic payments in retail locations (we had come a long way from the old physical machines that took a copy of your card details), taking that technology and porting it online was not as tough as you might think. The bigger challenge was convincing someone, who barely understood the internet, that sending this information into a black hole (now known as the cloud) was safe and secure.
Despite early pushback, the desire to gamble without going to a casino was stronger than the fear, and with that, the real money online gambling boom had begun. Players from all over the world were downloading casino software, or installing it from a CD, and connecting to the internet with their dial-up connection to make deposits and play. We won’t get into the challenges of playing on such slow connections (that’s for another page).
Credit card companies loved this new flood of transactions, with operators very willing to pay the fees that came along with them. However, some problems started to pop up – mainly fraudulent behavior. As the methods of verifying an account were nowhere as sophisticated as they are today, it was only too easy for someone who stole a card to create a casino account and use it to play online. Also, there was an issue of age verification – not having the right checks in place meant that children could take their parents’ cards and play without permission (and illegally, we might add). This resulted in a lot of chargebacks from cardholders, which did not please the credit card companies at all. Rates started to skyrocket, while online gambling companies scrambled to find a solution to their verification process.
Of course, this also made it difficult for someone without a credit card to make a deposit at an online casino. Here is where the folks from PayPal stepped in. They created a safe and secure online banking system that was a peer-to-peer system. Once you created a PayPal account and verified your bank and personal details, you could send money to anyone with the click of a button without having to input your banking information again. The gaming industry ate this up, and before anyone realized what was happening, over 60% of all the online gambling transactions in the United States were being run through the PayPal system.
This all seemed too good to be true, and it was. PayPal was also being used almost exclusively for people to complete purchases on an online auction site called eBay (you may have heard of them), and so they decided to make an offer to purchase PayPal. However, in the terms of the agreement, the payment company would have to stop taking online gambling transactions. Within 60 days of the deal agreement, the online gambling world was once again scrambling to find alternative solutions.
Fortunately, the success of PayPal spurred significant development in the space, and e-wallet solutions like Neteller started to become viable options. The idea of giving your data to a company to create a more anonymous third-party digital wallet, then using that wallet to fund your gambling accounts (and for any other online payments) was catching on, and these companies started growing like a wildfire.
UIGEA – The Game Changer
Everything was growing exponentially in the online gambling market, especially in the United States, where online poker had taken off and seemed to be everywhere. Unfortunately, the market in the US was unregulated, and many in the federal government were looking for ways to shut the industry down.
While there were never any laws added expressly making online gambling illegal, the government did figure out a way to choke off the supply of money flowing offshore. In October 2006, the Unlawful Internet Gambling Enforcement Act was passed into law, making it illegal for US banks to process gambling transactions. This crippled the industry in the States, forcing many of the market leaders out of the space. While many stuck around and found ways to make it work (also for another page), it became clear that funding an online gambling account for Americans was going to be a cumbersome process.
What to Look for When Finding a Deposit/Withdrawal Method
Ok, now that you have been brought up to speed on how payment processing came to be, let’s talk about the deposit methods you will find at an online gambling site. When you are researching sites, you can read our reviews and see a list of all the available processing options at any gambling site. However, as many of these are regional products (especially in Europe), you can also just head to the banking section of a website, where due to your geolocation, you will see the trimmed list of deposit methods available for you in your area.
Still, there could be dozens of potential processing solutions available to you. What makes one better than another? Well, here are three things you should think about when you are selecting a payment solution.
Fees
This applies more on the withdrawal side, but it could also ding you when you are making a deposit at a site. Credit cards may charge you as a cash advance instead of a purchase, which will cost you more in interest. Also, many of the e-wallet companies charge you a small percentage when you fund your account. All of this adds up, especially when you are planning to try to make a return on your cash. Make sure to read all the terms and conditions when you are planning to choose a payment provider.
Speed
Many e-wallet companies require a holding period to verify who you are before allowing you to use your new account to a make a deposit at a real-money gambling site. These delays can be a huge pain especially if you’re trying to make a time-sensitive sports bet. Look for the options that give you instant access to your account and funds so you can make your deposits easily.
Security
While you can never be sure which companies are going to be compromised by hackers, you can do some research to see which companies are the best prepared to handle it. With so many security breaches recently, you also want to find the companies that need the least amount of your personal information to create an account. If you are very concerned about this, you can always lean toward the pre-paid card options where you pay in cash for the anonymous account.
