National Bank of Ukraine made financail audit of LLC FC Leo Gaming

1. Financial audit results
LLC FC “LEOGAMING PAY”
Kyiv

2. 2
LLC "FC" LEOGAMING PAY" (EDRPOU code 39010283)
Director Shevtsova Alyona Volodymyrivna
UBO Shevtsova Alyona Volodymyrivna
Date of registration/ Authorized capital 12/05/2013/ UAH 19.700.100.00
The presence of criminal proceedings
According to https://youcontrol.com.ua, there are criminal cases
(total 144 documents)
Number of clients as of 12/10/2020 54, of which limited liability companies - 49; IEs - 5.
The payment organization of the International payment system "LEO"
Member of other payment systems
PS “FINANSOVYY SVIT”; PS “WELSEND”,
PS “AVERS №1”; PS “CITY 24”
Encashment 119 mln UAH (of which 90 mln UAH to the account of Oschadbank)
Payment Terminals as of 12/10/2020 - 27 during the inspection period - 57
Cash desks in Kyiv (2 cash desks) 0
Cash registers in Kharkiv (1 cash desks) 89 mln UAH
payments for admin services
payments by open details
purchasing of vehicles
The income received by the Company 51.4 mln UAH
the largest fees recieved from LLC FC "TREYD-HRUP" -
16,8 mln UAH and LLC "BUSLO" - 28 mln UAH
Acting officer responsible for financial audit
Tsybulnyk I.I. (Head of Services, Financial Products and Payment
System Development Department)
Website LLC FC " LEOGAMING PAY" https://leogaming.ua/
most of the payments were initiated from the web-
site that belongs to LLC "LEOGAMING" https://leogaming.net.ua
Based on the agreement № 01/01 on the use
of part of the site from 03.01.2017

3. The total amount of financial transactions for the transfer of funds
carried out by LLC FC "LEOGAMING PAY"– 925 mln UAH
3
№ НАЗВА ПЛАТІЖНОЇ
СИСТЕМИ
DATE OF
JOINING
TOTAL
AMOUNT
1. PAYMENT
SYSTEM
“FINANSOVYY SVIT”
01/20/2016 22 904 619.89
2. PAYMENT
SYSTEM
«WELSEND»
06/22/2017 490.00
3. PAYMENT
SYSTEM «AVERS
№1»
06/22/2017 0.00
4. PAYMENT
SYSTEM «CITY 24»
11/21/2019 0.00
5. INTERNATIONAL
PAYMENT
SYSTEM «LEO»
902 102 332.40
Name of the acquiring bank The period of
operations
The amount of transactions for the
period from 12/01/2019 to 12/10/2020
IBOX 10/05/2020-
12/10/2020
11 192 845.94
OSCHADBANK 09/11/2019 –
12/10/2020
55 176 141.39
PRIVATBANK 02/01/2019 –
12/10/2020
11 984 014.47
TASCOMBANK 02/01/2019 –
12/13/2019
310 605.28
CONCORD 02/01/2019-
08/25/2020
695 736 125.17
Total 774 399 732.25
Financial operations on the transfer of funds carried out by LLC FC “LEOGAMING PAY LLC”
for the period from 02/01/2019 to 12/10/2020 in terms of payment systems / acquiring banks
Domestic / international payment
systems created by residents
Acquiring banks

4. 4
LLC FC "LEOGAMING PAY"
Period: from 02/01/2019 to 12/10/2020
Transfer of funds initiated
by payment card holders
according to the agreements
with acquiring banks
≈ 774.3 mln UAH
925 mln UAH
Individuals ≈ 22.9 mln UAH
Individuals
Initiating transfer of funds on
cash desk OSCHADBANK
≈ 695.7 mln UAH
Transfer of funds in favor of clients of the Company
in terms of individual services
% ratio of total
transfers
40.4%
15.13%
13.8%
8.1%
3.7%
2.5%
Type of service*
According to the
Company
Loan repayment
FC TREYD-HRUP
Perfect World
(games)
GameXP (games)
Payment according
to free details
Lineage 2
Electronic money
"PROSTIR"
(Leowallet)
Sports poker and
e-sports tournament
Total transfers
(UAH)
374 905 361.29
140 124 198.01
128 623 963.03
75 458 013.33
34 827 539.06
23 204 459.19
9 395 668.92 0.9%
≈ 90 mln UAH
Through the terminals domestic
PS “Finansovyy svit”
≈ 30.0 mln UAH
Through their own terminals

