Definitive global law guides offering comparative analysis from top-ranked lawyers
CHAMBERS GLOBAL PRACTICE GUIDES
Gaming Law 2025 Definitive global law guides offering comparative analysis from top-ranked lawyers
Contributing Editor Bahar Alaeddini Harris Hagan
Global Practice Guides
Gaming Law Contributing Editor
Bahar Alaeddini Harris Hagan
2025
Chambers Global Practice Guides For more than 20 years, Chambers Global Guides have ranked lawyers and law firms across the world. Chambers now offer clients a new series of Global Practice Guides, which contain practical guidance on doing legal business in key jurisdictions. We use our knowledge of the world’s best lawyers to select leading law firms in each jurisdiction to write the ‘Law & Practice’ sections. In addition, the ‘Trends & Developments’ sections analyse trends and developments in local legal markets. Disclaimer: The information in this guide is provided for general reference only, not as specific legal advice. Views expressed by the authors are not necessarily the views of the law firms in which they practise. For specific legal advice, a lawyer should be consulted. Content Management Director Claire Oxborrow Content Manager Jonathan Mendelowitz Senior Content Reviewers Sally McGonigal, Ethne Withers, Deborah Sinclair and Stephen Dinkeldein Content Reviewers Vivienne Button, Lawrence Garrett, Sean Marshall, Marianne Page, Heather Palomino and Adrian Ciechacki Content Coordination Manager Nancy Laidler Senior Content Coordinators Carla Cagnina and Delicia Tasinda Content Coordinator Joanna Chivers Head of Production Jasper John Production Coordinator Genevieve Sibayan
Published by Chambers and Partners 165 Fleet Street London EC4A 2AE Tel +44 20 7606 8844 Fax +44 20 7831 5662 Web www.chambers.com
Copyright © 2025 Chambers and Partners
Contents
INTRODUCTION Contributed by Bahar Alaeddini, Harris Hagan p.5
GHANA Law and Practice p.194 Contributed by Legalstone Solicitors PRUC ISRAEL Law and Practice p.208 Contributed by Herzog Fox & Neeman
ARMENIA Law and Practice p.8 Contributed by Badasyan Consulting LLC Trends and Developments p.25 Contributed by Badasyan Consulting LLC
ITALY Law and Practice p.220 Contributed by Sbordoni & Partners
AUSTRALIA Law and Practice p.31 Contributed by Addisons Trends and Developments p.57 Contributed by Senet BELGIUM Law and Practice p.64 Contributed by EDSON Trends and Developments p.81 Contributed by EDSON
JAPAN Law and Practice p.248 Contributed by Nagashima Ohno & Tsunematsu Trends and Developments p.262 Contributed by Nagashima Ohno & Tsunematsu
MACAU SAR, CHINA Law and Practice p.267 Contributed by Lektou Trends and Developments p.286 Contributed by Lektou
BRAZIL Law and Practice p.86 Contributed by Maia Yoshiyasu Advogados – MYLAW
MALTA Law and Practice p.290
CANADA Law and Practice p.102 Contributed by McCarthy Tétrault LLP
Contributed by GVZH Advocates Trends and Developments p.305 Contributed by GVZH Advocates MEXICO Law and Practice p.310 Contributed by Portilla Ruy-Diaz y Aguilar
COLOMBIA Law and Practice p.117
Contributed by Asensi Abogados Trends and Developments p.137 Contributed by Asensi Abogados
MONTENEGRO Law and Practice p.321 Contributed by BDK Advokati
DENMARK Law and Practice p.142
Contributed by Mazanti-Andersen Trends and Developments p.157 Contributed by Mazanti-Andersen
NETHERLANDS Law and Practice p.341
Contributed by Franssen Tolboom Trends and Developments p.360 Contributed by Franssen Tolboom
ESTONIA Law and Practice p.161
Contributed by NJORD Law Firm Trends and Developments p.174 Contributed by NJORD Law Firm
POLAND Law and Practice p.364 Contributed by RM Legal
GERMANY Law and Practice p.178 Contributed by Melchers
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Contents
PORTUGAL Law and Practice p.381 Contributed by Lektou Trends and Developments p.400 Contributed by Lektou
SWITZERLAND Law and Practice p.502 Contributed by PLANZER LAW Trends and Developments p.518 Contributed by PLANZER LAW UK Law and Practice p.523 Contributed by Harris Hagan Trends and Developments p.543 Contributed by Harris Hagan
ROMANIA Law and Practice p.404
Contributed by WH Simion & Partners Trends and Developments p.420 Contributed by WH Simion & Partners
SOUTH AFRICA Law and Practice p.426 Contributed by Lurie Inc SOUTH KOREA Law and Practice p.445 Contributed by Kim & Chang
USA Law and Practice p.548 Contributed by Pillar Legal USA - FLORIDA Law and Practice p.565
Contributed by Jones Walker LLP Trends and Developments p.572 Contributed by Jones Walker LLP
SPAIN Law and Practice p.458
Contributed by Asensi Abogados Trends and Developments p.478 Contributed by Asensi Abogados
SWEDEN Law and Practice p.485
Contributed by Westerberg & Partners Trends and Developments p.497 Contributed by Westerberg & Partners
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INTRODUCTION Contributed by: Bahar Alaeddini, Harris Hagan Harris Hagan is the only specialist gambling law firm in the City of London. The firm was established in 2004 and is driven by the long-term sustainability and success of the gambling and leisure industries it cherishes. Harris Hagan has the largest dedicated gambling legal and regulatory team in the UK and offers unparalleled legal experience, knowledge,
and commercial understanding of the gambling in- dustry. The firm’s business includes gambling law, compliance and regulation, and it advises many of the world’s largest land-based and online gambling businesses (B2C and B2B), as well as many private equity firms, other investors, leading international law firms and start-ups. cross-border M&A transactions, investor disclosure and complex group restructuring. She is assistant treasurer and a member of the Programme Committee of the International Association of Gaming Advisors, a founding member of the VIXIO GamblingCompliance Executive Advisory Board, and a member of Global Gaming Women and the City of London Solicitors’ Company.
