Millions "out of thin air": Court upholds NBU fine on company that "inflated" capital with Parimatch funds

Millions "out of thin air": Court upholds NBU fine on company that "inflated" capital with Parimatch funds

On February 26, 2026, the Kyiv District Administrative Court in case № 320/19194/25  denied LLC «FINPAYMENT» (new name) the cancellation of a fine imposed by the National Bank of Ukraine in the amount of 6.64 million UAH. The main reason for the sanctions was that the company illegally included frozen funds of sanctioned gambling brands, such as Parimatch and Pokermatch, in its capital.

In January 2025, the National Bank fined FC «UP.ME FINANCE» 6.65 million UAH based on the results of a scheduled inspection of its activities for the period of 2022–2024. The company paid the fine but immediately appealed to the court, demanding that the NBU’s decision be declared unlawful and the collected funds be returned.

The plaintiff argued that the violations were «minor,» some of them were corrected during the inspection, and the National Bank allegedly exceeded its authority. However, the court fully supported the position of the Regulator.

The most serious violation concerned manipulations with reporting and capital (N2 standard). The company submitted unreliable data regarding its financial stability to the NBU 31 times.

The financial company included over 17.3 million UAH in its «acceptable assets,» which were actually blocked in bank accounts by the decision of the National Security and Defence Council. These were funds transferred to the companies LLC «POKERMATCH.UA,» LLC «PARIMATCH,» and LLC «POINTLOTO» for the payment of winnings to players. Since these companies were under sanctions, it was impossible to use these funds, but FC «UP.ME FINANCE» continued to account for them in the calculation of its capital, creating an illusion of a better financial condition. The court recognized this as a gross violation of the NBU’s methodology.

Among other violations for which the company was fined:

•  Delay in responding to BEB detectives: The company provided information to the Bureau of Economic Security untimely (with delays ranging from 5 to 13 days). In court, the company’s representatives explained this by the large volume of requested data, as well as frequent air raid alerts and missile attacks on Kyiv, due to which employees were in shelters.
•  Negligence with confidential information: The company sent 12 outgoing letters containing banking/payment secrets without any access restriction markings and did not register them in a special journal.
• Issues with outsourcing documentation: Internal rules for working with contractors did not meet the Regulator’s requirements (this violation was corrected by the company during the inspection).

The court recognized the fine amount (over 6.6 million UAH) as proportional and adequate to the committed violations. The claim of FC «UP.ME FINANCE» was fully denied.