What happens with payment blocking by the GGL?

The Joint Gaming Authority of the States (GGL) instructs payment service providers to stop transactions to unlicensed gambling providers. Your private bank account remains fully functional. Only the individual transfer to the illegal operator is rejected. This measure enforces the Interstate Gaming Treaty 2021 and protects players from unregulated offers without disrupting general payment traffic.

What is payment blocking and how does it work technically?

The GGL uses payment blocking as its main instrument to enforce the Interstate Gaming Treaty 2021 (GlüStV 2021). The authority prohibits payment service providers from processing transactions to illegal gambling operators. This so-called financial blocking does not target the freezing of private accounts. It specifically targets the flow of funds to unlicensed platforms by instructing banks and payment providers to reject specific payments.

The Mechanism: How Banks Detect Illegal Transactions

The technical implementation of payment blocking by the GGL is based on close cooperation with payment service providers. The authority transmits lists of unauthorized operators. In response, financial institutions cross-check their transaction data. To identify these transactions, banks use specific features such as Merchant Category Codes (MCCs), which flag gambling transactions, as well as IP address checks and domain blacklists.

Critics such as the Independent State Centre for Data Protection Schleswig-Holstein (ULD) point out that a flawless distinction between legal and illegal gambling is difficult with the available data. Financial blocking often requires a change of purpose in the use of customer data, which can be problematic from a data protection perspective. Nevertheless, the GGL considers this method effective because it increases the effort for illegal operators and makes Germany a less attractive market.

Overview of Affected Payment Methods

The blocking affects almost all common digital payment methods. Traditional services such as Giropay and Paysafecard are restricted just as much as modern open banking solutions. Trustly, a Swedish payment service provider for direct transfers, must also block transactions to listed illegal operators. Klarna (formerly Sofortüberweisung) is also integrated into the GGL's blocking lists. Installment payments or instant transactions to unauthorized casinos fail as a result.

Mobile wallets such as Apple Pay/Google Pay are also not immune. Since these services often only act as a technical bridge for stored credit or debit cards, payment blocking applies here as well as soon as the recipient is identified as illegal. The GGL is working to close these loopholes, although some operators attempt to bypass the blocks via complex chains of payment services.

The Myth of Account Freezing: What Happens to My Money?

Many players falsely fear that the GGL freezes private bank accounts. This is incorrect. With payment blocking, only the individual transaction to the illegal operator is rejected. The player's private checking account remains fully operational. The funds are not confiscated; they remain in the account or are credited back in the case of an already initiated transfer.

This specific rejection does not result in negative Schufa entries. It is an administrative prohibition of the business relationship with the operator, not a credit check of the customer. The measure aims to combat illegal gambling under the GlüStV 2021 without restricting the general financial freedom of citizens. However, players should note that repeated attempts to bypass blocks may lead to further administrative measures.

Legal Basis: The Role of the GGL and the GlüStV 2021

When addressing what happens with payment blocking by the GGL, the authority relies on the Interstate Gaming Treaty 2021 to halt payment flows. The GGL issues a prohibition order against payment service providers. Failure to comply threatens high coercive fines. This measure primarily targets the interruption of the financial connection to illegal operators. The Higher Administrative Court of Saxony-Anhalt has confirmed the legality of these interventions.

GlüStV 2021 as the Basis for Financial Blocking

The Interstate Gaming Treaty 2021 (GlüStV 2021) forms the central legal foundation for combating unauthorized gambling in Germany. Specifically, Section 4(1) sentence 2 of the GlüStV authorizes supervisory authorities to prohibit not only the operation of gambling but also participation in payments related to unauthorized gambling. This provision designates payment service providers as so-called "interferers," who are legally obligated to block transactions. Additionally, Section 9(1) sentence 3 no. 5 of the GlüStV 2021 allows measures against service providers when direct action against the operator is not promising.

The GGL (Joint Gaming Authority of the States) uses this authority to enforce so-called financial blocking measures. Unlike network blocks that affect internet service providers and cut off technical access, payment blocking directly targets the economic foundation of illegal operators. Nadja Wierzejewski, President of the GGL, therefore describes payment blocking as the "sharpest sword" in the authority's arsenal, as it directly reduces the market's attractiveness for illegal operators. By blocking payment channels, the business model of these operators is sustainably disrupted without necessarily requiring a technical domain block.

