The Ukrainian online gambling market demonstrates steady revenue growth among legal operators, while the illegal segment continues to operate around regulations through complex financial schemes. According to financial reporting cited in the investigation by the YouTube project "3na4", online casino revenues reached 55.5 billion hryvnias in 2023 and 55.6 billion hryvnias in 2024. Meanwhile, according to KANTAR estimates, the illegal gambling market in Ukraine has grown to 56.7% of the total sector volume. The authors of the investigation, published by RBC-Ukraine, traced payment chains of illegal networks, analyzed international jurisdictions through which operators operate, and recorded criminal proceedings against the former leadership of the regulator.
From Prohibition to Legalization: 16 Years of Market Transformation
The history of the Ukrainian gambling business after 2009, when casino activities were banned, went through 11 years in the complete shadows. In 2020, gambling was re-legalized, and the Commission for the Regulation of Gambling and Lotteries (KRAIL) was created to control the industry. However, the institution did not survive a series of corruption scandals and was liquidated. It was replaced by a new regulator, the PlayCity agency, which, according to the investigation, was integrated in 2025 into a management system associated with the Ministry of Digital Transformation. The transfer of responsibility for the gambling sector to the ministerial level has become one of the key management decisions of recent years, yet, as analysis shows, it raises questions about a clear distribution of powers.
Infrastructure of the Illegal Segment: Drops, Cryptocurrencies, and Thousands of SIM Cards
The journalists of "3na4" paid special attention to the operational mechanisms of illegal operators. To conduct payments, such networks use straw men — so-called "drops", cryptocurrency instruments, and numerous bank accounts. Advertising campaigns for illegal platforms are distributed, in particular, via Telegram channels. The scale of individual networks is illustrated by the results of law enforcement operations mentioned in the investigation: one operator managed 450 bank accounts from a single phone, and around 5,000 SIM cards were seized during searches. According to the author of the investigation, statutory fines are disproportionate to the incomes of such operators: the maximum fine for organizing an illegal casino is 850 thousand hryvnias, whereas a Kyiv network associated with former police officers earned about 500 thousand hryvnias per day — meaning the fine covered less than two days of their revenue.
Curaçao as a Jurisdiction: 124 Companies with Ukrainian Capital
A separate area of the investigation is the international structures through which online casino operators work. An analysis of data leaks from the island of Curaçao revealed a significant presence of Ukrainian citizens among the owners of gambling companies: 124 companies, which, according to the journalist, makes Ukraine the country whose citizens rank first in the world among casino owners on this island. Some operators, according to the investigation, continue to work through international structures and use foreign domains despite restrictions in force in Ukraine. This creates additional difficulty for law enforcement agencies, as the jurisdictional perimeter of such operations extends beyond national borders.
Criminal Cases Against Former KRAIL Leadership and Questions for Law Enforcement
The investigation mentions criminal proceedings against the former leadership of KRAIL. According to NABU, the former head of the commission is accused of facilitating the activities of an online casino associated with the aggressor state. Another member of the same commission figures in a case regarding 90 thousand dollars related to undue benefits in assisting to obtain permits and licenses for gambling activities; the indictment against him has been sent to court. The journalists also draw attention to potential ties between illegal gaming networks and law enforcement representatives who, according to the prosecution, systematically received funds for failing to shut down casinos. These episodes form a picture in which the regulatory body and law enforcement structures act simultaneously as controllers and as potentially involved in a conflict of interest.
Distribution of Responsibility: Resolution No. 924 and the Ministry of Digital Transformation's Position
The author of the investigation records a managerial conflict regarding who exactly at the government level is responsible for the gambling sector. Cabinet of Ministers Resolution No. 924 of August 19, 2022, included the organization and holding of gambling, as well as the issuance and holding of lotteries, in the list of issues supervised by Vice Prime Minister for Innovation, Development of Education, Science and Technologies, Minister of Digital Transformation Mykhailo Fedorov. In 2025, through a series of government decisions, the gambling sector was transferred to the Ministry of Digital Transformation, and PlayCity began operating within the management system associated with this agency. However, in June 2025, the Ministry of Digital Transformation publicly stated that Minister Fedorov was not responsible for this sphere, and Resolution No. 924 defined a different scope of powers. Thus, a discrepancy exists between the text of the regulatory act and the public position of the agency, which, according to the investigation's logic, complicates accountability for the state of the industry.
