Gaming Law 2025 Comparisons

In 2024, the National Assembly of Armenia adopted the Law on the Regulation of Gaming Activities (known as the “Gaming Law”), which entered into force on 1 January 2025. The Law introduced the principles of responsible gambling and fair play, as well as geo-blocking mechanisms designed to prevent Armenian residents from participating in foreign gambling platforms. Furthermore, the Gaming Law stipulated that a register of restricted domains be maintained and shared with the Central Bank of Armenia to block related financial transactions.

Gaming organisers are also required to host their online resources under the “.am” domain, a measure aimed at enhancing regulatory control. Although these reforms are expected to improve supervision and compliance, their practical effect has yet to be fully observed due to the Law’s recent entry into force.

Enforcement of consumer protection has intensified in parallel. In 2024, the Competition and Consumer Protection Commission (CCPC) imposed a landmark sanction on major online gaming activity organisers for unfair competition, including misleading advertising practices targeting both users and non-users.

Separately, the National Assembly adopted the Law on Crypto Assets on 29 May 2025 (effective 4 July 2025), while legislative work continues on a new Cybersecurity Law. Neither instrument introduces gambling-specific regulations.

Institutionally, responsibility for developing and implementing state policy in the field of gaming activities has been transferred from the Ministry of Finance to the Ministry of Economy, which now serves as the principal authority exercising state oversight over the sector.

The Operator

A major structural innovation in Armenia’s reformed gaming regulatory framework is the introduction of the Operator, a distinct entity entrusted with wide-ranging technical, administrative, and monitoring functions. Operating under a model comparable to public–private partnership (PPP) structures, the Operator acts as an intermediary between the state and gaming organisers, facilitating operational oversight while remaining separate from the direct conduct of gaming activities. Its responsibilities include administering the issuance, renewal, and suspension of operational certificates; certifying gaming products or validating international conformity certificates; ensuring the integration of gaming systems with the central monitoring centre; setting service fees within government-approved caps; and proposing technical standards and responsible gaming practices to the competent authorities. The Operator also conducts market monitoring, analyses risks, and provides recommendations to the regulatory authorities regarding industry developments, regulatory improvements, and player protection mechanisms.

The Government Resolution No 1149-N (“On the Procedure for Conducting the Competition for Selecting the Operator of Gaming Regulation, the Procedure for Participation in the Selection Process through a Consortium, the Procedure for Concluding a Contract with the Operator, and the Grounds for Declaring the Competition Void”) provides detailed rules governing the selection and contracting of the Operator. It establishes transparent criteria for participation, allows for consortium-based applications, and defines procedural safeguards for competition and contract conclusion. Through this framework, Armenia has institutionalised a hybrid model in which the Operator serves as a regulated partner of the state, managing certification, monitoring, and data access functions, while the government retains strategic and regulatory control over the gaming sector.

The regulatory framework in Armenia is generally licence-based and permissive, allowing both land-based and online operations subject to regulatory oversight by the competent governmental authority.

The legislation distinguishes between the following regulated categories:

• games of chance;
• internet games of chance;
• bookmaker activity (including totalisers); and
• lotteries.

The following outlines the legal status of key sectors.

Betting

Classified as bookmaker activity. Permitted on the basis of a bookmaker licence and the right to accept bets. Operations may be conducted exclusively through the organiser’s official website and mobile applications indicated in the licence.

Bingo

Not expressly defined in primary legislation. Likely falls within games of chance or lotteries, depending on structure. Permitted when conducted under an appropriate casino or lottery licence.

Casino

Permitted both in land-based and online formats, subject to licensing. Licensees must utilise certified gaming software and connect to the central monitoring system operated by the authorised state body.

Lotteries

Regulated under the Law on Lotteries and the Gaming Law. The Gaming Law explicitly prohibits the organisation of traditional lotteries (including instant (no-draw), draw-based, and combined formats) via electronic means or internet access within the Republic of Armenia, while land-based lotteries remain permitted.

Fantasy Sports

Not specifically regulated under existing legislation. Where no monetary stakes or winnings are involved, such activity may fall outside the scope of gambling laws. If linked to real-money wagering, it would likely be considered a game of chance and would require licensing.

Social Gaming

Generally exempt from the Gaming Law. Intellectual or knowledge-based games organised through audiovisual media or the internet, which award prizes rather than winnings, are unregulated. If such games involve in-app purchases convertible to monetary value or wagers, they become subject to gambling regulation.

Poker

Not separately defined in the legislation. Likely considered a game of chance and therefore permitted only under a casino licence. Online poker is subject to the same licensing and monitoring requirements applicable to internet games of chance.

