Compliance Updates
Ukraine’s Evolving Gambling Landscape: Insights from the Panel of European Gaming Congress in Warsaw
The panel discussion last week, at the European Gaming Congress made me feel inspired to contemplate on critical facets of Ukraine’s burgeoning gambling industry, positioning the nation as an appealing prospect for Western European investors. Although unique challenges, including historical financial corruption and external pressures, exist, Ukraine’s European identity makes it an attractive hub for investment. As the country grapples with ongoing conflict, it must simultaneously address customary market concerns such as safeguarding against Russian interference and protecting the personal data of its citizens.
A striking parallel emerged between Ukraine’s gambling landscape and the realm of cryptocurrencies, where combating money laundering and terrorist financing poses significant challenges. The National Bank, equipped with the capacity to monitor financial flows, plays a pivotal role, in conjunction with law enforcement agencies. A comprehensive strategy to combat mis-selling and gray schemes is being executed by the National Bank of Ukraine, alongside the Commission and the Ministry of Finance, resulting in the revocation of licenses, particularly among operators with Russian ties. Comparable license revocations have occurred in several European nations that have issued cryptocurrency licenses.
However, amid the ongoing struggle against these challenges, errors have emerged, exemplified by the imposition of sanctions on prominent Ukrainian industry leaders like Parimatch and Pokermatch. These sanctions have not only significantly impacted the legal gambling sector but have also cast a shadow of caution over Western investors. Notably, the President’s directive to the Cabinet of Ministers, prompted by a citizen petition with 25,000 signatures, seeks to investigate the circumstances leading to the inclusion of Parimatch in the sanctions list of the National Security and Defense Council.
In the wake of the Parimatch case, it’s worth noting that the Cosmolot brand has also recently faced heightened scrutiny, with law enforcement agencies conducting searches and investigations, further emphasizing the need for a robust law enforcement process. Ukrainian Gambling Council, representing 80% of licensed gambling operators, committed to serving its members by actively working on player protection, advertising regulation, and acting as a valuable business ombudsman for the industry, contributing to a more secure and transparent gambling landscape in Ukraine.
As technical impediments are surmounted, the regulatory body demonstrates its efficiency. Critical issues, such as streamlining market access through license issuance, promoting responsible gambling, stricter advertisement rules, and reinvigorating investments, are coming to the fore.
Once the security concerns are addressed, Ukraine is poised to unleash pent-up demand in its gambling sector. This situation will spur investors to contemplate their entry into the market, whether through direct investment, partnerships, or mergers and acquisitions, underlining the evolving landscape of opportunities in Ukraine’s vibrant gambling industry.
Article by Viktoriya Zakrevskaya, Founding Member and Deputy Chairwoman for Communications, Ukrainian Gambling Council
Viktoriya was a speaker at the European Gaming Congress by Hipther, that took place on 31 October at the InterContinental Warsaw. She discussed the emerging Ukrainian iGaming market at the Panel “The Greek Odyssey, La Dolce Vita, La Fiesta Española, The Ukrainian Spirit, and The Portuguese Fado”.
Compliance Updates
Why licensing will always be about jurisdiction, not harmonisation
This article is an opinion piece by Lee Hills, CEO of leading iGaming regulatory advisory service SolutionsHub.
For years, operators have built cross-border strategies on the assumption that European gambling regulation would gradually move closer together. It made commercial sense to think that way. A single market, a single set of rules, a single compliance framework. Less friction, lower cost, cleaner structure.
Instead, the opposite has happened.
For the past decade, regulation has moved towards greater national control. The jurisdictions that matter most to iGaming operators have each gone their own way, on their own terms and at their own pace. That assumption was not just wrong. For the operators who built strategies around it, it has become commercially dangerous.
The myth of pan-European harmonisation
The European Commission does not have a direct mandate to regulate gambling at a pan-European level. It never has. What it can do is put pressure on the areas around gambling, whether that’s state aid, freedom of services, data protection or financial crime.
But every time a member state has been challenged on its gambling framework, the outcome has been the same. Sovereignty wins.
Germany is the clearest warning sign. Malta-licensed operators once treated EU market access as a question of legal argument and commercial risk appetite. German courts have treated it far more simply. If gambling was offered in Germany without the required German permission, German law applies. The later dispute around Malta’s Bill 55 only sharpened the point. Malta sought to protect its licensed operators from certain foreign judgments. Germany and other member states continued to assert their own consumer protection and public policy rules.
