Kazakhstan Shows 8 ESU Betting Brands vs 9 in Licence Register

Kazakhstan’s public betting records currently give two different counts: nine licensed brands and eight brands listed as connected to the Unified Accounting System, or ESU. PIN-UP is the only name present in the licence count but absent from the ESU list.
The Centre for Monitoring and Analysis of Gambling, which operates the system, currently names eight connected brands: FONBET, OLIMPBET, 1XBET, OINABET, TENNISI, PARIMATCH, UBET and WINLINE.
Eight ESU Brands Map to Seven Companies
The eight brands on the current ESU page map to seven legal entities. OINABET and TENNISI are both listed under Adal Oyin LLP. Each of the other six brands has a separate company behind it.

However, Kazakhstan’s August 25 betting-licence register gives a different brand count. It contains eight licence holders but nine betting brands, because TENNISI and OINABET share one licence. PIN-UP is the only brand in that register that does not appear on the current ESU-connected list.

The August register lists pin-up.kz under Bonami LLP. An earlier June 23 version also contained Alviya LLP for the same website under licence No. 26261267, issued that day and valid until June 23, 2036. Alviya is absent from the August snapshot.
The comparison is therefore at brand level, not licence-holder level.
ESU Sits Inside the Betting Payment Flow
Kazakhstan’s Gambling Business Law requires bookmakers to account for bets through the ESU. Electronic bets must be accepted through the system, while betting software cannot operate without ESU integration.
The law also sets an integration timetable. After receiving a regulator notice, an operator has three working days to sign an integration agreement and 15 working days to connect its software to the ESU.
The public records reviewed by 15M do not show when any such notice was sent in relation to PIN-UP. The registry gap alone therefore does not establish a breach.
June Timing Does Not Explain Current Gap
The regulator published an earlier list of bookmakers that had completed ESU integration on June 4. Alviya appeared in the June 23 licence register 19 days later, so it could not have featured in that earlier integration document.
That timing does not explain the current discrepancy. The ESU operator says its public list changes as the set of connected organisers changes, yet PIN-UP remains absent from the current version. The mismatch remains in the latest public records reviewed by 15M.