5. 5
The largest volumes of financial transactions were carried out
for the benefit of such clients of the Company:
1. LLC FC "TREYD-HRUP"
(EDRPOU code 40340589)
operations for the period 05/15/2020 – 08/19/2020
347 mln UAH
(payments were made through JSC "IBOX BANK")
At the same time, website https://fctradegroup.com.ua (domain was
registered 15.05.2020, it is impossible to apply for a loan on the website,
there is no contact information, according to the website the main
occupation of the company is online loans, there are 32 more companies
registered at the address of the Company), operations with the appointment
of “loan repayment to TREYD-HRUP” according to the register of LLC FC “
LEOGAMING PAY” start from 05/15/2020, and as an example
05/15/2020 they were done from 00:56 to 23:59 4,1 mln UAH.
Date of application of LLC FC "TREYD-HRUP"for revocation of
licenses – 01/12/2021, date of receipt of the application by the National
Bank of Ukraine – 01/14/2021.
2. LLC "BUSLE"
(EDRPOU code 42579695)
operations for the period 102/13/2019 –
09/30/2020
331 mln UAH (pay for games as an
example Perfect World, Skyforge).
Business relations with the Company were
terminated on October 5, 2020.
From 10/29/2020 new name
LLC «PLASTERER-HRUP»
New director, UBO HOBRONIDZE
IOSEB (Georgia) + new occupation:
43.31 Plastering

6. An example of the frequency of financial transactions
6
Payment initiator ID Date of transactions
Total amount for
specified date (UAH)
List of financial
operations Time of transactions Name of the Company's client
6832209 08/10/2020 78420 9920
10000
10000
10000
10000
10000
8500
10000
22:55:13.
22:53:57.
21:12:23.
21:11:17.
21:10:16.
21:09:15.
18:20:54.
00:25:54.
LLC FC "TREYD-
HRUP"
6832209 08/07/2020 87000 10000
10000
10000
10000
7000
10000
10000
10000
10000
19:39:55.
19:38:44.
19:37:39.
19:36:23.
18:48:04.
18:47:03.
18:18:02.
16:20:06.
16:18:55.
LLC FC "TREYD-
HRUP"
184336785 05/25/2020 76700 4900
4900
4900
4900
4900
4900
4900
4900
4900
4900
4900
4900
4900
4500
4500
4000
16:40:39.
16:39:58.
16:37:37.
13:43:04.
13:42:01.
13:40:13.
13:39:34.
13:39:03.
10:04:55.
10:02:14.
10:01:10.
10:00:02.
09:57:16.
18:19:57.
18:19:21.
18:20:51.
LLC "BUSLE"

7. 7
 In addition, the inspection team recognized that the identifier of the payment initiator 155531601 were returning
loans in favor of FC "TRADE GROUP" in the amount of 910 738 UAH. while using the same identifier of
payment initiator payments proceeded for games Perfect World, GameXP on in favor of BUSLO LLC in the
amount of UAH 629.170;
 The identifier of payment initiator 184336785 were used to repay loans in favor of LLC "FC TRADE GROUP"
in the amount of UAH 91,100, while the same identifier of payment initiator was used to pay for the game
GameXP in favor of LLC "BUSLO" in the amount of UAH 716.783;

