KSA’s record €37m fine on EOD Code SRL signals tougher enforcement against illegal gambling in the Netherlands

The Dutch gambling regulator Kansspelautoriteit (KSA) has imposed a record €37m fine on EOD Code SRL for offering unlicensed gambling to players in the Netherlands. The case matters for PSPs because the regulator explicitly tied the enforcement action to payment methods, hosting, banks, and major tech companies.

1. The KSA said EOD Code SRL offered games of chance in the Netherlands without a licence through multiple websites, including Instantcasino and Skyhills. The operator had previously received a penalty payment order for the same activity, which is the sort of repeat-offence pattern regulators tend to treat as an aggravating factor rather than a warning shot.
2. According to the regulator, its employees were able to gamble on several of the company’s sites without effective measures stopping access from the Netherlands. The original probe focused on Instantcasino, but the investigation later expanded to other websites in the same network: skyhills.com, slotmonster.com, betiro.com, betblast.com, fastslots.com, goldenpanda.com, sambaslots.com, winningz.com, incognitocasino.com, foxygold.com, and luckypays.io.
3. The KSA cited several aggravating circumstances across the websites, including the lack of visible age verification and the availability of cryptocurrency and anonymous payment methods. The regulator said these payment options facilitate money laundering, which is a direct concern for acquiring and PSP risk teams evaluating exposure to gambling traffic.
4. For fines, the KSA can choose a revenue-related amount when standard fines would be disproportionate to the revenue generated from the illegal offering. In this case, it estimated that EOD Code earned more from bets placed by Dutch players and applied a higher fine based on that estimate, making this the largest penalty the KSA has issued for illegal gambling offerings to date.
5. The regulator also stressed that action against illegal offerings is not limited to administrative fines. It said enforcement involves intensive collaboration with third parties, including payment service providers, hosting parties, banks, and major tech companies, which is the part high-risk payment providers will read as a warning, not a footnote.