Frequently Asked Questions
Does It Cost Anything to Make a Deposit at an Online Gambling Site?
Many sites will not charge you for making a deposit, even though they are being charged a fee by the processor themselves for the transaction (in some cases up to 14%). However, the deposit method you choose could very well be charging you for funding your account. Make sure you read up on the options you have in order to find the one that charges you the least, if anything at all.

Is Cryptocurrency Safe?
Safety is not the biggest concern with cryptocurrency – the decentralized solution is meant to make it the safest out there. However, cryptocurrency is tied to a digital wallet that has a number attached to it. Unlike a bank that can verify the number, if you lose your coin wallet details, then you can’t access the funds anymore. Also, the value of some of these coins rises and falls so much that you may end up losing money on a transaction before you even play a hand of blackjack at the casino with which you deposited.
What Is a Chargeback?
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When someone thinks their credit card has been used fraudulently, they can contact their card issuer and file a chargeback claim. This is investigated, and in the case of the early days of the online gambling world, the charge was typically reversed. This meant that someone could head to a site, lose money, then call to cancel their company claiming they never made the deposit in the first place. While there are many more safeguards to protect the credit card companies from this type of fraud, chargebacks do still occur for legitimate reasons, and this causes much concern for processing companies.
Dear Mr. Freeman:
Thank you for your December 23, 2014, letter to FinCEN Director Jennifer Shasky Calvery with your concerns about a news article referencing potential FinCEN guidance concerning sports betting. While the article apparently was based on unauthorized sources without a clear understanding of the facts, we have been planning on communicating to the casino industry directly with respect to a particular concern in this regard.
It has come to the attention of the Financial Crimes Enforcement Network (“FinCEN”) and its law enforcement and regulatory colleagues that increases in sports betting conducted on behalf of third parties are facilitating criminal activity and posing a money laundering risk to the U.S financial system. In connection with this, it has also come to our attention that casinos may be under the impression that unless specifically directed to do so, a casino never has to ask a patron whether he or she is betting on his or her own behalf or on behalf of another party. We are communicating directly with your organization to correct any such misperception and to remind your industry about the importance of applying a risk-based approach with respect to this issue as well as the need to implement reasonably designed AML programs to address among other risks, the risks associated with third-party betting.
Anti-Money Laundering (“AML”) Vulnerabilities and Risk Exposure
FinCEN understands that certain organizations and individuals have been circumventing various laws related to sports betting.1 More specifically, criminals are making bets with legally operating sports books, including by using intermediaries to place bets on behalf of unidentified third parties (third-party betting). In these cases, the intermediaries rarely voluntarily disclose to the casino that a transaction is being conducted on behalf of a third party, thereby disguising the third party’s role in the transaction and obscuring the source of funds used to place the bet. This poses distinct money laundering risks for casinos.
In addition to concealing the owner and the origin of funds, third-party betting poses distinct money laundering risks for casinos because it allows criminal organizations, illegal sports books, and others located in any state, where gambling may be illegal, to place bets within states where sports betting is legal.
Law enforcement has been focusing on this activity for some time. For example, in October 2012, law enforcement closed down a significant bookmaking operation associated with a major organized crime group that had connections to Las Vegas sports books.2 Additionally, FinCEN has observed numerous instances in which casino sports books failed to identify in Currency Transaction reports (CTRs) third-parties on whose behalf transactions had been conducted.
Money laundering and Bank Secrecy Act (BSA) compliance risks associated with unidentified third party-betting may include:
- Increased money laundering exposure.
- Failure to identify and report suspicious activity.
- Failure to file accurate CTRs.
- Possible AML Compliance program deficiencies.
AML Compliance Program Requirements
Casinos subject to the BSA are required to develop and implement a compliance program reasonably designed to manage the risk of illicit activity and ensure compliance with applicable regulations. The BSA requires casinos to file reports, properly identify customers conducting transactions, and maintain appropriate records of transactions. These reports and records are highly useful in criminal, tax, or regulatory investigations or proceedings, or in the conduct of intelligence or counterintelligence activities, including analysis, to protect against international terrorism.3 Casinos’ compliance programs also must include risk-based procedures to prevent customers from circumventing BSA requirements.
