IF you must do kyc, it must be at account creation.
Actually, this is false. No one has to enforce KYC on signup or deposit.
What I'm saying is, if they HAVE to enforce KYC, and they know at some point they must, then it is onboarding that KYC should be implemented and not "surprise surprise we need to verify you" after the player decides he wants to withdraw his balance.
I think KYC shouldn't be enforced at all, but if they must because of law, actually I'm pretty sure the law states they must identify their customers whom they are taking money from. So either they have KYC or they don't. And if they do, make it clear from the beginning so that nobody is trapped.