Totalisers

Recognised as a form of bookmaker activity involving pooled betting on events. Permitted upon licensing under the same conditions as other bookmaker operations.

In Armenia, both land-based and online gambling operate under the same overarching regulatory framework, although certain practical distinctions apply. Land-based gambling is physically restricted to designated zones, including:

• Tsakhkadzor;
• Jermuk;
• Sevan;
• Meghri; and
• specific free economic zones such as Zvartnots Airport in Yerevan.

Large-scale projects approved by the government (with investments exceeding AMD40 billion) may also be permitted in other locations.

Venues must comply with minimum distance requirements from sensitive sites, such as schools, hospitals, and cultural centres, and are typically limited in size. Furthermore, all gaming products used must possess the required certification, ensuring compliance with Armenian legal and technical standards.

The gaming sector in Armenia is regulated through a framework of laws and normative legal acts. The key legislation and regulatory instruments are outlined here.

Law on the Regulation of Gaming Activities (No HO-263-N)

This establishes the regulatory framework for gaming activities, with the primary objectives of protecting players’ interests, enhancing oversight through electronic management systems, and setting mandatory technical requirements for gaming products in line with international standards.

Law on Lotteries (No HO-3-N)

This governs the organisation and conduct of lotteries and provides for state supervision of such activities.

Law on Games of Chance, Internet Games of Chance, and Casinos (No HO-1-N)

This regulates the organisation and operation of games of chance, internet games of chance, and casinos, and establishes state oversight over these activities.

Government Resolution on the Procedure for Conducting the Competition for Selecting the Operator of Gaming Regulation, the Procedure for Participation in the Selection Process through a Consortium, the Procedure for Concluding a Contract with the Operator, and the Grounds for Declaring the Competition Void (No 1149-N)

This sets out the rules and procedures for conducting competitions to select the gaming regulation operator, including consortium participation, contract conclusion, and grounds for declaring the competition void.

Government Resolution on Establishing the Procedure for Licensing the Organisation of Gaming Activities (No 855-N)

This defines the licensing requirements and procedures for organising gaming activities in Armenia.

Government Resolution on Establishing the Procedure for Approving the Rules for the Organisation and Conduct of Gaming Activities (No 310-N)

This provides the process for approving rules governing the organisation and operation of gaming activities.

Prime Minister’s Resolution on Establishing the Composition and Rules of Procedure of the Interagency Competition Commission for the Selection of the Gaming Regulation Operator (No 670-L)

This establishes the composition and procedural rules of the interagency commission responsible for selecting the gaming regulation operator.

Order of the Minister of Finance on Establishing the Procedure for Verifying That a Bank Account or Card Used by an Online Gaming Activity Organiser to Fund a Dedicated Gaming Account Belongs to the Player who is the Owner of that Dedicated Gaming Account (No 315-N)

This sets out the procedure for verifying that the bank account or card used by an internet gaming activity organiser to credit a dedicated gaming account belongs to the player who is the rightful owner of that account.

Order of the Minister of Finance on Establishing the Procedure for Verifying the Banking Account or Card Provided for Crediting Funds to a Dedicated Gaming Account Belonging to a Player Who is a Citizen of the Republic of Armenia, Either Through Participation in a Lottery (Totaliser) or Through Individual Gaming Cards Provided by Gaming Activity Organisers for Conducting Bets or Games (No 317-N)

This provides the verification procedure for bank accounts or cards used to credit funds to a dedicated gaming account belonging to Armenian citizen players, whether through lotteries, totalisers, or individual gaming cards issued by gaming activity organisers.

The term “gambling” is not expressly defined under Armenian law. However, it falls within the broader scope of the term “game” as defined in the Law on the Regulation of Gaming Activities. According to this law, a game encompasses any of the following: a game of chance, an internet game of chance, a game organised through bookmaker activity, or a lottery.

Game of Chance

This refers to any mechanised game, conducted through gaming products designed for programmed and/or mechanical play, that is based on risk and offers the opportunity to win. The winner is determined by a specific program or mechanical system contained within the product, with the player’s direct or indirect participation. The term also covers live games, in which a dealer participates alongside the player (acting on behalf of the organiser to conduct or verify the outcome), or games in which multiple players participate simultaneously without a dealer (except mechanised games).

Internet Game of Chance

This means a game of chance organised via internet access using gaming products. Such games may also be conducted through physical gaming halls.

Bookmaker Activity

This refers to the organisation of accepting, recording, and paying winnings on bets placed on the possible outcomes of sporting, gaming, social, political, or other events, as well as creating opportunities for players to place such bets (including through the granting of rights in any form). Bookmaker activity may also be conducted through a gaming hall.