By now, it should be clear enough that gambling regulation is not moving away from national control.
What matters is whether operators have built for that reality, or whether they are still pricing risk as if Europe will eventually fall into line.
What sovereignty actually means in practice
For operators, sovereignty is a commercial reality. It has direct consequences for every operator building across multiple markets.
In recent years, the focus has moved firmly to where the player is, not where the licence sits. The legal tensions surrounding Malta’s Bill 55 have made that principle hard to ignore. But the principle itself is not new. It has been quietly reshaping enforcement, banking relationships and payment processing for years.
For operators, this means one thing above all others. A licence in a well-regarded jurisdiction does not automatically protect you from regulatory exposure in the markets where your players actually are. Governance, compliance, and oversight must follow the player. In practice, that is now the central regulatory reality for any operator building across multiple markets. It cannot stop at the edge of the licensing jurisdiction.
Take an operator running on an offshore licence, taking revenue from a market that expects local authorisation. The first call usually comes from the bank, the payment provider or the platform partner, asking why revenue from that territory should be treated as acceptable. The answer cannot simply be that “we are licensed elsewhere.”
They have to make the case for that specific market. The controls have to hold up there, the local position has to be explainable, and the activity has to be justifiable where the players actually are. That is sovereignty in practice. The player’s jurisdiction is now where much of the commercial and regulatory exposure exists.
The structure that reflects this reality is the hub-and-spoke model. Operators are building this way because regulation is now fragmented market by market. The centre of the structure should be a Tier 1 jurisdiction. This is where governance, risk and strategic decisions are managed. Around that, market-specific licences are held in ring-fenced subsidiaries. Risk is contained within each spoke. Revenue recognised within appropriately licensed entities.
Commercially, it makes sense. More importantly, it reflects how regulation actually works, because every market still needs its own compliance framework.
The licence arbitrage illusion
For a long time, the gap between Tier 1 and Tier 2 licensing was manageable. A lighter-touch jurisdiction offered speed to market, lower cost and operational flexibility. Banks and payment providers asked fewer questions. Counterparties were willing to work with different licences as long as the basics were in place.
That space is shrinking.
Pressure is now coming from all directions. Banks and payment providers are no longer comfortable relying on the licence alone. They are looking at the governance behind it, the compliance culture, the ownership structure and the reputational exposure. Institutional partners are asking harder questions. The licences that were once “good enough” to unlock commercial relationships are increasingly being scrutinised in ways they were not before.
Game studios, platform providers and operators can still launch quickly through a Tier 2 structure, but the friction increases when they try to scale. Larger aggregators, regulated operators, banks and payment partners are now asking more questions about where the business is controlled, where revenue is coming from, who provides oversight, and whether the licence genuinely supports the markets being targeted.
In some cases, the issue is not whether a Tier 2 licence allows the relationship to happen at all. The issue is friction. Onboarding takes longer, the pool of available partners narrows, and extra conditions appear before revenue can move. That is where the commercial pressure is building. A licence may still get a business live, but that does not always mean it gets properly banked, distributed or supported for long-term growth.
Tier 2 licences still have a role to play. What is changing is the assumption that they offer long-term protection. In many cases, the underlying exposure is simply being deferred rather than removed.
What this means for conference season
As the European conference season accelerates through early summer, the industry will gather to discuss growth, technology and market opportunities. Yet behind much of that conversation is a more practical challenge. How do operators build for the long term when the regulatory picture continues to shift from market to market?
The answer lies less in the licence itself and more in the structure behind it.
Stop treating licensing as a badge-shopping exercise. The question is which markets you need durable access to, and what structure will still hold up when banks, payment providers, regulators and institutional partners start asking harder questions. This means building a hub-and-spoke strategy from the outset. A credible hub for governance and oversight, with local spokes added where player location, revenue, regulation or commercial counterparties justify them.
The businesses getting ahead here are not treating licensing as a shortcut exercise. They have recognised that gambling sovereignty lies with individual markets and regulators, and have built accordingly rather than assuming a cross-border structure will solve everything indefinitely.
Price matters, but it should not be driving the decision. What matters more is which structure gives you durable access to the markets you actually want to be in.
