Gaming Law 2025

ARMENIA Law and Practice Contributed by: Roustam Badasyan, Artur Manukyan, Marianna Grigoryan and Davit Baklachyan, Badasyan Consulting LLC

• 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 busi- ness activities that are carried out without the requisite licence. 3.6 Penalties for Unlawful Gambling In Armenia, unlawful gambling is subject to a com- bination of administrative and criminal sanctions, depending on the nature of the offence and the iden- tity of the perpetrator. Administrative penalties primarily target gaming activ- ity organisers and public electronic communications network operators. This includes establishments oper- ating 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 obliga- tions 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 deten- tion 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 organis- ing 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 frame- work 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 authori- ties 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 licens- ing policy, issuing licences, supervising compliance with licence requirements, and exercising other powers as prescribed by law. Before the establish- ment of the Operator, the Competent Authority will continue to be responsible for many of the opera- tional functions delegated to the Operator. 4. Licensing and Regulatory Framework 4.1 Regulatory Authority • The Supervisory Authority (State Revenue Commit- tee) oversees licensed gaming activity organisers, ensures compliance with applicable laws and regu- lations, and monitors gaming activities. The Super- visory Authority also examines complaints lodged by players against gaming activity organisers. • The Operator executes key operational functions, including: (a) the issuance, renewal, and revocation of operational certificates; (b) verification of gaming product conformity certificates; (c) connection of gaming products to the central

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