Lottery

A lottery is defined as a public event during which the organiser conducts a drawing of a prize fund among participants. The outcome depends solely on chance and is not influenced by the organiser’s actions or will. Lotteries, too, may be organised through gaming halls.

Under Armenian law, “gaming” broadly includes all forms of gambling activities. The legal framework does not differentiate between land-based and online gaming; thus, the statutory definition applies equally to both formats.

See 3.3 Definition of Land-Based Gambling.

Administrative Offences

The Armenian Code of Administrative Offences lists a number of breaches in the gambling sector that are subject to administrative penalties, as listed here.

• Failure or improper performance by public electronic communications network operators providing internet access services of their obligations, as prescribed by the Law on Regulation of Gaming Activities, to block access to websites of gaming interactive platforms organised in foreign states by entities that do not hold the relevant license required under the legislation of the Republic of Armenia – penalises the public electronic communications network providers for failure to carry out the geo-blocking obligations under the Gaming Law.
• Violation of the requirements of the Law of the Republic of Armenia “On Combating Money Laundering and Terrorism Financing (the “AML Law”)” and the legal acts adopted pursuant to that Law ‒ sanctions the head of a legal entity that is a non-financial institution, the responsible person of organisers of games of chance, internet games of chance, lotteries, or games organised through bookmaking activities, as well as an official of a state body vested with obligations under the AML Law for violating the requirements imposed upon such entities.
• Use, without the relevant registration (licence), of unauthorised or legally prohibited words, as well as the use of certain words in a name, advertisement, or public offer by unlicensed persons, or any form of assistance in such advertising ‒ given that the Gaming Law prohibits the use, in the name of an organisation, trade name, trademark, website name, or signage, the words “game of chance” (including “casino” or “gaming hall”), “internet game of chance,” “lottery,” “bookmaking activity” (including “bookmaker’s office” or “totaliser”), as well as any of their derivatives or translations, the Code sets out penalties for such restricted use.
• Carrying out activities in the areas of trade, public catering, restricted services, or household services without the requisite authorisation – prohibits operating gaming and lottery facilities, or casinos after midnight without the required authorisation.

Criminal Offences

The Criminal Code establishes a few offences related to engaging in unlawful gambling:

• the organisation of or participation in gambling by a person held in a place of detention, pre-trial detention facility, or correctional institution – makes it a criminal offence for people held in correctional institutions to participate in or organise gambling activities; and
• the organisation of or participation in gambling by a service member ‒ penalises organisation or participation in gambling by a service member in a military unit, in another place of military service, or during the performance of military duties.

The Criminal Code further establishes the offence of illegal entrepreneurial activity, criminalising any business activities that are carried out without the requisite licence. 

In Armenia, unlawful gambling is subject to a combination of administrative and criminal sanctions, depending on the nature of the offence and the identity of the perpetrator.

Administrative penalties primarily target gaming activity organisers and public electronic communications network operators. This includes establishments operating beyond permitted hours, with fines ranging from AMD200,000 (EUR448) to AMD300,000 (EUR672), escalating to AMD500,000 (EUR1,119) for repeat offences. Public electronic communications network operators that fail to block access to unlicensed foreign gambling platforms may face fines of up to AMD1,000,000 (EUR2,239), rising to AMD3,000,000 (EUR6,717) for repeated violations. Other breaches, such as violations of anti-money laundering obligations or the improper use of prohibited or unlicensed terminology in advertising or company names, are also subject to fines of up to AMD1,000,000 (EUR2,239) or formal warnings with corrective instructions.

Criminal liability applies in more serious or restricted contexts, such as gambling by individuals in detention or correctional institutions, or by service members during military service. Penalties vary depending on the conduct, ranging from short-term imprisonment and restriction of military service for participation (up to one year) to longer custodial sentences for organising gambling activities (up to two years).

For illegal entrepreneurial activities, the sanctions vary from fines to imprisonment, with harsher penalties in cases of causing especially large property damage. In calculating the damage, the amount of licensing fees is also included.

Overall, the Armenian regulatory and criminal framework combines preventive and punitive measures. Administrative fines and corrective instructions are designed to regulate and discipline gaming activity organisers, while criminal sanctions serve to protect vulnerable populations and maintain order within state and military institutions.

Under the Gaming Law, the key regulatory authorities in Armenia’s gaming sector are the Competent Authority and the Supervisory Authority, supported by functions carried out by the Operator under a model akin to a PPP.

