Crypto gaming brands that handle digital assets on behalf of players are no longer operating in a regulatory grey zone. As of mid-2025, regulators across the EU, UK, and several offshore jurisdictions have sharpened their expectations around custody arrangements and treasury practices, and banking partners have followed suit. Operators who cannot demonstrate clear, documented controls are finding it harder to open accounts, retain payment rails, and satisfy licensing authorities.
Why Custody Has Become a Licensing Issue
For many crypto gaming brands, custody was historically treated as a technical matter rather than a compliance one. That position is no longer sustainable. Regulators now view how an operator holds, segregates, and controls digital assets as a direct indicator of financial soundness and player fund protection. A brand that commingles player crypto balances with its own operating treasury, or that relies on a single unregulated hot wallet without documented controls, faces the same concerns a traditional operator would face if it mixed player funds with company funds.
The core regulatory question has become: can the operator demonstrate, at any point in time, that player funds are identifiable, protected, and recoverable? Answering that question requires documented custody policy, not just a working wallet setup.
Custody Structures Regulators Want to See
Regulators and licensing authorities are increasingly asking operators to present a formal custody framework. The minimum expectations in 2025 typically include:
- Segregation of player funds from operational treasury, with verifiable on-chain or custodial records that distinguish the two at all times.
- Use of a regulated or institutionally recognised custodian for cold storage of significant balances, rather than self-custody through internal key management alone.
- Multi-signature wallet controls requiring more than one authorised party to approve transfers above defined thresholds.
- Written key management procedures covering storage, access, rotation, and disaster recovery.
- Regular third-party proof-of-reserves audits, or at minimum, reconciliation reports that can be produced on regulator request.
Operators under MiCA-adjacent frameworks in the EU are also expected to align with the asset safeguarding requirements that apply to crypto-asset service providers. Even where a gaming licence does not explicitly reference MiCA, regulators are borrowing its language when evaluating applications.
What Banking Partners Are Scrutinising
Acquiring banks and EMI partners take a parallel but distinct view of treasury management. Where regulators focus on player protection and solvency, banks focus on financial crime risk and counterparty exposure. A crypto gaming brand seeking a banking relationship in 2025 should expect due diligence questions across three areas.
Source of Funds at the Treasury Level
Banks want to understand not just where individual player deposits originate but how the brand itself converts, holds, and moves crypto at the treasury level. Brands that cannot explain their crypto-to-fiat conversion process, or that use peer-to-peer exchanges without documented rationale, face immediate scrutiny. Using regulated on-ramp and off-ramp providers with their own AML programmes is now a baseline expectation.
Liquidity and Volatility Risk Controls
Holding significant unhedged crypto positions creates volatility exposure that banks treat as a financial stability risk. Operators should document how they manage exposure to price swings, whether through stablecoin conversion, hedging instruments, or defined treasury rebalancing policies. A written treasury risk policy, even a simple one, signals operational maturity to a bank's risk team.
Counterparty and Custody Provider Vetting
Banks will ask which custodians, exchanges, and wallet infrastructure providers the brand relies on. Relationships with unregulated or obscure counterparties create correspondent banking risk that most acquiring partners will not accept. Operators should maintain a documented list of their crypto service providers, including the regulatory status of each.
Practical Steps for Operators
Brands preparing for a licensing application or banking review should prioritise three immediate actions. First, commission a custody gap analysis comparing current wallet and key management practices against the standards described above. Second, formalise a treasury policy document that covers segregation, conversion, hedging, and emergency access procedures. Third, select custody and on-ramp partners whose own regulatory standing can be verified and documented.
OnlineShine works with crypto gaming operators to build and document the compliance frameworks that regulators and banking partners expect to see. A credible custody arrangement is not a competitive advantage; it is the baseline for operating in regulated markets in 2025.
