Casino regulation in Eastern Europe and the CIS

Comparative matrix (brief)

Jurisdiction	Online casino	Online rates	Land-based casinos	Common vector
Ukraine	Allowed under license, with enhanced control	Allowed under license	Allowed under license	Gradual tightening of RG/advertising, high supervision
Georgia	Allowed, but with strict restrictions and thresholds	Are resolved	Are resolved	Conservative RG (high age/Fin. barriers), strict advertising
Armenia	Are resolved	Are resolved	Are resolved	Increased ad and placement restrictions
Azerbaijan	None (for private operators)	Limited through authorized operators	Generally prohibited	De facto state focus on lotteries/betting
Kazakhstan	No (online casino)	Yes, licensed	Yes, in special areas	Hard Geofencing + AML
Kyrgyzstan	For non-residents/foreigners - allowed (online/offline)	Similarly	Allowed for non-residents	Model "for foreigners," citizens are limited
Uzbekistan	Online casinos - no	Individual modes/betting pilots, lotteries	Casinos banned	Cautious liberalization around lotteries/rates
Tajikistan	No	None (except lotteries)	No	Prohibitive model
Moldova	Through State Partnership/Concessions	Through State Partnership/Concessions	Restrictedly	Government model (lottery/concessions)
Romania	Allowed under ONJN license	Are resolved	Are resolved	Mature, detailed online supervision
Bulgaria	Are resolved	Are resolved	Are resolved	Tight reporting/taxes, active post-supervision
Serbia	Are resolved	Are resolved	Are resolved	Stable frame, clear requirements
Belarus	Allowed under license	Are resolved	Are resolved	Centralized control, online registration
Russia	Online casinos - no	Bookmaking under tight control	Casinos - zones only	Interlocks, payment filters, unified supervision

💡 Matrix - reference point: details (age, taxes, registration formats, dates) differ and are updated. A fresh legal audit is needed before entering the market.

Country profiles (per case)

Ukraine

Regulator and licenses. Centralized issuance of online/offline licenses, control of beneficiaries and platforms, increased attention to payments and affiliates.

RG/advertising. Visible limits, self-exclusion, age control; Advertising - limited by channel, time, and content.

Technique. RNG/RTP certification, version control, unchangeable logs, reporting.

Trend. Tightening rules, sanctions agenda, growing transparency requirements.

Georgia

Policies. Legal online/offline, but high entry thresholds for players (age/financial restrictions), reduction of advertising channels.

Supervision. Strong focus on RG and payments; increasing tax burden and identification requirements.

Inference. The model is "strict but predictable" for mature operators.

Armenia

Licenses. Available online/betting/offline subject to technical and financial requirements.

Advertising. Consistently tightened: restrictions on outdoor/media, 18 + warning requirement, transparent bonus T & C.

Payments/AML. KYC before withdrawal, reporting on suspicious transactions, segregation of funds.

Azerbaijan

Model. There is no private online casino market; sports betting and lotteries - through authorized structures.

Risks. Aggressive blocking policy, payment filters.

Kazakhstan

Zoning. Casinos - only in permitted areas; online casinos are prohibited.

Betting. Allowed under license; cash transaction monitoring, AML/KYC, payment tracking.

Technology. Mandatory certification of equipment/software, logs, control of providers.

Kyrgyzstan

Approach. Casino/online permission mainly for non-residents (foreigners); citizens have limited access.

Compliance. Requires provable RG/AML, payment control.

Uzbekistan

De jure. Casinos are prohibited; online casinos - no.

What is possible. Lotteries and individual betting regimes (phased development of regulations, pilot projects).

Supervision. Conservative, with a focus on payments and advertising.

Tajikistan

Policies. Prohibitive (except lotteries).

Corollary. High blocking and liability risks for unlicensed activities.

Moldova

Model. State/concession: online betting and casinos are implemented through partnerships with national structures.

Requirements. Tight payment control, reporting, RG/AML.

Romania

Regulator. ONJN: mature and detailed online/offline control.

Requirements. RNG/RTP certification, version control, logs, transparent bonus T & Cs, strict advertising and affiliate rules.

