Taras Miroshnychenko

Head of International Corporate Law and Fintech Practice

Phone numbers
+38 (073) 007-44-36

Expert in fintech, crypto, and international corporate law with over 20 years of experience. Specializes in crypto licensing (VASP/CASP), iGaming business support, and international structuring, asset protection, and OSINT analytics for risk assessment and due diligence.

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Case: Legal Opinion on compliance with Austrian law (Estonian company)

Fintech
Reading time: 3 min.

Service: Legal Opinion

Prikhodko & Partners Law Firm was commissioned by a client—an Estonia-registered gambling company—planning to scale its business and open additional accounts with several international payment systems. One of the key requirements from partners and financial institutions was confirmation that the company does not operate in the Austrian market. To this end, the client needed a legal opinion confirming compliance with Austrian law and transparency of the corporate structure.

Client’s Request

The company was actively operating in online gambling across the Baltics and Eastern Europe, and planned to onboard new payment providers in 2025. Opening accounts required proof that the corporate structure and business model comply with international AML/KYC standards, as well as documentary confirmation of no operations in Austria, which has particularly strict gambling regulations.

where online gambling is legal

Work Stages

  1. Preliminary audit of the client’s activity.
    Prikhodko & Partners reviewed the Estonian company’s corporate documents, business model, and client geography. Special focus was placed on transactions and marketing materials to exclude indicators of targeting the Austrian market.
  2. Analysis of Austrian law.
    We analyzed:
  • Gambling Act (Glücksspielgesetz, GSpG) — regulation of gambling activity in Austria;
  • Finanzmarkt-Geldwäschegesetz (FM-GwG) — anti–money laundering rules;
  • FMA (Austrian Financial Market Authority) requirements regarding the transparency of foreign operators.
  1. Drafting the legal opinion.
    We prepared a document confirming:
  • no indicators of directing activity at Austrian users;
  • the client’s internal AML/KYC policies aligned with EU Directives (AMLD5, AMLD6);
  • the corporate structure’s compliance with transparency requirements (§ 2 FM-GwG).
  1. Interaction with the client.
    The company provided additional evidence of no ad campaigns in Austria, IP blocking for this country, and agreements with geofiltering providers.
  2. Finalization.
    The final English-language legal opinion was delivered within the agreed timeframe — within 10 business days.

Result

  • The client successfully opened accounts with two international payment systems that required confirmation of compliance with Austrian law.
  • Gained the ability to scale into new jurisdictions without the risk of payment blocks.
  • Demonstrated to partners the transparency of the corporate structure and the absence of intent to enter the Austrian market, removing key regulatory risks.
legal opinion

Conclusions

In 2025, Austria ranks among the EU leaders in the strictness of control over gambling and financial monitoring. According to FMA, in 2024–2025 more than 40% of applications by foreign companies for payment system services were rejected precisely due to the lack of a proper legal opinion or non-compliant AML documentation.

Therefore, for companies operating in gambling or fintech, a well-prepared legal opinion becomes a key element of international scaling.

How Prikhodko & Partners Helps

We support clients with:

  • preparing legal opinions for banks and payment systems across the EU;
  • confirming compliance with gambling laws in Austria, Malta, Cyprus, and other jurisdictions;
  • setting up AML/KYC procedures;
  • protecting companies from risks of transaction blocks and penalties.

If you plan to scale your gambling or fintech business and work with international financial institutions, the Prikhodko & Partners team will prepare a legal opinion that meets the highest standards and regulators’ requirements.

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