Judicial Confirmation by the OVG and Federal Administrative Court

The legal validity of these measures has already been reviewed in court multiple times. The Higher Administrative Court of Saxony-Anhalt confirmed the legality of payment blocking orders in a landmark ruling. The court stated that the gaming authority makes a discretionary decision in individual cases that complies with the principle of proportionality, particularly given the high addiction potential and money laundering risk. Although a payment service provider cannot verify the origin of every payment with absolute certainty, it is obligated to request evidence of the operators' technical safeguards.

In parallel, the Federal Administrative Court is dealing with the controversial practice of network blocks, where internet service providers are asked to block IP addresses. While payment blocking is largely legally secured, the legality of IP blocks is still awaiting final clarification. This judicial differentiation shows that the GGL adapts its strategies to the respective legal situation: where network blocks are legally shaky, the authority increasingly relies on the financial leverage of payment blocking, which has been recognized as lawful by the Higher Administrative Court of Saxony-Anhalt.

Enforcement Measures: From Warnings to Coercive Fines

The enforcement of GGL orders follows a clear escalation path. Initially, a formal prohibition order is issued to the affected payment service provider or bank. This order requires the addressee to terminate the business relationship with the illegal gambling operator or to block specific transactions. Since many of these operators are located abroad, direct enforcement against the operator is difficult. Therefore, the payment channel regulated in Germany is used as a lever.

If the payment service provider fails to comply with this prohibition order, severe sanctions threaten. The GGL can impose a coercive fine based on the company's economic capacity. This high financial risk explains the high willingness of banks and payment providers to cooperate. Nadja Wierzejewski emphasizes that despite limited resources, the authority prioritizes and focuses on the most relevant illegal offers. By combining the legal basis in the GlüStV 2021 with the threat of massive coercive fines, the GGL creates an effective filter that pushes illegal gambling offers out of the German payment space.

Payment Blocking vs. Network Blocks: Differences and Synergies

When addressing what happens with payment blocking by the GGL, the authority intervenes directly in payment flows by instructing payment service providers to block transactions to illegal operators. In contrast, network blocks aim to interrupt technical access to the website via internet service providers. While payment blocking is considered a highly effective instrument that dries up the financial basis of illegal offers, the implementation of IP blocking is legally controversial and technically easier to bypass.

Network Blocks: When Access to the Website is Blocked

Network blocks, also known as IP blocking, are an enforcement tool used by the GGL when unauthorized gambling operators fail to cease operations despite a prohibition order. The authority requests internet service providers to block access to specific IP addresses or domains. However, this approach hits technical and legal limits: since IP blocking filters traffic at the network level, users can often bypass these blocks using VPNs or proxy servers.

From a regulatory perspective, enforcing network blocks is significantly more difficult than enforcing payment blocks. The Higher Administrative Court of Saxony-Anhalt and other courts have critically examined the legality of such blanket access bans, as they may be deemed disproportionate. Nadja Wierzejewski of the GGL therefore describes payment blocking as the "sharpest sword," as it cuts off the direct financial supply to illegal operators, while network blocks merely represent a hurdle that technically savvy players can easily overcome. Additionally, the GGL must weigh whether the effort for internet service providers is proportional to the protection goal in the case of network blocks, which leads to delayed implementation.

The Risk of Overblocking and Errors

A central problem in enforcing payment blocking is so-called overblocking. Since payment service providers often cannot distinguish between legal and illegal gambling transactions with absolute certainty, there is a risk that permissible payments or transactions to licensed operators abroad may also be blocked. This occurs when the technical features of a transaction, such as the Merchant Category Code, are not precise enough to fully capture the context.

Overblocking presents payment service providers with a dilemma: they must either risk violating the GGL's orders or set their filters so strictly that they lose potentially legal customers. Critics argue that the available data is often insufficient to make a flawless distinction, which can lead to false positives. For players, this means that a rejected transaction does not automatically indicate a frozen account, but is often due to an overly broad interpretation of the blocking lists by the financial service provider.

Bypass Techniques: Cloaking and Its Limits

Illegal operators are increasingly attempting to bypass blocks using technical tricks like cloaking. With cloaking, users or supervisory authorities are shown different website content than the actual, illegal gambling operation. This method aims to make it more difficult to uncover the identity of the operators behind the illegal offers, thereby delaying the enforcement of payment blocking and network blocks.