• The Competent Authority (state executive body, currently the Ministry of Economy, succeeding the Ministry of Finance) is responsible for developing and refining gaming legislation, formulating licensing policy, issuing licences, supervising compliance with licence requirements, and exercising other powers as prescribed by law. Before the establishment of the Operator, the Competent Authority will continue to be responsible for many of the operational functions delegated to the Operator.
• The Supervisory Authority (State Revenue Committee) oversees licensed gaming activity organisers, ensures compliance with applicable laws and regulations, and monitors gaming activities. The Supervisory Authority also examines complaints lodged by players against gaming activity organisers.
• The Operator executes key operational functions, including:
1. the issuance, renewal, and revocation of operational certificates;
2. verification of gaming product conformity certificates;
3. connection of gaming products to the central monitoring system;
4. provision of market monitoring, data management, and analytical services; and
5. support for responsible and fair gaming practices.

The Operator also provides technical guidance, collaborates with public authorities, and ensures the flow of information to the Competent and Supervisory Authorities, effectively acting as an operational arm of the state within a public-private partnership framework.

Armenia adopts a primarily prescriptive regulatory approach for the gambling sector. The framework is codified in the Law on Regulation of Gaming Activities and relevant secondary legislation, prescribing detailed requirements for licensing, operational standards, location constraints, technical compliance, and reporting obligations.

Under the Armenian regulatory framework, licences are principally categorised according to the type of gaming activity the organiser intends to conduct:

• licence for the organisation of games of chance or internet games of chance;
• licence for the organisation of bookmaking activities; and
• licence for the organisation of lotteries.

Licences are generally available, subject to compliance with legal, financial, and operational requirements. However, certain licences, such as those for organising games of chance or internet games of chance in Yerevan, or for large-scale investments, are limited by geographic zoning, minimum investment thresholds, and government approval. Online licences are available to gaming activity organisers who meet the technical and monitoring requirements prescribed by the Law on Regulation of Gaming Activities.

Under the Government Resolution on Establishing the Procedure for Licensing the Organisation of Gaming Activities, licences may be granted for an indefinite period, irrespective of the type of gaming activity. The Gaming Law provides for the suspension or revocation of licences in specific circumstances, including breaches of the Gaming Law, failure to fulfil tax obligations, or non-compliance with requirements set out in the orders of the Supervisory Authority. Licences may also be terminated upon the organiser’s request.

Application requirements for both land-based and online organisers are set out in the Government Resolution on Establishing the Procedure for Licensing the Organisation of Gaming Activities. While the general framework applies to all applicants, there are distinct differences between land-based and online gambling activities.

For land-based gambling, applicants must specify the location of the gaming hall. They are required to submit proof of property ownership or the right to use the premises, including floor plans, certificates confirming the installation of fire safety and alarm systems, declarations regarding compliance with spatial standards and minimum distance requirements, or hotel classification standards if the gaming hall is located within a hotel or motel.

Online gambling applicants must disclose their official website, any gaming applications they use, and the locations of their servers. Where online gambling is conducted directly through a physical gaming hall, the hall’s address must also be provided, and the hall-specific requirements, including fire safety and surveillance, apply. The applicants must submit a certificate confirming website compliance and a declaration confirming the availability of a deposit in an Armenian bank equivalent to twice the annual state fee.

All applicants, regardless of the type of activity, must submit:

• tax clearance certificates confirming that there are no overdue liabilities;
• the rules and regulations governing the conduct of gambling activities approved by the relevant management body;
• certificates of compliance for gaming equipment; and
• a copy of the responsible person’s operational certificate.

In summary, although all licence applications share a baseline of organisational, tax, and operational compliance requirements, land-based licences place greater emphasis on physical compliance, including property ownership, spatial standards, fire safety, and surveillance. In contrast, online gambling licences focus on digital infrastructure, website compliance, and financial guarantees, with hall-specific requirements applying only where online gambling is operated through a physical gaming hall.

Once an application is properly submitted, the licence is generally issued within 23 business days, subject to a possible extension of an additional 23 business days if the supporting documents contain information requiring further examination, with the applicant duly notified of any such extension.

An application will be refused if the submitted documents fail to comply with legal requirements or contain false information, if the applicant does not meet the eligibility criteria, if the rules governing the organisation and conduct of the gambling activity conflict with applicable laws or pose a risk to participants, or if there are reasonable grounds to suspect that invested funds have been obtained unlawfully. Applications may also be refused in other cases provided by law.

The Armenian regulatory framework does not prescribe any separate fees for submitting licence applications. Instead, state duties apply for obtaining a licence, forming part of the annual financial obligations of organisers operating under a valid licence.

