1. Infrastructure Is a Choice
Payment infrastructure is not neutral when it knowingly helps a harmful business model grow. Every payment session removes friction between a platform and a customer. That makes the infrastructure provider responsible for deciding which activities it is prepared to support.
PayCow will not provide payment infrastructure to a business whose success depends on repeated customer loss, impaired financial judgment, or a hidden conflict between the platform and the person using it. Growth does not justify a model that becomes more profitable as its customers become less financially secure.
2. Why Gambling Is Prohibited
Gambling products are designed around an expected customer loss. Individual customers may win, but the operator's advantage depends on the group losing more than it receives. Continuous play, rapid deposits, bonuses, near-miss mechanics and repeated prompts can turn an occasional decision into a destructive cycle.
The consequences rarely stop at a single transaction. Financial dependency can affect rent, debt, family stability, employment and mental health. For that reason, PayCow does not support casinos, sportsbooks, betting, lotteries, chance-based wagering, gambling account funding, player-balance top-ups, gambling affiliates, or software whose primary purpose is to enable those activities.
This restriction is based on the economic structure of the service. Changing the currency, placing the product on-chain, or describing it as entertainment does not change a model built on expected customer loss.
3. Why Profit From Customer Loss Is Prohibited
A fair commercial relationship gives the provider a reason to deliver value. A loss-driven relationship reverses that incentive: the provider performs better when the customer performs worse. Once revenue depends on customer failure, product design, execution, marketing and support can all be pulled in the wrong direction.
- The platform may benefit from encouraging excessive frequency, leverage or deposits.
- The customer may not understand that the platform is also the economic counterparty.
- Pricing, execution and withdrawal decisions may be influenced by a conflict the customer cannot independently observe.
- Losses can be presented as ordinary market risk even when the operator profits directly from the outcome.
PayCow therefore prohibits games, exchanges, brokers, prediction services, derivatives and similar platforms whenever the merchant takes the customer's opposing position or derives direct principal profit from customer losses. Independent fees or commissions do not excuse a separate prohibited conflict.
4. B-Book and C-Book Models
In a B-Book structure, customer exposure is internalized and the broker can become the principal counterparty to the trade. When the customer loses, the broker may retain the economic benefit. That is a direct conflict of interest and is strictly prohibited on PayCow.
C-Book, hybrid-book, risk-managed execution and other proprietary labels are also prohibited when they internalize customer risk, selectively route orders for the operator's benefit, or otherwise allow the platform to profit materially from customer losses. A new name does not change the underlying economics.
PayCow evaluates how orders and losses are handled in practice. Marketing language, dashboard labels and contractual disclaimers cannot turn an internalized loss model into an acceptable one.
5. A-Book Claims Require Evidence
An A-Book broker may be considered only when customer orders are genuinely routed to independent external liquidity providers or regulated execution venues and the broker does not take the customer's opposing principal position.
The merchant must be able to prove that structure. PayCow may request regulatory licenses, liquidity-provider agreements, order-routing records, execution reports, audited statements and other independently verifiable material. Screenshots, marketing claims and a self-assigned “A-Book” label are not sufficient.
If the evidence is incomplete, contradictory, withheld or cannot establish genuine external execution, PayCow will treat the model as ineligible. Access may be refused, suspended or permanently revoked.
6. Non-Custodial Does Not Mean Unaccountable
PayCow does not hold merchant funds or control customer wallets. Payments settle directly to a merchant's configured external address. That architecture reduces custody risk, but it does not remove our responsibility to control access to PayCow software, APIs, monitoring and hosted checkout services.
Decentralized settlement should give legitimate businesses greater control over their money. It should not be used as a shield for an operator that hides conflicts, bypasses public safeguards or scales a business around financial dependency.
7. Review and Enforcement
PayCow may review merchant-provided documents, public marketing, configured domains, payment-session metadata, webhook delivery records and other information relevant to policy enforcement. Where a broker or platform claims external execution, PayCow may require evidence sufficient to trace how customer orders are routed and how the merchant earns revenue.
Misrepresentation, refusal to provide requested evidence, concealed counterparties or a material conflict between stated and actual operations may result in immediate suspension or permanent loss of access. Because PayCow is non-custodial, enforcement disables PayCow services; it does not seize funds already settled to an external wallet.
8. Reporting a Concern
Customers, employees, partners and members of the public may report suspected gambling, B-Book or C-Book execution, concealed dealing-desk activity, or any platform believed to profit directly from customer losses. Reports may be sent to [email protected] with the relevant domain, transaction reference and supporting material.
This statement explains the principles behind our restrictions. Binding eligibility and enforcement requirements are set out in the PayCow Acceptable Use Policy.