The state plans to introduce strict fixed limits on spending and play time for players of legal online casinos. The Association of Ukrainian Gambling Business Operators (AUOGB) appealed to the Ministry of Digital Transformation with a letter urging it not to adopt this decision. Among the arguments are the unsuccessful experience of European countries, the risk of expanding the shadow sector where illegal online casinos from Russia already operate, and the lack of player protection.

The appeal provides examples of EU countries where strict limits and an advertising ban led to a sharp increase in the “shadow” segment: in Germany—to 60–80% of the market, in Finland—32–35%, in the Netherlands—25–30%. By contrast, in the United Kingdom the shadow segment is 1–2%, and in Denmark—about 9%. Such a low figure was made possible, among other things, by flexible or voluntary limit models.

The biggest shadow-market risk is that players may end up in the hands of Russian online casinos. In addition to the total lack of player protection (no limits and payout guarantees, risky transfer of personal data, money-driven incentives, etc.), during wartime this carries the risk of being recruited by Russian special services.

In AUOGB’s view, limits should be introduced gradually and adjusted according to a player’s gambling behavior. At the same time, illegal operators must be eradicated: blocking illegal sites, their advertising, and transactions. Against the backdrop of pressure on legal businesses and without fighting illegal operators, the shadow sector will only grow.

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