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Interview with Lawyer Tatyana Klimenko
— Tatyana, hello! Please tell us about your role at Law&Trust International.
— Good afternoon! I work as a lawyer at Law&Trust International, specifically as the Head of Legal: Banking & Finance Department. Accordingly, I closely collaborate with banks and financial institutions worldwide.
— Your company specializes in business registration and support, including gambling businesses. Do you remember your first major gambling project? Can you tell us about it?
— Yes, our company is a leader in the post-Soviet space in providing legal services to gambling companies. We were among the first to start working in Curaçao, which was and still remains very popular. Today, our clients operate on multiple continents.
My first major project was in the UK, involving five licenses at once. The key aspect is that in the UK, every type of gambling activity requires a separate license. Even croupiers and other significant figures in land-based casinos must be licensed. So, the project was quite complex but provided valuable experience. Since the UK is one of the leading countries in the gambling industry, it was interesting to delve into its legislation and guidelines, which are perfectly structured for business.
— In which countries do clients most often register gambling businesses? What makes these jurisdictions attractive?
— It varies, as each client has their own goals and business strategies. Most commonly, they consider the EU, particularly Malta, which I would call the European hub for gambling. It has relatively democratic requirements while maintaining balanced regulation. The UK is also in high demand, but the entry costs there are slightly higher than in Malta. The Isle of Man is a jurisdiction suitable for operators who have already worked in another country—essentially, it’s a place for more experienced operators with a history. Curaçao remains popular, with many operators continuing to work there while also expanding into Europe by establishing affiliated companies. However, they don’t leave Curaçao entirely.
— Suppose a client has chosen a country to register their online casino. What are the next steps?
— Once a client has chosen a casino jurisdiction, we move on to a detailed discussion of their project. Jurisdiction selection is highly individual, so we never take a one-size-fits-all approach. The first two critical factors are geography and budget. Geography matters because there are no international gambling licenses. A license obtained in one country allows the operator to work there and sometimes beyond its borders. However, when entering another country, the local regulator may require a separate license and tax payments on revenue earned there. This is common in most EU countries. Some countries have unclear regulations, while others ban gambling altogether. That’s why determining the operational geography and budget is essential. Once these two factors are decided, the list of potential countries narrows, and we can then analyze their specific regulations.
— What documents are required to obtain an online casino license?
— The document package depends on the country. Some jurisdictions have extensive requirements, especially those with a long-established gambling industry and a well-developed regulatory framework. In newer gambling markets, the initial licensing stage is often simpler. Generally, applicants must provide complete documentation on the legal entity applying for the license, as well as full KYC (Know Your Customer) details for key personnel, including owners, directors, and AML (Anti-Money Laundering) specialists. These individuals must have experience in the gambling industry. Additionally, operators must submit documents proving their commitment to fair business practices, including player verification, data record-keeping, financial reporting, and compliance with legal regulations. Transparency and publicity are now in trend.
— In a previous interview, you mentioned that one of the biggest challenges gambling operators face when obtaining a license is opening bank accounts. Why is this, and how can this issue be addressed?
— Yes, that’s absolutely correct. This remains a major issue because gambling is classified as a high-risk industry. Many banks refuse to work with gambling operators due to the associated risks, and those that do accept them conduct thorough due diligence. That’s why I mentioned that transparency and publicity are essential. The more understandable and publicly visible a business is—for example, if there is sufficient information about it in public sources and social media—the safer it appears to banks.
Banks must also report all client transactions to their regulators. If an operator’s transactions are deemed suspicious and the bank fails to detect or report them, it risks severe fines or even losing its license. Therefore, before selecting a bank, operators must prepare a complete documentation package and carefully choose suitable payment solutions.
— What steps are required to open a bank account for processing casino payments?
— The best solution is to set up a processing (merchant) account, which allows online card payments. This means that users can deposit funds into their casino accounts via online card payments. The key requirement here is having a website that meets Visa and Mastercard regulations if those cards are to be accepted, along with a suitable corporate structure.
— What are the most common issues clients face when opening bank accounts?
— The biggest challenge today is proving the source of funds. Banks and payment systems require documentation demonstrating the legal origin of capital, such as tax returns or bank statements. This is a common problem, especially for those who have earned income through cryptocurrency, which remains unregulated in many countries. While it is possible to prove cryptocurrency earnings, it requires legal expertise and a creative approach.
— How does the online gambling payment system function from the operator’s perspective?
— Every company structures its payment system differently, depending on its geographic scope. Generally, an operator must have several accounts:
- A corporate account for internal business expenses (e.g., salaries, office rent)
- A segregated account for client funds
- An operational account for contract payments
- A processing account for online payment acceptance
Having multiple accounts ensures proper capital diversification and increases financial security for the operator.
— Which payment systems are most convenient for operators, and which are more difficult to work with?
— The most convenient systems offer a full range of financial services, including SWIFT, SEPA, and Target2. SEPA operates within the Eurozone and doesn’t support transactions to countries like the US or China, whereas SWIFT works globally. Target2 also operates worldwide but only in euros. When selecting a payment system, operators should verify its licensing, available transaction channels, supported countries, currencies, and whether it provides card services. Despite the vast number of available payment systems today, those offering comprehensive functionality remain relatively rare.
— How do you assess the payment system for online gambling in the CIS region compared to the West?
— Currency control measures delay payments, and gambling is only partially legal in most CIS countries, making transactions more complicated. This is one of the reasons why operators prefer to work abroad.
— In recent years, hacker attacks on both user and operator accounts have become more frequent. How secure is the existing payment system in the CIS?
— Security is a top priority. We always recommend carefully selecting banks and payment systems, ensuring they provide strong account protection, user verification mechanisms, and two-factor authentication.
— Which countries have the most reliable financial monitoring systems for gambling operators?
— Malta and the UK are the leaders. These countries host numerous operators and generate significant gambling-related tax revenue, leading to strong regulatory oversight.
— What are the most effective payment monitoring measures in online gambling?
— Online monitoring systems are the most effective, as they allow real-time tracking of gambling transactions. However, implementing such systems requires significant resources, so they remain rare. More traditional monitoring methods include reporting, audits, and regulatory inspections.
— What major changes do you foresee in online gambling payment systems in the coming years?
— The trend is toward greater transparency. New payment systems are becoming faster, cheaper, and simpler. The world is moving away from bureaucracy and toward a streamlined, secure financial ecosystem. Fintech is increasingly replacing traditional banks, and this shift will continue, leading to safer and more efficient regulation for clients.
