Can cross-sector coordination help Poland tackle elusive illegal operators?

Poland is stepping up efforts to tackle illegal online gambling by targeting the financial infrastructure. Regulators, payment providers and industry stakeholders are increasingly turning to transaction monitoring, artificial intelligence and cross-sector cooperation.  

The country’s dominant mobile payment system, BLIK, will block transactions linked to illegal gambling websites from 1 September, while the financial regulator has identified weaknesses in the payment system that could require further regulatory intervention. Furthermore, experts from Totalizator Sportowy and the Polish Bank Association are calling for greater cooperation. 

This approach is in line with trends across other jurisdictions. Across Europe, regulatory and industry bodies have increasingly focused on disrupting payment channels used by unlicensed operators, reflecting a broader “follow the money” enforcement strategy. 

Can a coordinated approach strengthen financial enforcement? 

In June, experts from Totalizator Sportowy, the Polish Bank Association and the National Clearing House called for a new approach to tackling illegal online gambling. This includes a focus on financial data analysis, artificial intelligence and stronger cross-sector cooperation. 

A discussion between Totalizator Sportowy and financial institutions highlighted AI as a potential tool, particularly as the growth of instant payments has reduced the time available for risk analysis. Wojciech Pantkowski, Vice President of the National Clearing House, noted that transactions may need to be assessed within as little as 10 seconds. 

Speaking exclusively to Global Gaming Insider, Marek Plota, an online gaming legal expert, said real-time blocking is ideal but not always technically feasible, while retrospective analysis remains highly valuable. 

Plota said the main challenge is not a lack of legal tools but different priorities among stakeholders. Regulators, Totalizator Sportowy and licensed bookmakers want to reduce illegal gambling, while banks and payment institutions face additional compliance costs, technological investment and potential revenue losses. 

Nevertheless, Plota noted that cooperation between Totalizator Sportowy and representatives of the licensed betting sector has already prompted a visible regulatory response, including warnings issued to the payment market. 

According to Plota, financial restrictions are harder for illegal operators to bypass than DNS blocking because they directly affect their ability to process deposits and withdrawals.  

However, operators remain highly adaptive, with crypto wallets, third-party processors and anonymised payment methods still difficult to police. While AI and cross-sector cooperation will not eliminate the black market, they can create friction, increase operational costs and reduce conversion. 

BLIK to block illegal gambling transactions 

Polish mobile payment system BLIK will begin blocking transactions linked to illegal gambling websites from 1 September, following regulatory approval from the President of the National Bank of Poland. 

The new mechanism, announced by BLIK operator Polish Payment Standard (PSP), will check whether the domain initiating a transaction appears on the Ministry of Finance’s register of websites operating in breach of Poland’s Gambling Act. If a match is found, the transaction will be blocked. 

According to PSP, the system will apply to payments processed by both domestic and foreign payment agents, extending the reach of the controls beyond Poland’s borders. The verification process will be enabled through an API connection between the BLIK payment scheme and the Ministry of Finance’s register of prohibited gambling domains. 

BLIK is Poland’s dominant mobile payment system. It enables users to make instant payments online and in retail stores primarily using their bank's mobile application. In 2025, BLIK users completed a total of 2.9 bn transactions worth PLN 441.5bn ($118.5bn). Number of active users at the end of December was 20.7 million. 

Given BLIK’s large user base and convenience, the new controls could significantly disrupt payment access for average players gambling with illegal operators and create additional friction for operators. However, determined players will adapt to alternative payment routes. 

Are ‘small payment institutions’ a weak point?  

Last week, Poland’s Financial Supervision Authority (KNF) appealed to the Ministry of Finance, calling for small payment institutions (MIPs) to be abolished. KNF argues that the lighter regulatory regime is being exploited for high-risk activities, including illegal gambling. 

MIPs are companies offering services such as e-wallets, payment apps and money transfers. Introduced in 2018, they provide a less formalised alternative to fully licensed domestic payment institutions. 

The KNF has proposed an 18-month transition period for MIPs to wind down their activities unless they apply to become fully licensed national payment institutions. The regulator claims the MIP framework has failed to deliver its original purpose of supporting innovative start-ups and is instead being used to create shell companies and entities with limited genuine payment activity. 

The KNF says MIPs are frequently linked to high-risk jurisdictions, including Russia and Belarus, and are used to process payments for high-risk sectors such as illegal gambling and cryptocurrency trading. 

The concerns highlight what appears to be a broader structural challenge within Poland’s financial system, with the regulator identifying weaknesses that could require further regulatory intervention. 

Totalizator Sportowy expands cooperation 

Totalizator Sportowy recently announced plans to cooperate with the Border Guard Academy in Koszalin to share expertise on national security and violations of Poland’s Gambling Act, including illegal online gambling.  

The cooperation aims to strengthen the Border Guard’s analytical and IT capabilities for detecting potential violations and improving methods used to identify illegal operations. 

The agreement is the latest step in the operator’s wider efforts to strengthen cooperation across sectors. In June, the company signed a letter of intent with the Credit Information Bureau (BIK) to promote responsible gambling, financial security and ethical data management. Earlier in February, Totalizator Sportowy and the Polish police signed a letter of intent aimed at strengthening cooperation in the fight against illegal gambling. 

Overall, Totalizator Sportowy’s recent initiatives reflect the growing importance of data and knowledge sharing in tackling the black market.  

Can even a highly coordinated approach have limits? 

Overall, Poland is taking a more coordinated approach to tackling illegal online gambling, with greater attention turning to the financial channels that sustain the market. 

What Polish authorities and industry stakeholders seem to recognise is that no institution alone can effectively address the increasingly complex and adaptive illegal market. The approach has to be holistic, based on knowledge and information sharing, as well as coordinated. 

Even then, enforcement has its limitations due to the sophistication of the black market. But this is a problem every market faces. Poland is, proactively, trying to do something about it. 

Raising the cost of operating for unlicensed operators and making them less convenient for regular and less determined players could have a significantly positive effect on channelisation. These developments, therefore, still represent a ‘gigantic step in the right direction.’ 

The challenge will be turning all these plans into action. Ultimately, long-term disruption will depend on maintaining momentum and adapting the cooperative approach as operators find new ways to bypass controls. 

Certainly, many across Europe will have their eyes on Poland, to see just how effective this cross-sector collaboration will be.