ARMENIA Law and Practice Contributed by: Roustam Badasyan, Artur Manukyan, Marianna Grigoryan and Davit Baklachyan, Badasyan Consulting LLC
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. 6.2 B2B Licences (Suppliers, Software, Etc) No explicit regulatory framework governs B2B licences under Armenian law. However, the Gaming Law pro- vides 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. 6.3 Affiliates The Gaming Law does not explicitly regulate the use of affiliates. However, when a gambling organ- iser 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. 6.4 White Labels Similar to affiliates, the use of white-label providers is not explicitly addressed under Armenian gaming legislation. However, the general licensing and regula- tory requirements effectively extend to such arrange- ments. 6.5 Technical Measures Under Armenian law, participation in gambling organ- ised in foreign jurisdictions and the advertising of such activities within Armenia is prohibited. To enforce this, the law provides for the blocking of websites offer- ing foreign gambling services via public electronic communications network operators providing inter- net 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 con- sidered 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 imple- mented once the Operator is formally elected and fully operational. 7. Responsible Gambling (RG), Also Known as Safer Gambling (SG) 7.1 RG Requirements 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 activi- ties is subject to strict restrictions to protect vulner- able individuals and minors. Citizens receiving certain government financial assistance, those living in social housing, individuals declared bankrupt or with out- standing public debts, and persons registered at the National Centre for Addiction Treatment are prohib- ited from participating in gambling. Age-based restric- tions also apply: persons under 21 are prohibited from engaging in games of chance or bookmaking activi- ties, while those under 18 are barred from participat- ing in lotteries. In addition, individuals deemed legally incapacitated due to causing financial hardship to their families are restricted from gambling, with guardianship authori- ties notifying the Competent Authority and the Oper- ator to block access to gaming venues and online
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