Internal KSA documents reveal banks and PSPs were central to enforcement strategy
A newly released set of internal documents shows that the Dutch Gambling Authority (Kansspelautoriteit, KSA) conducted a years‑long, largely unseen campaign to obtain financial data from banks and payment service providers (PSPs) as part of its enforcement efforts against illegal online gambling operators.
The documents, disclosed under a public‑records request (Woo 19162), reveal that between 2017 and 2022, the KSA issued multiple legally binding information demands to major financial institutions including ABN AMRO, ING, and Worldpay, as well as later compliance letters to PSPs such as Neosurf, Klarna, and MIR.
The earliest records show the regulator’s focus on Unibet, which at the time was operating in the Netherlands without a licence.
Banks ordered to provide iDEAL transaction data
Two documents dated August 24, 2018 show that ABN AMRO and ING were compelled to hand over detailed iDEAL transaction data linked to accounts associated with Unibet. The KSA demanded:
- Transaction identifiers
- Dates
- Pseudonymised customer account numbers
- Account types
- Customer dates of birth
- All relevant iDEAL payments over a period of more than a year
The banks were instructed to comply within two weeks and were explicitly prohibited from informing third parties about the request. The legal basis cited included articles 5:16–5:20 of the Dutch General Administrative Law Act (Awb), which give regulators broad powers to demand business data.
A more extensive demand was issued to Worldpay on December 7, 2018. The KSA required the company to provide:
- All contracts with the operator of Unibet.eu
- All correspondence leading to those contracts
- A list of authorised signatories
- A full overview of iDEAL transactions by Dutch residents between July and December 2018
Worldpay’s response, dated December 21, 2018, is also included in the inventory list, though partially redacted.
The documents show that the Ksa invoked its statutory powers to require unredacted disclosure and instructed Worldpay not to notify the gambling operator involved.
Earlier pressure on Dutch PSPs DialXS and Cardgate
Two letters from September 2017 show the Ksa summoning Dutch PSPs DialXS and Cardgate to an evaluation meeting related to a cooperation agreement (“convenant”). The regulator requested that both companies send different representatives due to conflicts of interest involving ongoing legal proceedings.
These early communications indicate that the Ksa viewed PSPs as a key leverage point in restricting access to unlicensed gambling sites.
The inventory list also includes November 2022 letters addressed to Neosurf, Klarna, and MIR, each labelled as “aanschrijving psp” – formal compliance notices. While the contents are partially redacted, their inclusion shows that the Ksa continued to monitor and intervene in payment channels used for gambling transactions well after the Netherlands legalised online gambling in 2021.
Ongoing focus on payment instruments
Several documents from 2022 relate to policy development around gambling‑related payment instruments, including: a memo on payment instruments (UHT), and responses to consultations on the Remote Gambling Act (KOA) payment‑instrument rules
These materials suggest that the Ksa’s enforcement efforts were accompanied by parallel work on regulatory frameworks governing how gambling payments should be handled.