The GGL responds to cloaking and other bypass tactics by expanding its capacity to identify those responsible, even though this is laborious due to missing imprint information. Despite these technical maneuvers, payment blocking remains effective because it targets the financial transaction level regardless of the displayed website interface. As long as payment flows are identifiable, the GGL can request payment service providers to block them, thereby reducing the incentive for cloaking in the long term due to the lack of a monetary foundation.

Data Protection Concerns and Criticism of Financial Blocking

With payment blocking by the GGL, not only technical hurdles but also fundamental legal questions arise. Critics, including the ULD, complain that financial blocking deeply interferes with payment freedom and data protection. The central concern is overblocking, where payment service providers mistakenly stop legal transactions, as well as the lack of transparency for affected consumers.

ULD Statement on Interferences with Payment Freedom

The Independent State Centre for Data Protection Schleswig-Holstein (ULD) has expressed significant data protection concerns in its assessment of the regulations on financial blocking. The core of the criticism is the required data processing: to filter illegal gambling transactions, payment service providers must evaluate sensitive information such as the recipient's name, account details, and specific merchant codes. The ULD questions whether this change of purpose for stored data is compatible with data protection law. Furthermore, it is argued that the available data is often insufficient to clearly distinguish between legal and illegal gambling, leading to legal gray areas. This uncertainty burdens the GGL and the involved financial institutions, as the delimitation remains complex in individual cases.

Proportionality of Measures

The proportionality of payment blocking has been intensively reviewed by the courts. The Higher Administrative Court of Saxony-Anhalt confirmed the legality of the measures, even though so-called overblocking cannot be completely ruled out. This means that payments to legal operators abroad could also be blocked. Nevertheless, the court considered the interventions proportionate, as the GGL makes a discretionary decision in the context of combating unauthorized gambling. From a regulatory perspective, the protection of players from addiction and manipulation weighs heavier than the potential restriction of payment freedom for individual transactions. The GGL argues that while digital freedoms are of high rank, the societal mandate for prevention takes precedence.

Transparency for the Consumer

A frequent point of criticism is the lack of information for users. When a transaction is rejected, players often receive only a cryptic error message, without it becoming clear whether the reason is payment blocking by the GGL or an internal bank security check. This lack of transparency makes it difficult for consumers to exercise their rights or challenge false positives. Although the GGL is working on better clarification, in everyday life the distinction between a technical disruption and an official block often remains opaque for individual payment service provider customers. However, transparency is essential for responsible gambling to prevent loss of control.

Player and Consumer Protection: OASIS, Limits, and BzgA

In addition to payment blocking, the German gambling market is characterized by strict consumer protection measures that must be strictly implemented in licensed offers. These instruments are designed to prevent gambling addiction and protect players from financial harm.

The Blocking System OASIS

The online blocking system OASIS (Supreme State Authorities Information System for Player Blocking) is a central element of the GlüStV 2021. Licensed operators are required to check every player in OASIS before registration. If a player is blocked there, they are not allowed to play with any licensed operator in Germany. This effectively prevents players from switching from one operator to another to bypass blocks. Payment blocking complements this system by halting the flow of funds to unlicensed operators that are not connected to OASIS.

Deposit and Betting Limits

To limit financial risks, the GlüStV 2021 mandates strict limits. Players may deposit a maximum of 1,000 euros per month with licensed operators. Additionally, a betting limit of 1 euro per spin applies to online slots. These limits are technically implemented and monitored by the operators. Anyone attempting to bypass these limits by using multiple accounts or unlicensed platforms risks not only losing their money due to a lack of legal protection but also being blocked in the OASIS system.

Role of the Federal Centre for Health Education (BzgA)

The BzgA supports prevention efforts through information campaigns and counseling services. Players who feel they are losing control over their gambling behavior can seek anonymous and free counseling. The GGL consistently refers to these support services in its communications to emphasize the preventive nature of the Interstate Gaming Treaty. Payment blocking is thus only one component of a comprehensive protection concept that also includes psychosocial support and technical limits.

