ARMENIA Law and Practice Contributed by: Roustam Badasyan, Artur Manukyan, Marianna Grigoryan and Davit Baklachyan, Badasyan Consulting LLC
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 monitor- ing system to enforce these restrictions, including the identification of restricted individuals through author- ised databases and account verification. Organisers must ensure that their systems are coordinated with the Operator to apply participation restrictions effec- tively. Risk factors such as frequent changes of IP address may trigger additional scrutiny to prevent cir- cumvention of the rules. 7.2 Gambling Management Tools In Armenia, the Operator employs a suite of gam- bling management tools to ensure player protection, responsible gambling, and compliance. Participa- tion restrictions prevent minors, bankrupt individuals, socially vulnerable persons, and other restricted cat- egories from accessing gambling activities, with veri- fication 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. Col- lectively, these tools establish a robust framework for safe and responsible operation. 8. Anti-Money Laundering (AML) 8.1 AML Legislation 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 proce- dures as well as information obtained through opera- tional 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 insti- tutions 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-compli- ance or improper compliance is identified, the author- ity may impose the sanctions and measures provided under the law. 8.2 AML Requirements Casinos, gambling organisers, including online gam- ing 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 thresh- olds to the competent authority. For specific trans- actions, 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 cli- ent’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 sus- picions to the customer related to money laundering
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