Gaming Law 2025

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

shareholders or executives fall within these catego- ries. 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 oversee- ing 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 nega- tive 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 regard- ing 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 activi- ties. 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law, provides false information in the application, or is associated with a gaming activity organiser whose licence has been revoked as a sanction.

cific location and operational requirements. Gambling establishments are permitted only within the admin- istrative boundaries of Tsakhkadzor, Sevan, Jermuk, and Meghri, and must maintain a minimum distance from certain public and cultural facilities. In Tsakhkad- zor 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 cul- tural institutions, government or municipal buildings, and hospital areas. The law further prescribes minimum space require- ments. In Tsakhkadzor, Sevan, and Jermuk, casinos must occupy at least 250 square metres and gam- ing 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 des- ignated as the gaming floor, with the remaining space allocated to ancillary facilities such as a lobby, cash- ier’s area, and restrooms. Each establishment must have a separate entrance lobby adjacent to the main entrance, where custom- er identification and data registration take place to ensure compliance with the minimum age require- ment 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 instal- lation 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.

6. Online Gambling 6.1 B2C Licences

5. Land-Based Gambling 5.1 Premises Licensing

In Armenia, there are no specific regulations govern- ing 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,

Under Armenian law, premises used for organising land-based gambling activities, including casinos, gaming halls, and internet games of chance con- ducted through a gaming hall, must comply with spe-

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