Which accounts and services are needed?
Map the services rather than assuming one provider performs every function. A bank account, payment gateway, acquirer and e-money product can have different roles and restrictions.
| Function | Question |
|---|
| Operating account | How are ordinary business expenses paid? |
| Merchant processing | Which entity and transactions are approved? |
| Settlement | Where and when do net proceeds arrive? |
| Player funds | How are liabilities protected under the applicable rules? |
| Withdrawals | Who authorises and executes payments to players? |
How should a Cyprus group explain its flows?
Identify the player-facing operator and any Cyprus service, holding or IP entity. Explain intercompany payments separately from player deposits and withdrawals.
Do not route transactions through a company presented as a generic software business when it is actually receiving gambling payments. The provider application and contracts should describe the true activity and funds flow.
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What should be checked before selecting providers?
Obtain a scoped offer and identify dependencies.
- Permitted entity, licence, products and countries.
- Accepted payment methods and currencies.
- Fees, settlement timing and reserves.
- Treatment of refunds, disputes and account restrictions.
- Reporting and reconciliation data.
- Termination, migration and outstanding-liability arrangements.
How are player protection and liquidity connected?
Player-fund rules need their own legal analysis. A provider balance or separate account should not automatically be described as insolvency protection. Reconcile the actual customer liability with the relevant assets and arrangements.
Settlement delays and reserves can create liquidity pressure even when the business is profitable. Model withdrawals and accessible funds under a downside scenario. Do not use a gross processing forecast as a substitute for a cash-flow plan.
How should launch readiness be tested?
Trace a deposit, failed payment, refund, withdrawal and dispute across the player ledger, provider report and bank account. Confirm that references and amounts can be reconciled.
Test provider outages and manual escalation too. Keep finance, support and compliance responsibilities clear. The detailed onboarding, reserve, reconciliation and chargeback guides address those individual tasks; this page defines the overall architecture that connects them.
Sources and scope
- UKGC — customer-fund segregation
- Adyen — settlement reporting mechanics
- Adyen — product-specific onboarding restrictions
This guide was prepared with AI assistance using the linked sources. It provides general information and practical preparation suggestions, not a legal opinion for a particular business. No personal professional review is claimed.
Related guides
Get the right structure for your case
Book a free, no-obligation consultation. We’ll confirm the right Cyprus company + licence setup and a fixed fee for your business.