The situation surrounding the revocation of the license of LLC «Favbet Vip Casino» goes far beyond a local legal dispute. It exposes a systemic crisis in the interaction between law enforcement agencies, licensing regulators, and business under martial law. The reinstatement of the license by the court of first instance has called into question the very possibility of a swift state response to potential national security threats without prolonged litigation.
In the spring, the specialized regulator—the PlayCity Commission—faced a dilemma. On May 8, the State Bureau of Investigation (SBI) sent an official letter to the agency within the framework of criminal proceeding No. 6202500000000876. The documents featured officials from several companies, including «Favbet Betting Company» and «Casino.ua». The list of incriminated articles was striking in its severity: from tax evasion and income legalization to aiding the aggressor state and creating a criminal organization.
The main stumbling block was the ultimate beneficiary of the company, Andriy Matiukha. Investigation materials contained data on his alleged Russian taxpayer ID (INN), registration address in the Russian Federation, ownership of real estate in Crimea, and a scan of a Russian passport. Considering clauses 6 and 7 of part 1 of article 14 of the gambling law, which explicitly prohibit ties with residents of the aggressor state, PlayCity initiated an unscheduled desk audit.
Without waiting for a final court verdict in the criminal case—which, according to the regulator, could take years during the active phase of the war—the agency promptly drew up an act and revoked the land-based casino license.
In response to the sanctions, representatives of «Favbet Vip Casino» resolutely rejected all accusations. According to their version, Andriy Matiukha is exclusively a citizen of Ukraine, he has no Russian tax numbers or property in Crimea, and the mentioned address in the Russian Federation does not exist on the map. Regarding the main prosecution evidence—the passport scan—the company claimed it was a crude digital montage.
After the regulator decided to revoke the license, the plaintiff provided the court with three expert opinions:
Technical examination of the passport file: Revealed a lack of metadata and clear traces of third-party software processing.
Portrait examination: Concluded that the person depicted in the scan and the company’s beneficiary are most likely different individuals.
iCloud geotags: Confirmed that on May 24, 2022—the day the Russian identity document was allegedly issued in the Moscow region—the businessman was physically located in the capital of Croatia, Zagreb.
Reviewing the case in simplified proceedings without summoning the parties, Judge Roman Holobutovsky of the Dnipropetrovsk District Administrative Court sided with business, but surprised many experts with his argumentation. The court explicitly stated it was not assessing the materials of the criminal proceeding on the merits. The main question was different: did PlayCity have the right to independently establish the legal fact of residency, or did it simply mindlessly copy information from investigative correspondence?
The court verdict boiled down to the classic letter of administrative law:
The SBI letter is merely a signal of a potential offense, not a concrete legal fact.
The burden of proof lies with the state body. The regulator did not check the passport scan through competent sources, did not compare it with the original, and ignored the contradictions provided by the company.
The provision of new expert reviews to the court by the company after the regulator’s decision was used by the court not as new evidence of innocence, but as confirmation that PlayCity’s initial audit was too superficial.
In fact, the judge raised the standard of proof for licensing restrictions to the level of a criminal trial. Until a fact is proven through the agency’s own thorough review, the license cannot be touched. At the same time, the regulator has repeatedly stated that such a high barrier completely paralyzes the state’s ability to instantly respond to national security threats.
The reinstatement of the «Favbet Vip Casino» license does not mean a full recovery of the company’s business contour in Ukraine. The situation around the brand remains extremely tense:
Throughout 2026, the regulator has already managed to revoke or suspend other licenses of this group: betting activities, the operation of slot machine halls (where a fine of 933 million UAH was imposed), and the licenses of the lottery operator «Patriot».
«Favbet Vip Casino» itself has been in an active state of termination since April due to merger processes with another legal entity—»Favorit Casino Company».
For the state apparatus, this decision served as a serious wake-up call. The administrative court made it clear: an official report or a letter from law enforcement cannot automatically destroy a million-dollar business license if the state body failed to conduct a high-quality internal audit. However, the story is far from over. Ahead lies the consideration of the case in the Third Administrative Court of Appeal, where the state will attempt to defend its right to strict regulation of the gambling market under martial law. The SBI criminal proceeding also continues to operate as a separate, unwavering lever of pressure on the company.