The gambling sector, particularly online gambling, can be misused to launder the proceeds of crime. It is therefore important that gambling operators take adequate measures to prevent such attempts, detect them in time and report them.
Representatives of Ukrainian online gambling operators and supervisory authorities have gained practical tools to detect money laundering and fraud in player activity. At the request of the Ministry of Finance of Ukraine, which supervises online gambling operators' compliance with AML/CFT requirements, the Council of Europe delivered a two-day online training on 1-2 October 2026. Ahead of the training, the Ministry approved amendments to its risk criteria covering, among other issues, the schemes discussed during the sessions. Following the formal registration of the order, the Ministry plans to communicate its expectations to gambling operators on how to apply these criteria. It will also provide practical guidance, using the examples and approaches presented during the training, on how to detect signs of such schemes in online gambling.
Online gambling involves large volumes of fast, remote payments, which makes the sector particularly attractive to criminals. To counter this, operators need to recognise real risks rather than simply comply with formal requirements.
The topics addressed practical needs of online gambling operators and issues identified by the Ministry of Finance, in particular tools to prevent the use of third parties' payment cards. Instead of a legal overview, the training was built around numerous case studies. Participants learned how to detect "money mules" – people whose accounts are used to move funds in illegal schemes – and to check whether a payment method really belongs to the player. They also examined rapid deposits with minimal play followed by immediate withdrawal, which may indicate money laundering. Other sessions covered purchased, compromised and linked accounts, transfers between players through gameplay, and high-risk and VIP players, including politically exposed persons.
A recurring message was proportionality. Operators should detect suspicious schemes as early as possible and ensure that customer due diligence and monitoring measures are proportionate to the identified risks.
Representatives of 13 of Ukraine's 18 online gambling operators with valid licences took part in the training. Participants from the land-based gambling sector and a software provider for the gambling sector also joined, alongside public authorities, including the National Bank of Ukraine.
Participants positively assessed the practical focus of the training. Of those who completed the evaluation form, 83% said they now better understand when a signal is only a cause for concern and when it gives grounds for reporting suspicion, 75% said the case studies helped them understand how to detect suspicious activity.
"The training showed very practically how money laundering and fraud schemes work in online gambling. For the Ministry of Finance, it is important that knowledge of these schemes is applied in practice to detect suspicious activity and respond appropriately. We plan to draw on the practical examples presented during the training to explain our expectations on the application of the updated risk criteria," said Mr Denys KHOKHLOV, Head of the Division for AML Regulation and Supervision, Department for Coordination and Monitoring Activities, Ministry of Finance of Ukraine.
Participants also asked for further support in the form of short thematic webinars and practical workshops with case studies.
This training is part of the European Union and the Council of Europe joint programme "Partnership for Good Governance", co-funded by the European Union and the Council of Europe, and implemented by the Council of Europe, in the framework of the project "Enhancing anti-money laundering, counter terrorist financing and asset recovery regime in Ukraine".