Within the space of a week, two trade bodies on opposite ends of Europe did something notably different from their usual advocacy playbook.
Rather than issuing another position paper on illegal gambling, they filed formal complaints – not against illegal operators, but against the payment institutions allegedly keeping them afloat…
Two complaints, one message
On 10 July, the European Gaming and Betting Association (EGBA) lodged a complaint with the Bank of Lithuania against Walletto, alleging the e-money institution had processed deposits for illegal gambling sites, based on test transactions carried out during its own investigation.
Four days later, Portugal's APAJO reported both four unlicensed operators and payment institution EuPago to the Public Prosecutor's Office, arguing EuPago had enabled illegal platforms to accept payments via familiar local rails such as MBWay and Multibanco.
Notably, APAJO says it had already flagged its concerns to the Bank of Portugal back in April 2024 – meaning the criminal complaint arrived only after more than a year of quieter engagement went, in the association's view, nowhere.
From position papers to formal complaints
The tactical shift matters.
Trade associations have long lobbied for tougher rules – EGBA alone has recently pushed for EU action on fraudulent gambling apps and warned against a proposed gambling levy. But a formal complaint, backed by an association's own investigative evidence, is a different instrument: it hands regulators a ready-made case rather than a general call to action.
The logic is straightforward. Illegal operators are often difficult to pin down; they can rebrand, relocate or hide behind opaque ownership. Payment institutions, by contrast, are typically licensed entities sitting squarely within a national regulator's jurisdiction.
For associations frustrated by the pace of enforcement, targeting the payment link is simply the more tractable pressure point – and it dovetails with a "follow the money" approach regulators in Lithuania, Finland, Sweden and the Netherlands have already begun adopting themselves.
These complaints are best understood less as endpoints and more as pressure tactics... designed to force regulators' hands and spotlight gaps that broader advocacy alone hasn't closed
Part of a broader enforcement mosaic
These complaints don't sit in isolation. They arrive alongside a January 2026 ECJ ruling opening the door to cross-border claims against individual directors of unlicensed operators, and the Gambling Commission's Section 116 review of supplier Evolution over its content reaching unlicensed platforms.
Taken together, the throughline is an expansion of who counts as accountable: not just the operator, but its directors, its suppliers – and now, its payment providers.
Trade associations appear to be positioning themselves as the connective tissue in this shift, effectively acting as private investigators and evidence-gatherers where under-resourced regulators have struggled to keep pace.
APAJO's move is particularly telling here: it already has a track record of filing criminal complaints against unlicensed operators and the influencers promoting them. Extending that playbook to a payment institution suggests associations increasingly see the entire commercial ecosystem – not just operators – as fair game.
The limits of complaint-driven enforcement
None of this guarantees results. A complaint only triggers an investigation; it doesn't compel one – and financial regulators may move slowly or inconclusively.
Payment blocking, even where enforced, can be circumvented through alternative rails or cryptocurrency. A single provider being named does little to address the deeper issue of inconsistent enforcement across card schemes and payment chains EU-wide – which is precisely why EGBA is also pushing for harmonised application of the Payment Services Directive and AML rules, not just action against Walletto alone.
Seen this way, these complaints are best understood less as endpoints and more as pressure tactics – designed to force regulators' hands and spotlight gaps that broader advocacy alone hasn't closed.
Whether that pressure translates into systemic change, or simply another isolated case, will say a great deal about how seriously Europe's financial regulators are willing to treat the payments sector as a genuine gatekeeper.
We will also be exploring the role of suppliers in combatting the illegal market in further detail. Stay tuned for the August issue of Global Gaming Insider.
EGBA estimates illegal operators accounted for 27% of European online gambling gross gaming revenue in 2025 – around €18bn ($20.6bn) – much of it dependent on access to mainstream payment channels