Impact on Players: Alternative Providers and Crypto Casinos

When the GGL blocks transactions to illegal platforms, many players wonder whether cryptocurrencies represent a loophole in the GGL's payment blocking. While the GlüStV 2021 effectively blocks traditional payment channels, operators are shifting to decentralized networks, posing new technical challenges for regulators and increasing risks for players.

Why Crypto Casinos Are Harder to Block

Do cryptocurrencies like Bitcoin offer an escape from payment blocking? Yes, technically crypto casinos bypass traditional financial controls since transactions do not run through centralized payment service providers that the GGL can compel to cooperate. Instead of bank transfers, these platforms use blockchain networks. BTC (Bitcoin) and ETH (Ethereum) enable pseudonymous deposits that are hardly traceable for banks. Stablecoins like USDT (Tether) are also frequently used because they are price-stable while still offering the advantages of crypto infrastructure.

The GGL has identified this evasion trend. Nadja Wierzejewski, Head of Department 3, describes the fight against crypto casinos as a major project for the coming years. Since the GlüStV 2021 also classifies playing with cryptocurrencies with unlicensed operators as illegal, the authority is working on new methods to close this loophole. The advantage for players is the apparent anonymity. The disadvantage is the complete absence of consumer protection that licensed operators are required to provide.

Risks of Playing Without a German License

What dangers exist for players who bypass blocking measures? Those who switch to crypto casinos leave the protective environment of the GlüStV 2021. Unlike licensed operators, platforms that only accept BTC, ETH, or USDT often lack integration with the OASIS blocking system and offer no guaranteed payouts. The GGL explicitly warns against the risks of illegal gambling, as German courts cannot be contacted in the event of a dispute.

Furthermore, the use of cryptocurrencies is volatile (except for stablecoins like USDT) and technically complex. Errors when entering the wallet address lead to the irreversible loss of funds. The GGL's payment blocking serves not only to block illegal offers but also to protect players from such unsecured environments. Anyone who bypasses the blocks acts at their own risk and waives the security standards enshrined in the GlüStV 2021.

The Future of Blocking: Further Tightening?

How does Nadja Wierzejewski view the further development of blocking instruments? The Head of Department 3 at the GGL emphasizes that payment blocking is currently the "sharpest sword" in the fight against illegal gambling. However, the authority does not rest on this success. In the future, the GGL plans to specifically close loopholes related to crypto casinos.

Nadja Wierzejewski has announced that combating crypto offers and so-called cloaking (concealing the true identity of a website) will take priority. It is expected that the GGL, in close coordination with international partners and technology providers, will find new ways to better track transactions in BTC, ETH, and USDT or directly block access to these crypto casinos. The GlüStV 2021 provides the legal framework for this, which is dynamically adjusted through administrative measures by the GGL. Players should prepare for the fact that bypassing payment blocking through cryptocurrencies will become increasingly difficult and risky.

About This Article - Editorial & Responsibility

Author: Sarah Weber - Casino Tester & Bonus Analyst Peer-reviewed by: Dr. Markus Hoffmann - Senior iGaming Compliance Analyst Last Updated: 2026-06-23.

This article on "what happens with payment blocking by the GGL" was written by Sarah Weber and peer-reviewed by Dr. Markus Hoffmann. Both regularly update the content regarding regulatory changes, license availability, and bonus terms. All statements regarding licenses, authorities, and legal frameworks refer to publicly accessible sources (GGL (Joint Gaming Authority of the States), Interstate Gaming Treaty 2021 (GlüStV 2021)).

About the Author

8+ years of casino reviews, 200+ personally tested platforms in the EU and internationally. Former member of the eCOGRA Player Advocacy Program (2018-2022). Specialization: wagering requirements, payout workflows, customer support evaluation.

About the Reviewer

12+ years in the iGaming industry, including 5 years as a compliance consultant for licensed operators under the Interstate Gaming Treaty 2021. PhD in Business Mathematics. Research focus: bonus mathematics, wager analysis, player protection systems (OASIS).

Responsible Gambling

Gambling can be addictive. If you feel you are losing control over your gambling behavior, please contact the BzgA Gambling Addiction Helpline, Check-dein-Spiel.de, or use the central blocking system (OASIS (central player blocking system)). Set personal deposit and loss limits before playing with real money. Breaks and cooldown functions provided by operators are not a sign of weakness - they are a tool for sustainable enjoyment of the game.

