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Automatically translated version. May contain inaccuracies compared to the original.
What is the core paradox of Ukraine's gaming regulation?
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The State Gambling Agency PlayCity ceased the license of LLC SpaceX, owner of the well-known online casino Cosmolot in Ukraine. However, the gaming service continues to operate as if this decision does not exist.
Telegraf analyzed why and thanks to whom the regulator's decision did not stop the work of one of the most controversial online casinos.
License loss as an empty formality.
Billions in tax claims, criminal cases from the State Bureau of Investigation (DBR), and the regulator's decision to terminate the license — a set that in normal logic should have long since removed the offender from the market.
But in Ukrainian realities, this is more like a “see you in court” rather than a stop. Because even when the state employs all possible leverage, for gambling giants like Cosmolot, all this is like a grain of dust to an elephant.
22 April 2026 year, the State Agency PlayCity officially announced the termination of the license of LLC SpaceX, known for its gambling brand online casino Cosmolot, one of the market leaders.
According to the regulator's explanation, the basis was violations found during an unscheduled inspection of Cosmolot, including the use of peer-to-peer payments.
In addition to the license termination, LLC SpaceX must also pay a fine: 8,6 million UAH for using p2p and 4,3 million UAH for allowing top-ups to casino accounts from third-party cards.
Under the Law on Administrative Procedures, after the decision was published Cosmolot should have ceased operations. However, when Telegraf checked whether the decision was implemented, it turned out the casino site continued to operate: slots were available, account top-ups worked, and outwardly there were no signs of a shutdown.
Legal loophole: how Cosmolot managed to “stop the stop”.
The ability for the scandalous casino to continue its work was enabled by a court order to secure the claim filed by SpaceX LLC 22 on 2026, i.e., a day before the enforcement of PlayCity's decision. In the filing, the operator asked the court to suspend the regulator's license termination until a legally binding court ruling in the administrative case, which had not even been started.
Two days later, i.e., on 24 April, judge Alona Kushnova of the Kyiv Administrative Court of Appeal issued an order to suspend the regulator's license termination. Essentially, she allowed Cosmolot to continue operating despite documented violations.
PlayCity's press service told editors that they would not comment in detail yet, but emphasized that they continue to defend their position in court.
“The State Agency PlayCity has made a decision to revoke Cosmolot's license. The basis were violations found during an unscheduled audit in the realm of settlement of payments. Such violations under current law are grounds for license revocation. The court process is ongoing, so we do not comment on its substantive progress. At the same time, we continue to defend the state’s position in court,” said PlayCity.
Interesting coincidences or a "right" judge?
One of the most intriguing moments in the court ruling in Cosmolot's favor is the judge's surname. Strangely, Alona Kushnova, according to the Unified State Register of Court Decisions (EDR), has previously issued “positive” decisions for SpaceX LLC in various proceedings.
Thus, in November last year the judge sided with this gambling operator in the 320/50538/24 case concerning non-payment of several million in penalties.
In August 2024 year, in the case 320/10610/24, SpaceX LLC together with Judge Kushnova “defeated” the State Tax Service, canceling the tax assessment decisions under which the operator would have to pay several tens of millions in taxes.
Kushnova is also known for her involvement in cases of former OASK head Pavlo Vovk and the head of the High Economic Court Bogdan Lvov. It was she who once canceled the findings of the Public Council for Integrity about Vovk's lack of integrity and overturned the order by the Supreme Court to remove Lvov from the Supreme Court’s roster.
Blurry optics, or What’s wrong with the license to operate Cosmolot without a license.
Judge Kushnova's order to secure the claim effectively means that Cosmolot, formally an operator with a revoked license, obtained the opportunity to continue its activities — either until the appellate court cancels this order upon PlayCity's appeal, or until a final decision is made in the upcoming main administrative case where SpaceX will challenge the regulator's decision. In the first case it could be weeks, in the second — months or years of court proceedings.
In similar cases, people often refer to the so-called “presumption of innocence” — the principle that a person cannot be found guilty of a criminal offense without a court verdict. But it has nothing to do with this situation.
The activity of the State Agency PlayCity is not an investigation of a criminal proceeding, nor the work of law enforcement. It is a market regulator for gambling, operating within administrative procedures with different authority — monitoring compliance with licensing conditions and reacting to violations.
