Court victory for lottery operator
The Dnipropetrovsk District Administrative Court upheld the claim filed by Private Joint-Stock Company PATRIOT against the Ukrainian State Agency PlayCity. The judges annulled the regulator's decision No. 84-R dated 25 March 2026, which had deprived the company of its status as a state lottery operator and annulled its licence.
The verdict in case No. 160/16767/26 was issued on 17 September 2026. The annulled licence had been issued to PATRIOT just one month prior, on 13 February 2026.
Regulator and SBI allegations
The grounds for the licence annulment were materials and letters from the State Bureau of Investigation. Law enforcement officials claimed that the company's ultimate beneficial owner holds or held Russian citizenship and tax residency, as well as a Russian taxpayer identification number and a registration address in the Russian Federation.
Furthermore, the materials mentioned alleged retained links between the company and a sanctioned Russian oligarch who owned PATRIOT through the Cypriot entity CEHRIBA INVESTMENTS LIMITED until June 2023. The beneficial owner was also accused of having ties to the gambling business in Russia and Belarus, specifically through the companies BET INVEST and FavBetBel.
Defence evidence
Representatives of PATRIOT refuted these claims by submitting a package of documents to the court. These included the beneficial owner's Ukrainian passport, a Ministry of Internal Affairs certificate confirming no criminal record, a notarised affidavit with an apostille, and official responses from the State Migration Service confirming the absence of Russian or Belarusian citizenship.
According to depository institution extracts, the citizen has been the direct owner of 100% of the company's shares since December 2025. No documents confirming his affiliation with the Russian oligarch were provided to the court.
Separately, the company drew attention to data from Russian and Belarusian registries. According to their arguments, the presence of records in such databases does not confirm citizenship or tax residency. It was also noted that the Russian legal entity BET INVEST was liquidated back in 2019, while the activities of the Belarusian FavBetBel were terminated by annulling its licence in 2022. The beneficial owner sold his stake in this company in May 2023.
Reasoning of the decision
The court agreed with the plaintiff's position. The decision states that information from the SBI's pre-trial investigation materials, based on operational report data and extracts from the aggressor country's databases without proper primary documents, cannot be considered admissible evidence in an administrative case.
According to the court's conclusion, PlayCity issued the decision to annul the licence based on assumptions and unverified information, failing to provide a proper assessment of the official documents submitted by the operator. As a result, Private Joint-Stock Company PATRIOT's claim was fully upheld, and PlayCity's decision No. 84-R dated 25 March 2026 was deemed unlawful and annulled.
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