Legal Disclaimer

The information in this article serves exclusively editorial and comparison purposes. It does not constitute legal advice. The legal assessment of online gambling without a German license is a gray area and is subject to ongoing adjustments by the GGL (Joint Gaming Authority of the States). Players are solely responsible for complying with local regulations.

FAQ

What happens during payment blocking by the GGL and will my private bank account be blocked?

No, your private checking account will not be blocked or frozen. Payment blocking is a measure in which the GGL (Joint Gambling Authority of the States) as the regulatory authority instructs payment service providers to block transactions to certain unlicensed gambling providers. This exclusively affects the payment channels to these specific illegal platforms and has no impact on your other banking transactions or the availability of your account for other services.

Which payment methods are affected by the GGL's payment blocking?

Financial blocking primarily targets established payment channels offered by regulated payment service providers in Germany. The GGL works closely with these financial institutions to identify transactions directed at unlicensed operators. Since these providers take their compliance obligations seriously, payments to the authority's blacklist entries are technically rejected before the money leaves the player.

Is the GGL's payment blocking legally permissible?

Yes, the measure is legally anchored in the GlüStV 2021 (State Treaty on Gambling 2021), which was ratified by the 16 state parliaments. The Higher Administrative Court (OVG) of Saxony-Anhalt has already confirmed the legality of these interventions into the providers' freedom of business, as they serve to protect players and enforce the state gambling monopoly. The Federal Administrative Court is also reviewing related blocking mechanisms, with current case law supporting the GGL's authority to block illegal offerings.

What is the difference between network blocks and payment blocking?

While network blocks (IP blocking) target internet service providers to block technical access to a website, payment blocking directly targets the flow of money. With network blocks, the domain's accessibility is blocked, whereas with payment blocking, the site often remains accessible, but deposits and withdrawals are stopped by financial service providers. The GGL employs both instruments in parallel to financially and technically dry up illegal offerings.

Can I bypass payment blocking by using cryptocurrencies?

The use of crypto casinos and cryptocurrencies like Bitcoin or USDT represents a known loophole, as these decentralized payments are harder for traditional payment service providers to control. However, the GGL warns that providers without a German license offer no legal protection and often operate fraudulently. Furthermore, authorities are increasingly developing methods to identify crypto flows, and the risk of total loss is significantly higher on these unregulated platforms compared to licensed providers.

Who is responsible for enforcing payment blocking?

Primary responsibility lies with the GGL, which acts as the central supervisory authority maintaining the lists of illegal providers and issuing the blocking orders. However, the technical implementation is handled by payment service providers and banks, who are legally required to integrate these blocking lists into their compliance systems. Failure to comply threatens financial institutions with substantial fines based on their economic capacity.

What happens if my payment is incorrectly blocked (overblocking)?

The phenomenon of overblocking occurs when legitimate transactions are incorrectly identified as gambling payments due to similar merchant codes or IP addresses. In such cases, you must contact your payment service provider or bank directly to manually release or clarify the transaction. The GGL itself does not process individual customer complaints regarding incorrect blocks, as it only manages the lists of illegal providers and does not oversee the operational processing of banks.

Do I face penalties as a player if I attempt to deposit despite the blocking?

No criminal consequences or fines are provided for players themselves if they attempt to play with an unlicensed provider. Payment blocking and the associated network blocks are legally directed at the providers and the intermediary service providers, not at the consuming end customers. Nevertheless, experts such as Nadja Wierzejewski, who focuses on the impacts of gambling law, recommend playing only with licensed providers for consumer protection reasons, as deposit guarantees and complaint authorities exist there.

How can I tell if a casino is being blocked by the GGL?

You can view the current list of illegal gambling offerings directly on the GGL's website, where all providers against whom measures such as payment blocking or network blocks have been imposed are listed. Another indicator is the rejection of your payment method with a reference to "

Does payment blocking also apply to unlicensed sports betting providers?

Yes, the GlüStV 2021 covers both online casinos and sports betting, meaning unlicensed betting providers are also affected by the GGL's measures. If a sports betting provider does not hold a German license and is on the blacklist, payment channels via German payment service providers are also blocked here. The goal remains identical: protecting players from manipulation and addiction risks, as well as ensuring that only tax-compliant and legally compliant offerings participate in the market.