Plus. Projected deadlines and procedures; high "weight" among payment partners.

Bulgaria

Model. Fully regulated online/offline; high density of inspections and tax discipline.

Focus. RG, advertising, provider control and payments.

Serbia

Mode. Allowed online with clear licensing requirements; sustainable post-surveillance practices.

Advantage. Balance of costs and reputational "weight."

Belarus

Policies. Centralized online with registration and reporting; offline is allowed.

Contour. High level of state control over processes and payments.

Russia

Online. Casinos are prohibited; licensed bookmaking operates under a single supervision and settlement circuit.

Toolbox. Blocking domains/applications, payment filters, ad control.

Zones. Land casinos only in special gambling zones.

What unites "strict" regimes

1. Responsible play: limits, timeouts, self-exclusion, trained support, KPI by RG.

2. AML/KYC/KYT: verification of identity and sources of funds, monitoring of transactions (including crypto streams), incident reporting.

3. Game integrity: RNG/RTP certification, version control, immutable logs and retro auditing.

4. Advertising and affiliates: 18 +, anti-mislead, prohibition of "guaranteed winnings," transparent bonus conditions.

5. Payments: segregation of client funds, SLA for conclusions, local methods (cards, bank transfers, wallets), 2FA.

Licensing Roadmaps (Generic)

A. Fully regulated online markets (Romania/Bulgaria/Serbia/Belarus, part of the Caucasus)

1. Preparation: KYC beneficiaries, business plan, AML/KYC/RG/IS policies, platform architecture.

2. Submission: dossier, contracts with content and payment providers, test acts of integration.

3. Technical control: RNG/RTP, version control, unchangeable logs, BCP/DR, IR plan.

4. Go-live: reporting, RG/anti-fraud monitoring, advertising/affiliate control, periodic audits.

B. Partially authorized/zoned markets (Kazakhstan, Moldova, Ukraine with peculiarities)

1. Legal design (zones/concessions/partnerships).

2. Local responsible persons, payment integrations, cash discipline.

3. Enhanced reporting and approvals for advertising/perimeter sales.

4. Post-supervision: offline inspections, payment reconciliations, recertification.

C. Restrictive/prohibitive (Azerbaijan, Tajikistan, part of Central Asia)

Online casinos are not allowed; emphasis on lotteries/betting through authorized operators. Any B2C initiatives require a separate legal assessment and compliance with local prohibitions.

Operator's checklist (universal)

Transparent beneficiaries and confirmed source of funds.
Key Functions are assigned: Compliance, MLRO, InfoSec, RG-Lead (local representatives where required).
Real, not "paper" RG tools in the product; intervention scenarios.
RNG/RTP certification, version control, immutable logs, incident log.
Payments: segregation of funds, local methods, withdrawal SLAs, 2FA; for crypto - KYT and off-ramp rules.
Advertising/affiliates: 18 +, anti-mislead, transparent T&C bonuses, partner whitelists.
Audits/penetration tests/HRV-DR - by calendar, with reports and corrective actions.

Player checklist

Check the license number and jurisdiction in the site footer.

Look for limits/self-exclusion, a help section, and contacts for complaints/ADRs.

Read bonus T & Cs before deposit (vager, games contribution, limits, deadlines).

Look at payments (local methods, withdrawal dates, 2FA) and RTP/providers.

Avoid brands with aggressive "no risk/guaranteed win" ads and murky withdrawal conditions.

Frequent business mistakes

"Paper compliance" (there are policies, they do not work at UX).

Releases without math/client logic recertification.

Hidden bonus limits and sloppy affiliate perimeter.

Weak incident management (no IR plan, journals, BCP/DR).

Ignoring local advertising/financial nuances (fines and blocking).

The region offers a full range of regimes - from mature EU-east markets to conservative models in the CIS. A successful strategy is based on accurate legal cartography, localization of payments, proven honesty of games and "embedded" RG/AML. The right license and compliance discipline turn the regulator's permission into a long-term asset - reputation, access to Tier-1 providers and a sustainable product economy.