Transactions with the same identifiers of payment initiators are reflected in the system of the PS "Leogaming payment
processing".
 It should be noted that according to the information available to the National Bank, electronic means of payment from
which payments were initiated, in particular with such identifiers as 155531601 belong to only one person, the same
situation is with the identifier 184336785.
 According to the register, the initiator with the identifier 155531601 repaid the loan of LLC «FC "TRADE GROUP" at
the same time in the bank funds were written off with the following purpose "ENTERTAINMENT: RFA, KYIV
PURCHASE P 10" instead of loan repayment, and when the payment is made by the same initiator an individual in favor
of "BUSLO" GameXP, the bank is written off with the purpose "ENTERTAINMENT: LEOGAMING.NET, KYIV
PURCHASE P 10».
Identical identifiers for payment initiators from different clients
of FC LEOGAMING PAY LLC

8. 8
 Clients of LLC FC "LEOGAMING PAY" - payment for the "Sport poker and E-Sports Tournament"
service. Total - 9,3 mln UAH
Client’s name
Provider's trademark
displayed on the
terminal screen, on the
website or in the
application at the time
of initiating the transfer
Date of
establishment of
business relations
Date of
termination of
business relations
The total
amount of
funds
contributed
for the
purpose of
transfer by
terminals
(UAH eq.)
The total amount
of funds
transferred
through the
website
or application
(UAH eq.)
LLC WAIMZ
Sport poker and
e-sports
tournament
(WAIMZ)
05/12/2020 09/14/2020 7 378 050.55 JSC "IBOX BANK"
Formula 1 02/06/2020 10/05/2020 50 918.20 JSC "IBOX BANK"
Sport poker and
e-sports
tournament
MELBRON) 57410.00 80 962.67 JSC "IBOX BANK"
LLC REDSIN
Sport poker and
e-sports
tournament
(REDSIN) 05/12/2020 10/20/2020 561.00 632 478.95 JSC "IBOX BANK"
LLC CELIOS
Sport poker and
e-sports
tournament
(CELIOS) 12/24/2019 06/12/2020 1 146 510.00 JSC "IBOX BANK"
LLC MELBRON
Name of the bank to
whose account the
transfer of funds was
made

9. 9
The information on in terms of Participants of the IPS "LEO"
for the service «Sport poker and e-sports tournament»
The total amount of
financial transactions
462 065 234 UAH
178,9 mln UAH
STARMONEY
LTD
273,4 mln UAH
“BIZNES
RITEYL HRUP"
LYD
9,6 mln UAH
LLC FC
"LEOGAMIN
G PAY"
Period: 05/14/2020 – 12/10/2020
76,7 mln UAH
JSC "IBOX
BANK
93,7 mln UAH
LLC FC
"LEOGAMIN
G PAY"
291,5 mln UAH
“BIZNES
RITEYL HRUP"
LYD
The legal entities
are service
providers
ТLLC WAITGOAL
LLC DIGISPACE
LLC REDSIN
LLC MELBRON
LLC CELIOS
LLC WAIMZ
LLC NEYRON GOLD
LLC CLARITY TRADE
The Amount and
% to total volume
65,7 mln UAH
14,2 %
254,2 mln UAH
55 %
7,4 mln UAH
1,6 %
80,6 mln UAH
10,4 %
26,6 mln UAH
5,7 %
26,9 mln UAH
5,8 %
49,5 thnd UAH
0,0001%
344,1 thnd UAH
0,0007%

10. 10
National Bank conducted a study of clients on the basis of:
1. The MEMORANDUM OF COOPERATION between the Associations and the NGO
"FEDERATION OF SPORT POKER AND CYBERSPORTS" (EDRPOU code 43599817)
https://pokerfederation.net.ua/
2. The letters - messages from the NGO "FEDERATION OF SPORT POKER AND
CYBERSPORTS" (according to which it is stated that LLCs organize sport poker tournaments
on the web resource https://pokermatch.com/
3. The scientific and legal conclusions on the dissemination/non-dissemination of the Law
of Ukraine "On Prohibition of Gambling Business in Ukraine" for online sport poker
competitions conducted via the Internet (PokerStars, PokerMatch), provided by the
NATIONAL ACADEMY OF LAW UKRAINE (Kyiv regional center) at the request of the
Ukrainian Association of Payment Systems "UAPS
4. The scientific and legal conclusions on the appeal of the NGO "FEDERATION OF
SPORT POKER AND CYBERSPORTS".

