Player balances are not your money. Regulators want to see that clearly, in the bank, not just in the ledger. Getting the structure right is straightforward; getting it wrong is the kind of finding that follows a licence around.
This guide is general. Your licence conditions are specific, so check them and take advice where needed.
What the regulators are asking for
MGA. Player funds must be held separately from the operator's own funds, and the operator has to be able to show at any time that the segregated balance covers what is owed to players.
UKGC. Operators must tell customers how their funds are protected, using the Commission's rating of not protected, medium or high, and the protection they claim has to be real. Segregated accounts are the basis of a medium rating; high requires a formal arrangement such as a trust.
Other licences vary in wording, but the core is the same: keep the money apart, and be able to prove it.
The structure
- One segregated player account per licensed entity, in each currency you hold player balances in. Not one for the group. A UKGC entity and an MGA entity each need their own.
- Operating accounts alongside, for everything that is your money: revenue, supplier payments, payroll, marketing.
- Clear naming so nobody has to guess.
MT-EUR-PLAYERandMT-EUR-OPSare obviously different accounts. - A daily reconciliation of the player account balance against the player liability in your platform. If the account is short, that is the number you top up the same day.
Xace supports segregated accounts per licence and entity as standard, so this is configuration, not a workaround.
The controls that make it hold
- Sensitivity rules on the player accounts, so only the people who need to see and move those balances can. Most of the finance team does not need access.
- Approval policies on any payment out of a player account, with a low threshold and two approvers. Money should leave a player account for withdrawals and for agreed transfers, and nothing else.
- Keep it out of the sweep. If you run scheduled sweeps into a treasury hub, exclude player accounts. A sweep that pulls player money into operating funds is exactly the finding you are trying to avoid.
- Statements and exports per account, so the regulator can be shown the segregated account on its own.
What good looks like at audit
The auditor asks for the player account statement and the platform's player liability report for the same date, and the two numbers reconcile with a short list of timing differences. That is the whole test. Everything above is in service of making that a two-minute answer.
