12 March, 21:44
Some things are hard to miss. An enormous elephant in the middle of a clearing, for instance. Or billions of hryvnias draining out of Ukraine every year through licensed casinos — with the tacit acquiescence of those responsible for stopping it. But it is precisely this silence that is most striking of all.
Official statistics from the National Bank of Ukraine record a legal gambling market turnover of approximately UAH 158 billion in 2025. The difference between stakes accepted and payouts made — the Gross Gaming Revenue, or GGR — amounts to roughly UAH 56 billion. Simple arithmetic yields a margin of 30–35%. And this is where things get interesting.
An Anomaly Nobody Notices
In any developed jurisdiction — the United Kingdom, Sweden, Denmark, the United States — a standard GGR margin for casinos and bookmakers runs between 10 and 15%, while bookmakers targeting mainstream sports lines aim for 5–10%. A figure of 30–35% is not a "fat profit." It is a statistical anomaly that, under international AML standards, constitutes a self-sufficient red flag.
What does such a margin mean in practice? When significantly more money flows through the official, licensed channel than can be explained by pure gaming activity, it is a clinical sign that "non-market" transactions are being processed through a legal shell. Fictitious winnings. Schematic deposit top-ups. Laundered funds in search of a legitimate origin.
At the same time, industry participants openly acknowledge that 40–55% of real market turnover remains in the shadows, outside the licensed segment. The result is a paradoxical construction: official statistics with an anomalously inflated margin describe only the "white" portion of flows — flows that may themselves serve as legal cover for money arriving from gray and black schemes.
Cosmolot: The Art of "Returning" Billions
The specifics are even more eloquent. In its case against Cosmolot, the Bureau of Economic Security alleged that the company processed approximately UAH 4.5 billion as "returns of unused funds" — not winnings, but deposit refunds. The distinction is decisive: winnings are subject to personal income tax and a military levy, while refunds are not. According to investigators' calculations, this manipulation allowed the company to avoid paying approximately UAH 1.1 billion in taxes.
This was not an accounting error. It was an architectural decision.
"Deposit returns" are one of the oldest and simplest tricks in the classical money-laundering typology. A player deposits funds, engages in minimal play, and then withdraws money in the status of a "legitimate refund." The scheme corresponds precisely to what the FATF and the British Gambling Commission describe in their AML risk guides for online gambling: "minimal gaming activity before withdrawal, bets placed on near-certain outcomes, use of multiple accounts and drops."
Favbet and Diamond Pay: When the Intermediary Matters More Than the Casino
If Cosmolot illustrates tax evasion, the Favbet case — together with payment operator Diamond Pay — illustrates systemic capital flight.
Investigations describe Diamond Pay as an operator that processed between 70 and 90% of payments across the entire casino market. When a single intermediary controls nearly all the money flows of an industry, that is no longer a market — it is a monopoly over the gateway. And when that same gateway was helping operators with proven Russian beneficial ownership to move blocked funds worth billions of hryvnias even after their licenses had been revoked, the question of whether capital is being exported ceases to be rhetorical.
Separate materials point to systematic underreporting of the personal income tax base by Favbet and manipulation of GGR reporting, with estimated budget losses of up to UAH 2.5 billion. The company's owner, Andriy Matyukha, held a valid Russian passport at the time the business was operating. Not some Soviet-era document left over from a previous life — new identification papers issued to a citizen of the aggressor state.
The question, again, is simple: how does a Russian citizen obtain licenses in Ukraine, control billion-hryvnia transactions through Ukrainian banks, and publicly declare a "patriotic position"? The Ministry of Digital Transformation, KRAIL, the Security Service, the National Bank — all these bodies are involved in the licensing process in one way or another. Who, exactly, signed off?
The International Context: This Is Known to Everyone
To claim that the problem is hidden or non-obvious would be a lie. Online gambling ranks among the top three industries globally for AML-related fines. Research on the British market directly links digital gaming platforms to the expanding capacity of organized crime to "convert, control, and conceal" criminal proceeds. Canada's financial intelligence unit FINTRAC, the British Gambling Commission, American gaming regulators — all maintain dedicated bulletins on money-laundering schemes in online gambling.
Chinese authorities estimated the volume of funds laundered through online casinos over just nine months of 2020 at $150 billion — a sum comparable to the annual budgets of small sovereign states.
The FATF classifies gambling as a sector of inherently elevated money-laundering risk. The online format dramatically amplifies those risks through speed, anonymity, and cross-border reach. Without rigorous near-real-time transaction monitoring, without deposit and loss limits, without KYC/AML controls and independent oversight, the sector defaults into infrastructure for laundering — not merely a source of taxable revenue. This is not a hypothesis. It is the conclusion of international regulators.