11. 11
The NBU sent inquiries to:
 Ministry of Youth and Sports of Ukraine
 CIVIL ORGANIZATION UKRAINIAN SPORT POKER FEDERATION (EDRPOU code 39214501)
 PUBLIC ORGANIZATION ALL-UKRAINIAN ORGANIZATION FEDERATION OF E-SPORT
OF UKRAIN
The Ministry provided the following response:
"We note that the Ministry of Youth and Sports does not have any information about NGO FEDERATION OF SPORT
POKER AND ESPORTS (EDRPOU code 43599817).
The development of the sport "sport poker" in accordance with Article 20 of the Law of Ukraine "On Physical Culture and
Sports" is responsibility of Ukrainian Sport Poker Federation, which in accordance with the order of the Ministry of Youth and
Sports from 23.10.2018 №4897 has the status of a national sports federation.
According to the rules of sports competitions in the sport of "sport poker", online tournaments are not provided.
According to the Unified calendar plan of physical culture, health and sports events of Ukraine 2020 in the discipline “sport
poker”, in Kyiv there were held the Open Cup of Ukraine, qualifying round 1, III rank on February 01-03 and the
International tournament "Ukraine Poker Open", 1 stage on January 26 – February 03.

12. 12

13. The total volume of transfers by participants of the IPS «LEO»
LLC FC
"LEOGAMING
PAY"
LLC FC"
SYSTEMA"
JSC
"IBOX
BANK"
STARMON
EY LTD
LLC FC
ARTUA
"BIZNES
RITEYL
HRUP" LYD
TANDEN-
FINANCE,
FC LLC
FINTEKO
LLC
Period:
02/01/2019 –
12/10/2020
902,1 UAH 89 % initiated through the website,
mobile application and terminal of the Company
11,7 bln UAH 99,9 %
initiated through
terminal
1,06 bln UAH 100 %
initiated through
the website
682,1 bln UAH 100 %
initiated through the website
380,1 bln UAH, 100 %
initiated through
the website
318,3 bln UAH, 100 %
initiated through
terminal
*LLC FC "LEOGAMING PAY" - payment organization the IPS “LEO” settlement
banks – JSC "IBOX BANK”; JSC JSCB CONCORD”; CB UkrGasBank
The diagram shows the operations of the participants of the IPS "LEO" from
50 mln UAH for the period
2,8 bln UAH 99,9 %
initiated through
the website
165,3 bln UAH, 100 %
initiated through
the website
Total amount of registered
transfers in the IPS “LEO”
18 201 182 206 UAH

14. ILOT LLC
M.S.L. - state lotteries
14
The case contains: distribution certificate; agreement with M.S.L. and other documents
The contract for the transfer of funds LLC FC "LEOGAMING PAY" with ILOT LLC from
07/27/2018 № 2018/07-06.
 According to this agreement, it is credited to the accounts of ILOT LLC in ALFA BANK JSC -
11.2 mln UAH (9.9 mln UAH were paid to the winners)
 JSC CB PRIVATBANK - 900 thnd UAH from LLC FC "LEOGAMING PAY" (account closed)
 According to the register of transactions, there were transferred through LLC FC
"LEOGAMING PAY"- 3 mln UAH "receiving cash in favor ILOT LLC was carried out by
participants of IPS "LEO": PAYCELL LLC, STARMONEY LTD LLC FC "SYSTEMA"…… LLC FC
"LEOGAMING PAY" transfers funds received from payers during the settlement period…"
 However, it is established that TRANSFER TO THE OPERATOR OF STATE
LOTTERIES "M.S.L." was not provided at all.
 According to information from open sources, in 2020 ILOT LLC paid prizes, in particular to
the Deputy from " SLUHA NARODU" Pavlyuk M.V.
https://www.pravda.com.ua/news/2021/02/5/7282428/
Period: 02/04/2019-12/10/2021