Pursuant to the most recent amendments to the Law on State Duty, the framework for calculating these licensing fees for gambling activities has been revised. Under the updated provisions, the annual licensing fee for lotteries, bookmaker activities, and internet games of chance is AMD600 million (EUR1,343,454), while the fee for casinos and games of chance varies according to the location of the establishment. Specifically, casinos and gaming halls in Tsakhkadzor are subject to a fee of AMD180 million (EUR403,036), in Sevan AMD150 million (EUR335,863), in Jermuk AMD100 million (EUR223,909), in Meghri AMD35 million (EUR67,172), and in other locations AMD5.5 billion (EUR12,314,995).

All fees are payable in accordance with the rules set out under the Law on Licensing and the Law on State Duty.

Licensing fees in the gaming sector are annual and remain payable by the game organiser for the duration of the licence, until the licence is suspended or revoked.

Armenia does not have a standalone “personal gambling licence”. However, individuals who hold significant stakes (10% or more), beneficial ownership or key managerial roles in gaming activity organisers must obtain regulatory approval from the authorised body before acquiring such status.

Responsible Persons and Significant Participants

A gambling organiser may only obtain a licence if its responsible persons, significant participants, beneficial owners, and their affiliated persons meet the statutory suitability and integrity requirements. Responsible persons include the executive head of the organiser’s governing body, the manager of the gaming hall, the head of the internal monitoring unit responsible for anti-money laundering and counter-terrorist financing (AML/CFT), or another duly appointed representative. The law disqualifies individuals from holding a significant interest or serving as a responsible person where they have a criminal conviction for an intentional offence that has not been expunged or annulled, have been disqualified by court judgment from holding positions in the financial, commercial, economic or legal fields, have been declared bankrupt with outstanding liabilities, have failed to substantiate the lawful origin of their funds, or have been involved in a gambling business whose licence was revoked as a disciplinary measure within the previous three years. Similar restrictions apply to legal entities whose key shareholders or executives fall within these categories.

Approval Process

Before acquiring a significant shareholding or being appointed as a responsible person, an applicant must undergo a formal fit-and-proper assessment by the competent authority (the authorised body overseeing gambling regulation). The assessment process is initiated either through a direct application by the applicant (in the case of a significant shareholding) or via an intermediary application submitted by the organiser (in the case of responsible persons). The submission must include all required documents and information that verify the absence of disqualifying circumstances. The authorised body must review the application within one month of receiving a complete file. This period may be extended once, for up to an additional month, if further examination is required. If no negative decision is issued within the statutory timeframe, the approval is deemed granted. A negative conclusion is issued if the authority finds any of the disqualifying circumstances set out by law or has reasonable grounds to suspect that the funds used for participation in the charter capital were obtained through unlawful means. The burden of proof regarding the lawful origin of funds lies with the applicant.

Operational certificate

In addition to the above approvals, the responsible person managing gaming operations must hold an operational certificate. This certificate attests to their qualification and suitability to manage gambling activities. The regulator may suspend the certificate if the holder no longer meets the legal requirements, fails to comply with the obligations set out by law, provides false information in the application, or is associated with a gaming activity organiser whose licence has been revoked as a sanction.

Under Armenian law, premises used for organising land-based gambling activities, including casinos, gaming halls, and internet games of chance conducted through a gaming hall, must comply with specific location and operational requirements. Gambling establishments are permitted only within the administrative boundaries of Tsakhkadzor, Sevan, Jermuk, and Meghri, and must maintain a minimum distance from certain public and cultural facilities. In Tsakhkadzor and Sevan, premises must be located at least 100 metres away, and in Jermuk and Meghri, at least 50 metres away, in a straight line from educational or cultural institutions, government or municipal buildings, and hospital areas.

The law further prescribes minimum space requirements. In Tsakhkadzor, Sevan, and Jermuk, casinos must occupy at least 250 square metres and gaming halls at least 100 square metres; in Meghri, the respective thresholds are 200 and 80 square metres. Between 50% and 70% of the total area must be designated as the gaming floor, with the remaining space allocated to ancillary facilities such as a lobby, cashier’s area, and restrooms.

Each establishment must have a separate entrance lobby adjacent to the main entrance, where customer identification and data registration take place to ensure compliance with the minimum age requirement of 21 years. Operations are permitted only at the address specified in the licence, and gaming halls must not be visible from the outside.

Additional operational safeguards include the installation of fire and security alarm systems, continuous video surveillance of both the interior and the exterior of the gaming area, visible display of game rules, the permanent presence of a responsible person on-site, and strict adherence to AML/CFT requirements. Video recordings must be retained for at least 30 business days and made available to competent authorities upon request.

