From Prohibition to Supervision: Licensed Betting in Uzbekistan and the Control of Payment Flows, Financial Crime and Consumer Harm

Abstract

In July 2026 Uzbekistan issued its first licences for online bookmaking, under a framework adopted in 2024. This article argues that the reform is better understood as a shift from prohibition to supervision than as the legalisation of a new activity, because betting demand, and the payment channels serving it, existed throughout the period of prohibition. Using doctrinal legal analysis, comparative regulatory analysis and a structured review of 30 documentary sources, including Uzbek legislation, Central Bank of Uzbekistan materials, regulatory reports from Sweden, the Netherlands, Denmark, the United Kingdom and Australia, and recent public-health and household-finance research, the article examines what licensing changes for anti-money laundering (AML), fraud prevention and consumer protection, and what it leaves unresolved. It finds that Uzbekistan's centralised register of bets and players gives the state an unusually strong technical basis for supervision, but that its effectiveness will depend on controls not yet clearly required: alignment between account holder and payment instrument, closed-loop payments, a monitoring role for banks, attention to credit-funded gambling, binding affordability limits and market-wide self-exclusion. The article proposes that the reform be evaluated against three outcomes: a shrinking illegal market, more transparent financial flows, and contained consumer and social harm. It also recommends that baseline data be collected now, before those outcomes can no longer be measured against a starting point.