Ukraine launched this sector without a single one of these safeguards in place.
The DSOM Monitoring System: Perpetually "Coming Soon"
The DSOM system, which was supposed to provide online transaction monitoring for the gambling industry, is still being "implemented." Until it arrives, the regulator has relied on blocking the domains of unlicensed sites — a useful but fundamentally insufficient measure that does nothing whatsoever about transaction flows inside licensed operators.
The mass use of drops, circumvention of KYC procedures, the practice of "deposit returns," and the practical absence of effective betting and loss limits are all officially acknowledged — by members of parliament and by investigative bodies in public statements. The problem is known. A systemic response does not exist.
By comparison: the United Kingdom, Sweden, and Denmark use a simple and transparent model — tax is levied on the operator's GGR, player winnings are not taxed individually, and in exchange a rigorous set of AML requirements is enforced: mandatory identity verification, deposit and loss limits, enhanced due-diligence triggers, centralized registers of self-excluded players, real-time integration with financial monitoring. It took Britain years of high-profile scandals and hundreds of millions of pounds in fines to reach this system. Ukraine deliberately chose to start without that hard-won experience — as if by design.
The Elephant in the Clearing and Those Who Cannot See It
Here is where the central question arises. Not "does Ukraine have a gambling laundromat" — the signs are plain and conform to every recognized international typology. But why have the Security Service of Ukraine, the Bureau of Economic Security, and the National Anti-Corruption Bureau — agencies whose explicit mandate is to track precisely these kinds of schemes — publicly failed to respond to what is impossible not to see?
The anomalously high margin against a massive shadow-market share is not insider information. It is NBU data available to any analyst. The Cosmolot case with UAH 4.5 billion in "returns" is drawn from criminal proceedings. The Diamond Pay case — involving monopolistic control over payment flows and documented links to operators with Russian beneficial owners — was covered in open-source investigative journalism. Owners holding the passports of the aggressor state who nonetheless receive licenses: verifiable by any law student with access to public registries.
If all of these facts fail to generate a systemic response from the law-enforcement apparatus, there are exactly two explanations. The first: systemic incompetence, whereby the relevant units are physically incapable of seeing what lies on the surface. The second: systemic interest, whereby seeing it would mean dismantling the very concrete financial arrangements of very specific people.
Neither explanation is acceptable for a state fighting for its existence.
Corrupt Money Seeks Laundering. Where Else Would It Go?
As control over banking transactions tightens, as ARMA's reach expands, and as public pressure mounts on traditional schemes — real estate, government bonds held through nominees, fictitious import contracts — the gambling industry remains the most technologically convenient and legally protected channel for laundering funds of corrupt origin.
The scheme is elementary in execution. Corrupt funds are deposited via a network of drops — nominal players — as gaming deposits. Minimal play activity is conducted to simulate genuine participation. Withdrawal follows as a "win" or "deposit refund" — now carrying a legally clean status. Meanwhile a payment intermediary like Diamond Pay, controlling 70–90% of market flows, becomes a genuine distribution node through which money can be moved with near-complete opacity to the regulator.
This is not speculation. It is a documented FATF typology, confirmed by the British Gambling Commission and FINTRAC. And it is precisely this typology that appears to be reproduced in Ukraine today at industrial scale.
The Architects and Their Accountability
The law legalizing gambling was advanced and passed with the active participation of specific political actors who publicly positioned themselves as the authors and drivers of the reform. The President. The relevant parliamentary leadership. The chair of the fiscal and financial committee. Their names are known.
International precedent is unambiguous. The Maltese and Philippine online gambling controversies unfolded along exactly these lines: political leaders who legalized the sector without adequate AML barriers ultimately faced accusations of having created a favorable environment for laundering — and were forced either to radically tighten the rules or to curtail parts of the market under pressure from international partners and regulators.
Proving the intent of a specific lawmaker from open-source data is not possible. But establishing the systemic mismatch between the declared goals of the "reform" and the actual design of the market is entirely possible. A market that systemically generates an anomalous margin, lacks effective monitoring, tolerates operators holding enemy-state passports, and permits billion-hryvnia "deposit returns" in lieu of taxable winnings — is either the product of gross legislative incompetence or of deliberate design serving specific beneficiaries.
The accurate formulation is this: Ukraine's gambling market, as currently architected, objectively performs the functions of tax evasion, money laundering, and capital flight — and does not impede them. By any international standard, this looks either like a conscious allowance or gross institutional negligence. Either demands not a journalistic article, but a criminal investigation.
The elephant is standing in the middle of the clearing. The only question is whether anyone in Ukraine has the courage to see it.