In Armenia, there are no specific regulations governing B2C licences. The relationship between game organisers and players is regulated by a contract that follows the organiser’s rules and regulations. This contract can be formalised by issuing a lottery ticket, receipt, or other document, which may be in electronic form, or by creating a gaming account. It is deemed concluded under the terms set out in the organiser’s rules upon such issuance or account creation.

No explicit regulatory framework governs B2B licences under Armenian law. However, the Gaming Law provides that where a gambling organiser’s functions are delegated to third parties, whether under a mandate, commission, agency, guarantee agreement, power of attorney, or any other arrangement, the activities of such third parties must be licensed in accordance with the general procedure established by law.

The Gaming Law does not explicitly regulate the use of affiliates. However, when a gambling organiser delegates its functions to a third party under any arrangement, that third party must obtain a licence to conduct gaming activities in accordance with the general licensing procedure. Additionally, the law extends the same regulatory requirements applicable to responsible persons and significant participants to their affiliates.

Similar to affiliates, the use of white-label providers is not explicitly addressed under Armenian gaming legislation. However, the general licensing and regulatory requirements effectively extend to such arrangements.

Under Armenian law, participation in gambling organised in foreign jurisdictions and the advertising of such activities within Armenia is prohibited. To enforce this, the law provides for the blocking of websites offering foreign gambling services via public electronic communications network operators providing internet access services, based on a list established by an inter-agency commission and approved by the Supervisory Authority. The Supervisory Authority also coordinates with the Central Bank to restrict payments to such websites.

Gambling organised on interactive platforms is considered foreign if the organiser’s information resources are outside the Armenian “.am” domain.

Technical measures also include connection to the operator’s monitoring centre, use of certified gaming products, and verification of gamer bank accounts or cards through social service number, Merchant ID, and MD order, as regulated by two Minister of Finance Orders.

While the regulatory framework is fully established, the specific technical measures, such as IP blocking, monitoring, and payment restrictions, will be implemented once the Operator is formally elected and fully operational.

Under the Gaming Law, Responsible Gambling is defined as a set of rules for regulating the gaming sector based on principles of player protection, game integrity, and the prevention of gambling addiction. These rules aim to assist individuals suffering from gambling problems and protect players from potential negative consequences.

Under Armenian law, participation in gambling activities is subject to strict restrictions to protect vulnerable individuals and minors. Citizens receiving certain government financial assistance, those living in social housing, individuals declared bankrupt or with outstanding public debts, and persons registered at the National Centre for Addiction Treatment are prohibited from participating in gambling. Age-based restrictions also apply: persons under 21 are prohibited from engaging in games of chance or bookmaking activities, while those under 18 are barred from participating in lotteries.

In addition, individuals deemed legally incapacitated due to causing financial hardship to their families are restricted from gambling, with guardianship authorities notifying the Competent Authority and the Operator to block access to gaming venues and online platforms. Voluntary self-exclusion is also permitted; citizens may request to be barred from gambling, with restrictions taking effect immediately and potentially lasting indefinitely, subject to a minimum one-year period before the restriction can be lifted.

The Operator is responsible for maintaining a monitoring system to enforce these restrictions, including the identification of restricted individuals through authorised databases and account verification. Organisers must ensure that their systems are coordinated with the Operator to apply participation restrictions effectively. Risk factors such as frequent changes of IP address may trigger additional scrutiny to prevent circumvention of the rules.

In Armenia, the Operator employs a suite of gambling management tools to ensure player protection, responsible gambling, and compliance. Participation restrictions prevent minors, bankrupt individuals, socially vulnerable persons, and other restricted categories from accessing gambling activities, with verification conducted through authorised databases and monitoring systems. Citizens may also self-exclude, with the Operator obliged to enforce the restriction immediately.

Identification and monitoring systems track high-risk or unusual activity, including frequent IP changes, while personal and operational licensing ensure that only fit and proper individuals manage operations. Technical measures, including IP blocking, prevent access to unlicensed or foreign gambling sites. Collectively, these tools establish a robust framework for safe and responsible operation.

The primary AML legislation in Armenia is the AML Law, which applies to all sectors, including the gaming sector. In addition, the Gaming Law imposes specific AML obligations on the organisers of gaming activity, requiring them to identify players in order to monitor their compliance with the AML Law. Additionally, the Supervisory Authority is responsible for overseeing compliance with the law’s requirements concerning the Operator’s founders, shareholders, partners, or beneficial owners.

