US vs Europe: How Crypto Gambling Regulations Compare

Home » US vs Europe: How Crypto Gambling Regulations Compare

Two very different starting points

The United States regulates online casinos at the state level; only a handful of states currently license real-money iGaming and regulated platforms do not take cryptocurrency directly. Europe has no single EU-wide gambling licence; member states set their own gambling rules, while EU-level frameworks like MiCA and the crypto “Travel Rule” shape how payments and compliance must work.

The legal scaffolding

US online casino gambling is legal only in certain states, including Connecticut, Delaware, Michigan, New Jersey, Pennsylvania, Rhode Island and West Virginia. These regimes license operators, require geolocation, and apply strict AML/KYC standards. Offshore crypto casinos targeting the US remain illegal; enforcement actions continue (for example, Michigan’s 2025 cease-and-desists against offshore sites).

Across Europe, there is no unified gambling law. The European Commission explicitly notes that online gambling is regulated nationally, within EU law constraints interpreted by the Court of Justice of the EU. Operators must navigate country-by-country licensing, tax and advertising rules.

Crypto rails: who can touch them, and under what rules

United States. FinCEN treats many crypto businesses as money transmitters subject to the Bank Secrecy Act; its 2019 CVC guidance and related advisories apply Travel Rule obligations to covered institutions. Regulated US casinos generally do not accept crypto for wagering; regulators have confirmed as much in key markets.

European Union. The EU’s Markets in Crypto-Assets Regulation (MiCA) builds an authorization/supervision regime for crypto-asset service providers, while Regulation (EU) 2023/1113 extends “Travel Rule” data to crypto transfers. The EBA’s binding Travel Rule Guidelines apply from 30 December 2024. Together, these frameworks govern the pipes that EU-facing gambling operators and their payment partners must use when they allow crypto.

Malta example. The Malta Gaming Authority does not issue a standalone “crypto casino licence”; instead, licensed operators need prior approval under its 2023 Policy on the use of Distributed Ledger Technology to accept virtual assets or deploy on-chain components. Approvals cover the asset list, wallet/custody setup, reporting and AML controls.

AML is tightening in Europe: the rise of AMLA

The EU formally established a new Anti-Money Laundering Authority (AMLA), headquartered in Frankfurt, via Regulation (EU) 2024/1620. AMLA and the new EU AML Regulation/Directive create a single rulebook and bring direct EU-level supervision for high-risk entities, complementing MiCA and the crypto Travel Rule. Application timelines run into 2025 and beyond.

Advertising and consumer-protection: Europe’s patchwork in practice

Spain. The Supreme Court partially annulled key restrictions in Royal Decree 958/2020 on gambling advertising in April 2024, reshaping one of Europe’s strictest ad regimes; authorities and courts continue to refine what is permitted.

Netherlands. A ban on untargeted gambling ads took effect on 1 July 2023; as of 1 July 2025, sports sponsorships by gambling operators are also prohibited, with the regulator KSA enforcing at major events.

United Kingdom. Although outside the EU, the UK is part of the European market. The Gambling Commission is tightening promotions and AML expectations. New promo rules—banning mixed-product incentives and capping wagering requirements—are scheduled to come into force on 19 January 2026. UKGC also flags digital/crypto risks in AML publications.

Do regulated sites actually accept crypto?

US. State-licensed online casinos do not allow customers to bet with crypto directly. Public statements from major regulators confirm prohibitions or the absence of permissions.

Europe. It depends on the country and the operator’s specific approval. In Malta, crypto use is allowed only after MGA approval under the DLT Policy. Elsewhere in the EU, acceptance hinges on national gambling licences plus compliance with MiCA/Travel Rule and AML rules via licensed payment partners or custodians.

Enforcement reality: onshore vs offshore crypto casinos

Despite restrictions in both the US and many European markets, offshore crypto casinos have grown rapidly. 2024 gross gaming revenue was estimated at $81.4bn, driven by VPN access and lighter KYC—highlighting the ongoing channeling risk regulators are trying to address with tougher advertising and AML measures. US state regulators like Michigan have stepped up cease-and-desist orders against unlicensed sites.

Side-by-side comparison

US snapshot
• Licensing is state-by-state; iGaming legal in a limited set of states only.
• Regulated platforms do not accept crypto for wagering; payments run through approved fiat methods under BSA/AML.
• Active state enforcement against offshore sites; federal AML/Travel Rule applies to covered intermediaries.

Europe snapshot
• No single EU gambling licence; national licences govern games, RTP, taxes, ads.
• EU-level rules standardize crypto rails: MiCA for CASPs; crypto Travel Rule from 30 Dec 2024; AMLA builds an EU-wide AML rulebook/supervision layer.
• National ad/consumer rules vary widely (for example, Spain’s decree partly annulled; Netherlands ad and sponsorship bans).

Practical takeaways for players and operators

For US players, stick to state-licensed platforms and assume that any casino offering crypto wagers to US residents is offshore and unlicensed. For EU/UK players, check the site’s national licence, payment disclosures and whether crypto processing is handled by an authorized provider under MiCA/Travel Rule expectations. For operators, plan for Travel Rule messaging, robust transaction monitoring and clear exchange-rate/fee disclosures wherever crypto is in the flow.

FAQs

Is there a federal US “crypto casino” licence?
No. Online casinos are licensed at the state level; permitted states do not allow wagering directly in crypto.

Does the EU have a single licence for online casinos?
No. Gambling licences remain national; however, EU-level crypto rules (MiCA, Travel Rule) affect how compliant operators handle crypto payments.

How did 2024–2025 change compliance?
The EBA’s Travel Rule Guidelines took effect 30 December 2024; AMLA was created in 2024 to oversee a single AML rulebook, and countries like the Netherlands tightened advertising and sponsorship rules.

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