The bank asks where the money came from: documenting casino winnings

A larger casino withdrawal has reached the current account, and a few days later the bank gets in touch: it wants to know where the money came from. In Austrian forums this comes up again and again as “Mittelherkunftsnachweis”, proof of the source of funds. The overview of withdrawal problems sorts pending, cancelled and blocked withdrawals by status and cause; this page covers the step after that, when the money has left the casino and the bank asks questions.

Anyone in this situation who considers moving a casino withdrawal to a different account runs into the same question about the source of funds. The sections below show what the bank relies on, which documents players submitted, what HellSpin, Verde Casino, Nomini, Izzi Casino and Starda Casino require themselves, what happens when an account is terminated and what role § 52 GSpG plays.

I

Why the bank asks: due diligence under the FM-GwG

The enquiry follows from the Austrian anti-money laundering act for financial markets (FM-GwG). Under § 6 (1) no. 1 FM-GwG, due diligence includes establishing and verifying the customer's identity on the basis of documents or independent data.

For a casino withdrawal, two more provisions matter. § 6 (1) no. 4 FM-GwG obliges credit institutions to obtain and verify information about the source of the funds used. This can include occupation or business activity, income or general financial circumstances. § 6 (1) no. 6 FM-GwG requires ongoing monitoring of the business relationship and of transactions, including the source of funds where necessary. Transactions have to match what the bank knows about the customer, their business and their risk profile.

An incoming payment well above the known salary that comes from a gambling operator or a crypto exchange does not fit that profile without explanation. That is when the bank asks. § 7 (1) FM-GwG adds that identity and source of funds must be checked before a business relationship is established. Opening a new account just for casino withdrawals therefore leads to the same check at the new bank.

The provisions examined do not set a fixed amount. One Austrian forum post says banks ask about “alles über 10k”, everything over 10k; that is a player's view, not a rule. Another player reports that Erste Bank asked for proof of source of funds because of “ca. 25k casino auszahlungen” within four months.

Records also matter outside the bank. In a legal principle of the Supreme Administrative Court (VwGH 90/13/0075 of 23.02.1994), gambling winnings that had not been proven were not accepted in a tax procedure as an explanation for how a household and assets were financed.

II

What evidence players submit

What the bank accepts is its own decision. Reports from players in Austria show which documents were requested.

One player whose bank asked for proof of source of funds for a five-figure win from a crypto casino asked whether it is enough to submit the casino's records of winnings and withdrawals. He meant statements from the player account plus the transactions of the crypto exchange through which the money reached his current account.

The replies focused on a point many underestimate: the bank checks “die ganze Kette ab deiner ersten EUR-Einzahlung bis zu der Auszahlung”, the whole chain from the first euro deposit to the withdrawal. The evidence should show where the money for the first deposit came from, how it went into the casino and how the winnings came back. With crypto, wallet addresses and exchange statements are added; what that chain looks like for Crypto withdrawals and what banks ask there is covered on its own page.

Two follow-up questions stay open in the forums. One player asks whether winnings from an unlicensed crypto casino are not reason enough for a refusal. The player with roughly 25k wants to know whether this also applies to crypto casinos. The bank decides case by case.

One piece of advice concerns timing: a large withdrawal should have been discussed with the bank or account manager beforehand. Announcing the payment and having the documents ready answers the question before it is asked.

The tax office comes up too. One user warns that the bank may report it to the tax office; another asks where the idea of 27.5 % tax on winnings comes from. A rate of this size is documented only for crypto: the Ministry of Finance (BMF) has taxed current income and price gains from cryptocurrencies at 27.5 percent since 1 March 2022. For the tax treatment of players' casino winnings there is no information from a primary source.

III

Records from the casino: statements, transaction list, support

The documents the bank wants resemble those the casinos request during verification. All five ask for an identity document; at HellSpin, Izzi Casino and Starda Casino proof of address and proof of deposit are part of it. On the payment method it gets specific: Izzi asks for proof of ownership of the payment method, Starda for proof of the payment method, Verde for a photo of the payment card.

There is a mirror effect. Verde Casino may ask for a bank statement or employer's letter, Nomini for transaction histories of the payment methods (bank and card statements) and proof of ownership. The casino asks about the source of the deposit, the bank later about the source of the withdrawal. Which documents are due when is shown on the page about verification before a withdrawal for all five operators.

Whether a casino issues its own confirmation of winnings or withdrawals is not stated in the available terms: no information. The route is support. HellSpin offers live chat 24/7, e-mail and a contact form, no phone. Verde Casino and Nomini offer live chat 24/7 and e-mail; Izzi Casino offers live chat and e-mail around the clock. Starda Casino has live chat 24/7 and e-mail; on phone support the sources differ: according to the operator there is a callback or phone support, according to LCB no direct phone support. An e-mail request has the advantage that the answer exists as a document.

Booking dates help with the chain too. The bank transfer withdrawal time is 5-9 days at HellSpin, 1–7 days at Verde Casino (according to AskGamblers), 1–5 days according to AskGamblers or 3–5 working days according to LCB at Nomini, 3–5 days at Izzi Casino and 0–5 days at Starda Casino. Request date, receipt date and the transaction list from the player account make the match easier. If the withdrawal already fails at the casino, for example over missing documents, the page on withdrawal declined explains the most common reasons according to the casino terms.

IV

When the bank closes the account

The toughest reaction is ending the business relationship. A legal basis for this, for example in bank terms, has not been researched here; there are only players' reports.

Those reports are clear. If the money is transferred to an Austrian account, the bank can terminate the account contract, one user writes about winnings from casinos without an Austrian licence. Another says banks already block people over normal crypto trades and would rather end the relationship. Banks are named as well: “Raiffeisen und Volksbank sind zb extrem lästig bei Crypto”, Raiffeisen and Volksbank are very difficult about crypto.

The follow-up question is which account to use instead. A bank account in someone else's name does not fit the payment method checks: Izzi asks for proof of ownership of the payment method, Verde for a photo of the payment card.

Which routes exist besides bank transfer, namely card, e-wallet and crypto, and which records each involves is shown in the overview of withdrawal methods for players from Austria. PayPal is not listed at any of the five casinos.

One mistake is avoidable: closing the player account with a balance because the bank is nervous. Nomini only allows closure with no remaining balance and no pending withdrawals; closing with a balance means losing it. Verde Casino pays nothing out after deactivation. According to LCB's analysis of the terms, Starda Casino may close accounts at its discretion and then refunds the balance. For HellSpin and Izzi Casino the terms give no information on remaining balances at closure.

V

§ 52 GSpG and the planned payment blocking (RV 594 d.B., draft)

The banks' caution also has a gambling-law background. Under § 3 GSpG, gambling is reserved to the federal state; in Austria online casino games are offered only by win2day of Österreichische Lotterien. § 31c GSpG requires licence holders to identify and assess money laundering risks under § 4 FM-GwG.

For banks, § 52 (1) GSpG is central. It penalises a credit institution that knowingly forwards a player's payment to operators of prohibited gambling. For the individual player, the BMF refers to § 168 (2) StGB: the ordinary player faces no court penalty unless playing commercially.

An amendment pending as government bill 594 d.B. in the Finance Committee is meant to tighten this. According to the bill, payment blocking for prohibited gambling is planned in a new § 56e GSpG, scheduled from 31.12.2026. It has not been passed, and deliberations have not started. How the monopoly, foreign licences and payment blocking fit together is explained on the page about the legal situation in Austria in more detail.