This oversight applies both during the Operator’s selection and throughout its ongoing operations. It may be conducted using standard regulatory procedures as well as information obtained through operational or investigative measures, with the consent of the individuals concerned. Those subject to oversight must also consent to the disclosure of results from customer due diligence carried out by financial institutions under the AML Law, providing such results in person if necessary.

The Supervisory Authority is responsible for ensuring that organisers comply with the AML Law and related regulations. Oversight is conducted through on-site inspections or documentary reviews. If non-compliance or improper compliance is identified, the authority may impose the sanctions and measures provided under the law.

Casinos, gambling organisers, including online gaming providers, and lottery organisers are designated as reporting entities under the AML Law. They are required to report both suspicious transactions and transactions subject to mandatory reporting thresholds to the competent authority. For specific transactions, such as purchasing lottery tickets, placing bets, and receiving winnings, reporting is required for any transaction amounting to AMD1 million or more (approximately EUR2,239).

In addition to reporting obligations, these entities are required to conduct customer due diligence. This includes identifying and verifying the identity of clients, authorised representatives, and ultimate beneficial owners using reliable official documents, and obtaining sufficient information about the client’s business and the purpose and intended nature of the transaction or relationship. Reporting entities must also ensure that information obtained from other financial or non-financial institutions is accurate and that ultimate responsibility for customer due diligence rests with them. Where there is a risk of revealing suspicions to the customer related to money laundering or terrorist financing, reporting entities may limit the due diligence process to identification and verification while still reporting suspicious activity to the competent authority.

This framework ensures that gambling organisers play a key role in preventing illicit financial activity, striking a balance between effective oversight and the practicalities of ongoing customer relationships.

Under the Gaming Law, the Supervisory Authority is responsible for monitoring compliance with advertising requirements and restrictions and is empowered to impose financial penalties on organisers for any breaches.

The Armenian Law on Advertising defines “advertising” as the dissemination of information about legal or natural persons, products, ideas, or initiatives to an indeterminate number of individuals through various types of information channels, intended to generate or maintain interest in the relevant persons, products, or initiatives.

Advertising of lotteries, games of chance (including online games of chance), and casino operations is governed primarily by the Gaming Law and the Law on Advertising.

Only licensed gaming activity organisers are permitted to advertise within Armenia. Advertising must comply with content, format, and timing requirements approved by the supervisory authority.

The competent authority has the power to monitor compliance, issue guidance on acceptable advertising practices, and impose penalties for breaches.

Under Armenian law, the advertising of lotteries, gambling activities, including online gambling, and casino operations is subject to strict limitations. Promotion of monetary winnings through mass media is prohibited. Broadcasting of prize draws, or combined lottery winnings, is permitted only in accordance with the schedule and procedures approved by the competent authority, limited to the hours between 22:00 and 07:00, and may not exceed a total duration of 30 minutes. External advertising is restricted in size and may display only the corporate name or logo. Larger signs are not to exceed 5 square metres, and smaller signs at building entrances are limited to 0.5 square metres.

All advertising must include age-appropriate markings: “21+” for games of chance (including online games of chance), totalisers, and casino promotions, and “18+” for lottery advertising. It is prohibited to depict minors or monetary assets in advertisements, target minors, create the impression of guaranteed winnings, present gambling as a source of regular income or an alternative to employment, suggest social or professional success through gambling, or criticise non-participation. Advertisements must include a clear warning regarding the prohibition of playing while intoxicated or under the influence of substances, and the risk of financial loss, which must be as prominent as other information in the advertisement.

Unlicensed organisers of lotteries, games of chance, internet games of chance, or casinos are prohibited from advertising within Armenia. Advertising via public broadcasters is further restricted: games of chance (including online games of chance), lotteries, casinos, nightclubs, tobacco products, and other prohibited goods or services may not be promoted as sponsors or featured in programmes. Advertising of foreign gambling activities within Armenia or via websites accessible from Armenia is prohibited, including both facilitation of access and promotional content.

Exceptions are limited to official websites and premises of authorised organisers, or, in the case of lotteries, to authorised points of sale.

Under the Gaming Law, non-compliance with advertising rules is subject to fines of up to AMD2 million (EUR4,478) per instance.

Under Armenian law, any individual or entity acquiring a significant participation (10% or more) in a gambling organiser must undergo a fit-and-proper assessment by the Competent Authority before the acquisition. Organisers must submit information on new significant participants, including evidence of the lawful origin of funds. The regulatory authority must review the application within one month (extendable by an additional month once), and a positive conclusion is required before the change of control takes effect. Government Resolution No 348-N outlines the procedure and the required documents for acquiring a significant participation in a gambling organiser.

