KYC and AML

KYC Requirements for Online Gambling in Germany

How German-licensed operators identify players under the Interstate Treaty and the anti-money laundering act, and how LUGAS and OASIS checks fit in.

3 min readPart of kyc and aml

On this page
  1. How are German players identified?
  2. What does the GwG add?
  3. What does a German registration look like?
  4. How does Germany compare?
  5. Worked example: German sign-up
  6. What mistakes do operators commonly make?
  7. Checklist
  8. Frequently asked questions
  9. Sources
  10. More guides

German-licensed operators must open a player account in the player’s name before any play, identify and authenticate the player under the Interstate Treaty on Gambling 2021, and meet section 16 of the anti-money laundering act (GwG). Section 16 allows a preliminary identification from an electronic copy of an ID document, followed promptly by full identification, and limits deposits and payouts to payment accounts in the player’s name. Operators must check OASIS and register activity in LUGAS.

Key takeaways

  • A player account in the player’s name before participation (GwG 16(2)) [1].
  • Preliminary identification allowed, full identification without delay (GwG 16(8)) [1].
  • Own-name payment accounts for deposits and payouts, with a €25 / €100 small-payment exemption for deposits [1].
  • LUGAS enforces the €1,000 monthly cross-operator deposit limit [2].
  • OASIS self-exclusion must be checked before play.
§16 GwGonline gambling AML rules
€1,000default monthly deposit limit
18minimum age

How are German players identified?

German identification steps
Step Rule Source
Player account Opened in the player’s name before play [1]
Preliminary identification Electronic or postal copy of an ID document [1]
Full identification Without delay, or under gambling-law identification and authentication rules [1]
Payment account check Deposits and payouts via own-name accounts [1]
OASIS and LUGAS Self-exclusion and limit checks [2]

What does the GwG add?

Section 16 removes the usual euro threshold for customer due diligence in online gambling, so CDD applies regardless of amount, and it requires operators to notify the supervisor when they open or close payment accounts in their own name that hold player funds [1]. Payouts must carry a payment reference that makes the purpose clear.

What does a German registration look like?

  1. Verify identity and ageBefore play.
  2. Check OASISThe national player exclusion system.
  3. Register with LUGASThe cross-operator file used for limits and preventing parallel play [2].
  4. Set the monthly deposit limitCross-operator monthly limit.
  5. Link payment accountPayments only from accounts in the player’s name [1].

How does Germany compare?

Germany compared
Topic Germany Malta Great Britain Source
CDD threshold None for online gambling €2,000 in deposits Risk-based, before play for ID [1] [3]
Own-name payments Required by law Pay back to source where possible Closed loop expected [1] [4]

Worked example: German sign-up

  1. Player account created in the player’s name.
  2. Preliminary identification from an uploaded ID copy.
  3. OASIS check; LUGAS registration.
  4. Full identification completed by an approved method; deposit from own-name account.

What mistakes do operators commonly make?

Allowing play before an account exists

Prohibited by section 16(2) [1].

Third-party deposits above small limits

Breach the own-name rule [1].

Ignoring LUGAS on deposits

Breaches the cross-operator limit.

Checklist

  • Account in player’s name before play.
  • Preliminary then full identification.
  • Own-name payment checks.
  • OASIS and LUGAS checks.
  • Payout references.
  • OASIS and LUGAS checks before play.

Frequently asked questions

How do German casinos verify identity?

Through preliminary and full identification under GwG section 16 and the Interstate Treaty.

Can I deposit from a friend’s account?

Only very small amounts can be exempted; otherwise deposits must come from your own account or card.

What is LUGAS?

The GGL’s central limit and activity file.

What is OASIS?

The national self-exclusion system.

Is there a minimum deposit for KYC in Germany?

No. CDD applies to online gambling without a euro threshold.

Who regulates online gambling in Germany?

The GGL.

What is the minimum age?

18.

Why does my payout show a reference?

The law requires the payment purpose to be clear.

What is OASIS?

Germany’s national player exclusion system.

Can I play at two German operators at once?

LUGAS is designed to stop parallel play across operators.

Sources

  1. Geldwäschegesetz section 16
  2. SBC News: LUGAS and the GGL
  3. FIAU: Implementing Procedures
  4. MGA: Player Protection Directive
  5. GGL (official site)

KYC rules by market

When identity and age must be verified in eight regulated markets, and which registers apply.

Casino withdrawals in Germany

GwG section 16 own-account payouts, LUGAS, OASIS and GGL enforcement.

Germany

Payments, KYC, responsible gambling and marketing rules in Germany.

Deposit limits by market

Mandatory and default deposit limits in the UK, Netherlands, Germany, Sweden, Malta, Ontario and US states.

Self-exclusion schemes

GAMSTOP, Spelpaus, OASIS, Cruks, BetGuard, Brazil’s platform and US state lists compared.

Further reading elsewhere