The operators who understand sovereignty will be the ones best placed to scale in the markets that matter.
The post Why licensing will always be about jurisdiction, not harmonisation appeared first on EE Gaming | Global iGaming & Tech Intelligence Hub.
Anti-Money Laundering Act
Denmark: Gambling Operators’ Obligation to Assess the Risk of New Technology Before Launch
According to Section 7(1) of the Anti‑Money Laundering Act, gambling operators are required to identify and assess the risk that they may be misused for money laundering. The risk assessment must be based on the operator’s business model and must cover risk factors associated with customers, products, services and transactions, as well as delivery channels and countries or geographical areas.
The Danish Gambling Authority points out that this obligation means that any new technology used by a gambling operator must be risk‑assessed before it is launched, ensuring that no part of the operator’s business remains unassessed. New technology could, for example, include the introduction of new games or new payment solutions. The introduction of new technology therefore constitutes a change to the operator’s business model, which requires an update of the risk assessment.
When launching a new game product or other technology with which the operator has no prior experience, the operator must investigate whether relevant sources exist that can support the risk assessment.
The post Denmark: Gambling Operators’ Obligation to Assess the Risk of New Technology Before Launch appeared first on EE Gaming | Global iGaming & Tech Intelligence Hub.
Brazilian License
Groove Secures Pivotal Brazilian License, Cementing LATAM Expansion
Platform pioneer unlocks one of the world’s most dynamic iGaming markets, offering operators and providers a seamless, compliant gateway to millions of new players.
Groove, the award-winning iGaming aggregation platform, has today announced a monumental leap in its global expansion strategy with the official granting of its license to operate in Brazil.
This landmark regulatory approval marks a decisive moment in Groove’s strategic blueprint for Latin America, a vision further reinforced by the significant strengthening of its established and fully regulated infrastructure in Argentina. Together, these developments create an unrivalled dual-hub strategy, positioning Groove as the definitive gateway to the continent.
This hard-won license provides a fully compliant and powerful conduit for Groove’s partners to engage a market on the cusp of historic growth. For operators, it translates to a frictionless, single-integration pathway for capturing market share in this coveted region. They can now leverage Groove’s robust platform to deploy a fully localised and compliant casino offering at unparalleled speed, complete with curated game portfolios tailored to local preferences, integrated local payment processing, and bespoke marketing tools designed to captivate Latin American players. This eliminates years of complex regulatory legwork, allowing partners to go to market in a matter of weeks, not years.
For game studios and content providers, the Brazilian license acts as a direct and streamlined conduit to a vast new audience. Groove offers a managed route to market, taking on the heavy burden of complex regulatory technical standards and certification processes. This allows creators to focus on their core mission of developing world-class entertainment, secure in the knowledge that their content will be efficiently placed in front of a massive, engaged audience through a trusted and fully compliant pipeline.
Rachel Tourgeman, Head of Partnerships at Groove, emphasised the transformative nature of this development. “The green light in Brazil is more than a license; it’s a key that unlocks a kingdom of opportunity for our partners. We’ve built a platform capable of not just entering, but driving in regulated markets.”
Tourgeman put the new license in perspective, saying: “Operators can now immediately tap into Brazil’s immense potential, while providers gain a trusted pipeline to a passionate new player base. This is a definitive moment that accelerates the entire LATAM iGaming ecosystem.”
This strategic expansion is a direct reflection of Groove’s commitment to being the most reliable and agile aggregation partner in the world’s most promising emerging markets. With over 20,000 games available and a raft of over 150 games partners, Groove brings unrivalled choice to the Brazilian market.
Yahale Meltzer, Co-Founder and CEO of Groove, commented, “Our vision has always been to build the bridges that connect great content with passionate players, wherever they are. Securing our Brazilian license and reinforcing our Argentine operations is a testament to our team’s relentless execution and our long-term commitment to LATAM.”
Meltzer concluded: “We are not just following trends; we are actively architecting the future of iGaming in the region, providing a secure, scalable, and sophisticated platform for our partners to grow with us. The door to Latin America is now open, and Groove is the key.”
For further information visit the new web domain at www.groovetech.com
The post Groove Secures Pivotal Brazilian License, Cementing LATAM Expansion appeared first on Americas iGaming & Sports Betting News.
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