In this framework, establishing a violation is not a mere assumption or “version” to be proved in court. It is the result of an inspection conducted under the law, with records of specific facts of non-compliance. After that, the regulator makes an administrative decision — including about license revocation. This is not a process of proving guilt, but a consequence of already established violations of market rules.
In this logic, a decision to revoke a license should have a declarative character only, not a direct regulatory effect, like a criminal case notice, but a direct regulatory effect: the violation is recorded, and the operator no longer meets market conditions and must halt activity.
In the Cosmolot case this means that, from a regulatory system perspective, its activity should have been stopped immediately after the violations were documented and the corresponding PlayCity act was issued. Only a positive court ruling regarding the challenge to regulator actions would resume it.
However, the court’s mechanism of securing the claim and Judge Kushnova seem to have manipulated this logic to 180 degrees — allowing the violator (and Cosmolot's status is officially recorded by the regulator) to continue activity.
When license revocation means nothing.
The Cosmolot saga goes far beyond a single case and reveals a systemic problem: companies already entrenched in Ukraine’s multi-billion gambling market are practically impossible to remove even after official violations are established. And Cosmolot is far from an exception.
One need only recall 1Xbet and Parimatch cases, which continued to operate for a long time despite serious state claims, including questions about legality and ties to Russia. The effective removal of these operators from the market occurred not within regulator procedures, but only after applying sanctions.
The reason for this is well known: gambling operators accumulate enormous financial resources, enabling them to build a multi-layered protection system — legal, judicial, public, and media. As a result, any regulator's decision is automatically transformed not into an end but into the start of a lengthy process to block it.
Thus, the key paradox of Ukraine's gambling regulation emerges: the state formally can establish violations, but practically cannot stop the offender's activity. License revocation ceases to be a final regulatory decision and becomes only one stage of a prolonged legal fight with an uncertain outcome.
And this creates a dangerous signal for the entire market: compliance becomes less profitable than violating and then appealing. Because even after license loss one can operate for months or years, the regulator's decision loses its main function — to immediately halt activity, even when gross violations are documented.
Until this logic changes, license revocation in Ukraine risks remaining not a final sanction, but only the initial stage of a multi-year legal battle that operates to the advantage of the violator.
Telegraf will closely follow the Cosmolot case and other operators. Stay tuned.
For reference
Gambling establishments under the Cosmolot brand operated in Ukraine even before the formal legalization of gambling in Ukraine, using the UNL lottery and later MSIL signs. It is believed that during the “lottery” period the true owner of Cosmolot could have been Russian-origin businessman Sergei Tokarev, who also developed gambling business in Russia.
Later (in the 2020-2021 years) the Cosmolot brand was acquired by SpaceX LLC. Since 2024 year to present, the formal owners of the company are NEVADA GAMING HOLDING LLC (USA), 49% and German citizen Arnulff Dunker Dam… (51%). Dam… calls himself a “strategic investor” and has an interesting biography – founder of investment company Euro Atlantic Group and charity Euro Atlantic Institute.
According to press data, among Arnulf Dameraus’ most well-known investments is a stake in the cyber company CrowdStrike (he participated in organizing its IPO and bought a portion of its shares). It is known for one of the most high-profile Windows-based system crashes, where its software caused “blue screen of death” on tens of thousands of computers, causing billions in damages. CrowdStrike is also mentioned in connection with the so-called “Trump conspiracy theory” (later deemed fake). As the BBC wrote citing Forbes, according to this theory CrowdStrike allegedly hired the Democratic National Committee in 2016 to investigate the hacking of its servers.
If in the 2023 year SpaceX LLC showed a net profit of 3,57 billion UAH, then in the 2025 year it showed only 279 million UAH.
Currently, a number of criminal proceedings are being investigated against the company, including manipulations with p2p transfers and the withdrawal of funds from the defunct Diamond Pay payment network.
Document: PDF proof of the original version of the news item "Безсилля держави і живучість казино: чому "Космолот" досі "на орбіті", попри анулювання ліцензії". It records the publication content at the moment of the first scan, the preservation date and the source: Telegraf.
