Highest Risk Level — Gambling Sector: Ministry of Finance on Risk Levels in Business
The Ministry of Finance presented the results of sectoral risk assessments in the field of financial monitoring for 2022–2024.
The assessments cover 8 sectors for which the Ministry of Finance sets requirements in the field of financial monitoring: gambling, lotteries, auditors, accountants, tax consultants, real estate transactions, trade in precious metals and gemstones, as well as trade in cultural valuables and brokerage in such trade.
The main goal of the assessments is to provide primary financial monitoring entities with a practical tool to understand risks in their activities and to adjust their own risk-oriented procedures.
“Sectoral assessments are useful both for the state and for entrepreneurs, as they show vulnerabilities in each sector and help determine practical measures to reduce risks. In the conditions of a full-scale war, effective financial monitoring is an important component of financial and national security. It is worth noting that the assessments were prepared taking into account real data from the annual financial monitoring reports of the business itself,” said Yurii Koniushenko, Director of the Department for Coordination and Monitoring Work Support at the Ministry of Finance.
Event Participants and International Support
Representatives of government authorities, the Council of Europe, relevant associations, professional organizations, primary financial monitoring entities, and international experts joined the discussion.
The head of the Council of Europe project, Aliona Werner, emphasized the importance of further cooperation with Ukraine in combating money laundering and terrorist financing. International expert of the Council of Europe, Liza Florkowski, presented participants with international experience and practical recommendations on using the results of sectoral risk assessments by regulators, supervisory bodies, and primary financial monitoring entities.
Risk Levels by Business Sectors: Key Findings
Based on the assessments, the highest risk level was identified in the gambling sector.
A medium risk level was established for the sectors of real estate, precious metals and gemstones, cultural valuables, lotteries, accountants, and tax consultants.
A low risk level was determined for auditors.
The Essence of the Risk-Oriented Approach
Special attention during the event was given to the practical application of the risk-oriented approach. The Ministry of Finance emphasized that this approach does not mean automatic refusals, formal prohibitions, or equal treatment of all clients. It involves the proportional application of financial monitoring measures considering the nature of the primary financial monitoring entity’s activity, the type of client, the nature of the transaction, and the actual risk level.
In particular, an accountant, a small accounting company, an auditor, a real estate broker, or another primary financial monitoring entity should not mechanically replicate approaches typical for the banking sector. At the same time, they must understand their own risks, have internal procedures to identify risky situations, and apply financial monitoring measures reasonably and proportionally.
Initial Results and Plans
The approach based on open dialogue with the market is already showing practical results. In the first five months of 2026, the number of companies and specialists who completed training and registered with the State Financial Monitoring Service nearly doubled.
The next step will be to work on proposals from relevant associations, self-regulatory organizations, and representatives of the respective sectors regarding measures to minimize identified risks.
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