The BSA requires casinos to file accurate and complete reports of each transaction in currency involving either cash in or cash out, of more than $10,000 (Currency Transaction Reports) (CTRs).4 Casinos also are required to aggregate transactions in currency (that is, treat the transactions as a single transaction) if the casino has knowledge that the transactions are conducted by or on behalf of any person and result in either cash in or cash out totaling more than $10,000 during any gaming day.5 With respect to completing a CTR, the BSA requires casinos to verify and record the name and address of the individual presenting a transaction, as well as record the identity, account number, and the social security or taxpayer identification number (if any) of any person or entity on whose behalf such transaction is conducted.6
When implementing a compliance program, a casino must consider and manage the risks associated with sports betting on behalf of third parties in order to file complete and accurate CTRs, as required by the BSA. One way that a casino can obtain information about the identity of the person on whose behalf the transaction is being conducted is to ask the person conducting the transaction whether he or she is acting for himself or herself or on behalf of another person.7 This approach may be particularly effective for casinos that may not otherwise be able to identify a third party on whose behalf a transaction is being conducted. Casinos may also implement other approaches that are best suited to their business activities and customer base, but that allow them to identify effectively those persons on whose behalf a CTR-reportable transaction is being conducted. Casinos should also consider the possibility that a person conducting a transaction may intentionally fail to disclose a third party on whose behalf the transaction is being conducted. In circumstances where a casino knows or suspects this to be the case, the casino would be required to file a SAR consistent with FinCEN’s regulations.8
Casinos should be aware that failure to identify a third party on whose behalf a transaction is conducted may constitute a violation of the casinos’ recordkeeping and reporting obligations under the BSA. In addition, this may prompt concern over the adequacy of the casino’s overall compliance program and result in potential deficiencies and rule violations. FinCEN is authorized to assess civil money penalties against a casino, card club, or any partner, director, officer, or employee of the casino for willful violations of BSA anti-money laundering program, reporting, and recordkeeping requirements, and the U.S. Department of Justice prosecutes criminal violations of the BSA and related money-laundering statutes.9
FinCEN appreciates the efforts of your organization to help maintain industry focus on the importance of the BSA, and the effort that the American Gaming Association has put into the recent release of a best practices document. FinCEN invites the AGA to share this letter with its members in advance of FinCEN placing it on our website for future reference. Please don’t hesitate to reach out to us again with any of your concerns. Your association and members are welcome to contact FinCEN’s regulatory helpline at 800-949-2732 with any questions about this letter.
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Sincerely, /s/ Jamal El-Hindi Associate Director Policy Divison
1There has been a ban on land-based sports betting in most states since the passage of the Professional and Amateur Sports Protection Act (“PASPA”) in 1992. Currently, Nevada and Delaware have legal land-based sports betting, though several other states are trying to implement legalized sports betting. Together, the PASPA, the Interstate Wire Act of 1961 (18 U.S.C. § 1084), the Travel Act of 1961 (18 U.S.C. § 1952), and the Illegal Gambling Business Act of 1970 (18 U.S.C. § 1955) prohibit sports betting between states that disallow sports betting. The Interstate Wire Act, often called the Federal Wire Act, prohibits the operation of certain types of betting businesses in the United States. The U.S. Fifth Circuit Court of Appeals has ruled that the Wire Act prohibition on the transmission of wagers applies only to sports betting. The Travel Act forbids the use of the U.S. mail, or interstate or foreign travel, for the purpose of engaging in certain specified criminal acts. The Illegal Gambling Business Act was enacted as part of the Organized Crime Control Act of 1970 and specifically aimed at syndicated gambling, that is, large-scale, illegal gambling operations that were thought to be financing organized crime.

2See FBI New York Field Office press release (February 17, 2012). Four Gambino Crime Family Members and Associates Plead Guilty in Manhattan Federal Court, http://www.fbi.gov/newyork/press-releases/2012/four-gambino-crime-family-members-and-associates-plead-guilty-in-manhattan-federal-court.
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3See 31 U.S.C. 5311.
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4See 31 CFR § 1021.311-313.
5See 31 CFR § 1021.313.
631 CFR § 1010.312.
7See FIN-1989-R005.
8A SAR is required if a casino knows, suspects, or has reason to suspect that the transaction (or a pattern of transactions of which the transaction is a part) is intended or conducted as part of a plan to violate or evade any Federal law or regulation or to avoid any transaction reporting requirement under Federal law or regulation. 31 CFR § 1021.320.
9See 31 U.S.C. 5321(a)(4) and 5324 and 31 CFR § 1010.820(e) and 31 CFR § 1010.314; see also 18 U.S.C. 1956 and 1957.
