ARMENIA Law and Practice Contributed by: Roustam Badasyan, Artur Manukyan, Marianna Grigoryan and Davit Baklachyan, Badasyan Consulting LLC
• 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 require- ments applying only where online gambling is oper- ated through a physical gaming hall. 4.7 Application Timing 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 docu- ments fail to comply with legal requirements or con- tain false information, if the applicant does not meet the eligibility criteria, if the rules governing the organi- sation 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 invest- ed funds have been obtained unlawfully. Applications may also be refused in other cases provided by law. 4.8 Application Fees The Armenian regulatory framework does not pre- scribe any separate fees for submitting licence appli- cations. Instead, state duties apply for obtaining a licence, forming part of the annual financial obliga- tions 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. Spe- cifically, 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 mil- lion (EUR67,172), and in other locations AMD5.5 bil- lion (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. 4.9 Ongoing Annual Fees Licensing fees in the gaming sector are annual and remain payable by the game organiser for the dura- tion of the licence, until the licence is suspended or revoked. 4.10 Personal Licensing Armenia does not have a standalone “personal gam- bling licence”. However, individuals who hold signifi- cant 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, benefi- cial owners, and their affiliated persons meet the statu- tory 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 sig- nificant interest or serving as a responsible person where they have a criminal conviction for an inten- tional 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 out- standing liabilities, have failed to substantiate the law- ful 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
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