15. LLC "BUSLE" online games
15
The Institution has agreements (extracts, only 2 pages), that were concluded between LLC
"BUSLO" and non-residents PERFECT WORLD GAMES Inc. (USA), PERFECT WORLD
ENTERTAINMENT Inc. (USA) on "provision of information technology services for access to
online services according to the application (online games)".
Cash flow scheme LLC "BUSLO" (Ibox Bank):
At the same time, TRANSFERS in favor of these non-residents
are not present at all during the inspection period.
LLC FC "LEOGAMING
PAY" (2650)
LLC "BUSLE"
(2600)
Transfer on the basis
of the Commission
Agreement
LLC ODERIN
(2600)

16. Analysis of information onVisa Visa | Mastercard, payment card holders,
that are initiating payments on the resources of LLC FC "LEOGAMING PAY"
16
 Issuing banks
 Clients of Banks (individuals) with a work place:
employee of the department of interaction with executive bodies of the Verkhovna Rada of Ukraine, JSC
FARMAK, member of election commission, UMG Lvivtransgas PJSC LVIVHIMZAVOD, Individual entrepreneur,
employee of a military unit A4267, TEXTILE DESIGN COMPANI LLC, PERSHA NAFTOVA KOMPANIIA LLC,
LUHANSK BUILDING COLLEGE, National University of Kharkiv, CO "AROVANA VF" LTD, AVTOSYMETRIIA LLC etc.
Funds are written-off as: Payment of funds:
Replenishment of the card account through the terminal №KHO00001
Replenishment of the card account through the terminal №31000867,
M. KYIV, VUL. BUL'VARNO-KUDRIAVS'KA, 6,K
Replenishment of the card account through the terminal
№31001017, 01042, m. Kyiv, provulok Novopecherskyi,
P2P transfer of credit part ECM00021, BILLER-
A2CB,EBPP,EBPP,UA
ENTERTAINMENT: LEOGAMING.NET, KYIV PURCHASE P 10
ENTERTAINMENT: RFA, KYIV PURCHASE P 10
ENTERTAINMENT: RFA, KYIV PURCHASE P 10
Purchase operation in the trade and service network
№E0105511, RFA, Kryglouniversytetska str., 7. of.26
Purchase,RFA, KYIV, UKR
Purchase operation in the trade and service network №a0150896,
MAKSYM CHYCHKANOV, Pari Match, Karpenisiou 9, Cyprus, CY
*information from the Internet: Parimatch - an international bookmaker headquartered in Limassol, Cyprus https://parimatch.com/
RFA- ukrainian team of players in CS:G0 https://ggscore.com/ru/csgo/team/risefromashes

17. Some financial transactions using a payment card (write-off)
The individuals initiate
payments using payment cards
of various issuing banks,
including non-residents
https://leogaming.net/
Leowallet (app)
leogaming.net (LeoBot)
≈ 695,7 mln UAH
Inconsistency of the received information
The information provided by LLC FC "LEOGAMING PAY"
(June 2020): Address of the place of the transfer initiation:
https://leogaming.net/ - 217,7 mln UAH
Leowallet (app) - 400 thnd UAHю
The information provided by JSC JSCB CONCORD (June 2020):
https://leogaming.net/ - 56,3 mln UAH
Leowallet.net - 161,4 mln UAH
More than 90% of financial transactions using Visa and Mastercard
payment cards, initiated by payment cards holders on the resources
of LLC FC “LEOGAMING PAY", are assigned as High-Risk
Merchant Category Code (MCC) 7994 – Video games
MCC code (Merchant Category Code) – is a four-digit number that is used to classify
business by payment transactions using bank payment cards in the trade and service
enterprise in the electronic transmission of information in the transaction for the
goods or services provided.
17