Under the Gaming Law, a change of corporate control is triggered by:

• acquisition of 10% or more of the organiser’s charter capital; or
• appointment of new responsible persons who manage or oversee gaming operations.

Passive investors are subject to the same fit-and-proper assessment as active participants, as there is no specific exemption applying to such investors. They must provide documentation verifying the lawful origin of funds and are subject to restrictions if they fall within disqualifying categories (criminal convictions, bankruptcy, prior involvement in revoked licences, or disqualification from financial/management roles). Approval from the regulatory authority is required before the acquisition is effective.

Where the provisions of the Gaming Law are violated, the Supervisory Authority may impose the following sanctions on the organisers:

• a warning accompanied by an instruction to remedy the identified violations; or
• a fine.

If the Supervisory Authority identifies grounds for suspending or revoking a licence, it submits a written request to the Competent Authority, providing all necessary documents for initiating the relevant procedure.

In turn, where a violation of the Law is established, the Competent Authority may impose the following measures on the organisers of gaming activities:

• suspension of the licence; or
• revocation of the licence.

Additionally, the sale of lottery tickets is subject to location-based restrictions. In particular, tickets may not be sold within 500 metres of the place where winnings are displayed. Breaches of this requirement are subject to administrative fines, imposed by the local self-government authorities in Yerevan or by the regional administrations in the provinces.

Warnings

The Supervisory Authority may, through on-site inspections or documentary reviews, identify breaches of the Gaming Law and issue a warning to the organiser. The warning includes a binding instruction to remedy the breach within the prescribed timeframe or to take preventive measures against future violations. This measure applies to breaches of reporting and disclosure obligations (including monthly reporting on gaming activities and lottery operations), as well as certain premises requirements, such as visibility from outside, the installation of fire and security alarm systems, the display of gaming rules, and video surveillance.

Fines

Fines are imposed for more serious breaches at fixed rates, as outlined in 11.3 (Financial Penalties).

Suspension

Licences may be suspended for violations relating to responsible persons or significant participants, the use of uncertified gaming products, the employment of personnel without the requisite operational permits, operating outside authorised premises or websites, or the non-fulfilment of financial obligations. During the suspension period, the organiser is prohibited from conducting gaming activities, except for the payment of winnings.

Revocation

A revocation of licence applies in cases of submitting false information, repeated breaches, violations of territorial restrictions on land-based gambling, failure to establish gaming accounts or verify player identities, and provision of distorted or incomplete information in licence applications that would otherwise have resulted in refusal.

Enforcement Practice

As the current regulatory framework was adopted relatively recently, no significant enforcement practice has yet been established in Armenia.

Financial penalties are imposed and collected by the Supervisory Authority in accordance with the Gaming Law, the Law on the Organisation and Conduct of Inspections in the Republic of Armenia, and the Law on the Fundamentals of Administration and Administrative Proceedings.

Fixed fines are determined based on the nature and frequency of the violations. For instance:

• a breach of the minimum payout requirement (90% for random-number-generated games) incurs a fine of AMD500,000 (approximately EUR1,119) per gaming product (or per game in online settings);
• violations of the requirements relating to premises, surveillance, visibility restrictions, or internal procedures result in fines of AMD2 million (EUR4,478) for first-time offences, increasing to AMD5 million (EUR11,195) and AMD10 million (EUR22,390) for repeated breaches within one- and two-year periods respectively;
• a repeated breach following a warning within a two-year period triggers a fine of AMD300,000 (EUR672);
• failure to notify the authorised body of non-material changes in licence-related data is fined at AMD200,000 (EUR448) per case;
• for lottery organisers, failure to form or allocate the required prize fund (at least 50% of ticket sales) results in fines equal to double the unallocated or untransferred amount; and
• if the same or similar violation occurs within one year after a fine has been imposed, the amount of the fine increases by AMD1 million (approximately EUR 2,239).

Additionally, delays in submitting reports or including inaccurate data may result in administrative fines being imposed directly on the organiser’s management under the Code of Administrative Offences.

In Armenia, the taxation of gambling varies by sector and type of activity. Player winnings are subject to a tiered regime: winnings from licensed gaming activity organisers are generally taxed at 5%, “large winnings” exceeding AMD5 million (EUR11,195) are taxed at 10%, and winnings derived from unlicensed gaming activity organisers are subject to a 20% tax. For winnings other than large winnings, the taxable income is calculated as the positive difference between the total winnings credited to a player’s account (gross gaming revenue (GGR)) during the reporting year and the total bets or participation fees paid.

Corporate income tax at 18% applies to organisers’ profits, while gaming operations remain exempt from VAT.