18. The route of financial transactions initiated on the resources of LLC "FC LEOGAMING PAY"
18
Initiation of transfer on the resources
of the Company, including entering
payment card data
Acquiring bank
Settlements on transactions using
payment cards of international
payment systems
Public offer agreement Acquiring agreement
LLC FC
"LEOGAMING
PAY"(2650)
Transfer in favor of clients
of the Company
(service providers)
Contract for the funds transfer
LLC "BUSLE"
(example)
(2600)
Transfer on the basis
of the Commission
Agreement
Under the terms of the A2C Agreement,
payments are collected by companies that do
not have a license to transfer funds without
opening accounts, and are also not in the
register of commercial agents of banks!
IBOX bank
(2909)
Transfer of payments
previously collected by the
Companies to the transit
account of the Bank
Agreement on acceptance
of payments for further crediting
to the Recipient's account (А2С)*
JSC FUIB
LLC FC" SYSTEMA"
(example)
(1819/2809)
Service agreement
Agreement on the organization of interaction in the funds transfer
1 2
3
4
5
6
LLC FC "TREYD-HRUP"
(example)
(2600)
LLC ODERIN
(example)
(2600) (2932)
LLC FC "TREYD-HRUP"
(example)
(2932)
Transfer to a bank
account
41
41
Payment
on PS

19. Simplified calculation scheme
19
Chain of payments
company-to-company
Сard to account Account to card
According to the Law of Ukraine "On Prohibition of
Gambling Business" (expired on 13.08.2020) – gambling
– it is any game in which the player must pay money,
including through a system of electronic payments, which
allows the participant to receive a prize in any form, and
not to receive it depending on by accident.

20. 20
Activities of LLC FC “LEOGAMING PAY”
in the field of electronic money use
Distribution
ЕM of PROSTIR
From December 3, 2019,
the were distributed EM
for amount 26.4 mln UAH
Settlement agent
Repayment of EM to
PROSTIR from 12/01/2017
30,4 mln UAH
Transfer of funds
in favor of clients
of the Institution
LLC "BUSLE" and
LLC "WANGAME"
Number of EM users
for the period 04/28/2020 –
12/10/2020
8 763
Leowallet (app)
No verification!
from 04/28/2020
(violation of Article 14)
=12.2 mln UAH
ISSUER
UKRGASBANK

21. Violations that are referred to lawyers
21
 Failure to ensure the functioning of a proper risk management system, application of a risk-oriented approach and
taking appropriate measures to minimize risks (or non-implementation of the NPC) requires discussion with lawyers;
 Improper fulfillment of the requirement to submit (draw up, certify) in time and in full at the request of the National
Bank as a subject of state financial monitoring reliable information and / or documents (conclusions, decisions, etc.),
copies of documents or extracts from documents related to execution the subject of primary financial monitoring of the
requirements of the legislation in the field of prevention and counteraction;
 Failure to properly verify the transfer by verifying the payer (initiator of the transfer) (for EG transactions);
 Inadequate fulfillment of the financial company’s requirement to develop, implement and update financial monitoring
rules, financial monitoring programs and other internal documents on financial monitoring, as well as failure to provide
procedures sufficient to ensure effective risk management;
 Not accompanying the transfer, in particular the unique number of the electronic payment instrument of the payer
(initiator transfer);
 Failure to check that the person's representative has the appropriate authority on the basis of official documents;
 Absence of date during making copies of identification documents;
 Failure to record the functional responsibilities necessary for the effective functioning of the internal system
 APC / FT and understanding of employees of the company of their responsibilities and credentials in the field of
APC / FT;
 Failure to reassess the client's risk;
 Failure to provide the date of receiving documents regarding the study of clients (norm of Regulation 388.)