Contributing Editor
Bahar Alaeddini is a partner at Harris Hagan and is recognised as being “at the top of her profession”. She advises many of the world’s largest online and land-based gambling businesses (B2C and B2B) – as well
as many start-ups, investors and leading law firms – on matters ranging from licence applications, compliance investigations and licence reviews to
Harris Hagan Hamilton House 1 Temple Avenue London EC4Y 0HA UK Tel: 020 3334 8225
Email: info@harrishagan.com Web: www.harrishagan.com
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INTRODUCTION Contributed by: Bahar Alaeddini, Harris Hagan
Booms and Bans: A Global Overview of the Gambling Industry Harris Hagan is again pleased to introduce the Cham- bers Global Practice Guide to Gaming Law. The 2025 edition – albeit not an exhaustive text on gambling law – is a guide to the licensing and regulatory regimes in many of the major global markets. As the editor, I hope that its geographical coverage and the informa- tion provided on the regulatory frameworks around the world continue to serve as a helpful guide to in-house and private practice lawyers, gambling businesses, and other industry stakeholders. This year’s guide brings together leading gaming law experts from around 30 jurisdictions. It continues to provide guidance on the framework that applies to all types of regulated gambling, while setting out the cur- rent outlook and recent changes in each jurisdiction Gambling remains a popular leisure activity, with industry analysts estimating global gambling revenues will reach USD700 billion by 2028. It also remains an important revenue generator for many countries by contributing significant tax revenues to the public purse, attracting investment, creating jobs, attracting tourists, and funding certain public initiatives. A prop- erly regulated market is key to the future sustainability of the gambling ecosystem. The ongoing challenge for the gambling industry – affecting its long-term sustainability – is balancing the need to protect con- sumers with the risk of hindering economic growth through excessive or unnecessary regulation. Legal and regulatory changes must be backed by evidence. Although there are cultural nuances stemming from national history, religious, sociocultural factors and local customs in each jurisdiction, the proliferation of smartphones and “smart living” has driven player behaviour and demand for online gambling in recent years. At the same time, public and political scrutiny has increased, with the future of the gambling industry currently looking uncertain in certain jurisdictions – for example, the UK, where significant tax increases are expected as part of the 2025 Autumn Budget. What remains key is finding the right balance between con- sumer freedoms and protecting those harmed by at the time of writing. Gambling ecosystem
gambling, while also recognising that most gambling businesses are privately owned and operate cross- border. As the global gambling industry continues to grow and evolve, the regulatory landscape continues to adapt to new challenges, opportunities and technologies. Throughout 2025, two key challenges have been concerns about illegal gambling and the prediction markets, and these issues will continue to be hotly debated well into 2026. Illegal gambling is a global threat The illegal gambling market remains a significant and persistent challenge around the world, with industry research suggesting it is worth a staggering USD1.7 trillion globally. Despite extensive efforts by govern- ments and regulators, illegal operators and suppli- ers continue to thrive. This underground market not only undermines the regulated gambling ecosystem – particularly given links to organised crime – but also poses a fundamentally serious risk to players, who do not receive any of the same consumer protections. Although there are jurisdictional differences, what is very clear is that a multifaceted approach is essen- tial to effectively combat the illegal gambling market, particularly where gambling regulators do not have criminal powers or extraterritorial reach. We welcome INTERPOL’s late-2024 operation SOGA X, which made more than 5,100 arrests and recovered more than USD59 million, together with the partnership between the American Gaming Association (AGA), the Betting & Gaming Council (BGC) and the European Casino Association (ECA). M&A activity This year was a busy year for transactions, with a number of high-profile transactions closing – most notably, two private equity deals that saw Apollo funds acquire IGT’s digital and gaming businesses and Everi for USD6.3 billion, and Brightstar acquire AGS for USD1.1 billion, as well as Intralot’s acquisi- tion of Bally’s online business for EUR2.7 billion. M&A activity in the second half of 2025 has been quieter owing to the macroeconomic climate; however, the tide is expected turn in 2026.
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INTRODUCTION Contributed by: Bahar Alaeddini, Harris Hagan
Predicting the predictions markets The predictions market has dominated the US betting market in 2025 by posing the simple question of what is meant by a bet. Kalshi and Polymarket (known as “predictors”) are federally regulated by the Commod- ity Futures Trading Commission (CTFC) and therefore fall outside the authority of state gambling regulators, who argue that laying money on the outcome of a sports event is sports betting and should be regulated by them. It therefore comes as no surprise that many US state regulators have issued cease and desist orders against predictors. Kalshi processed more than USD1 billion in sports wagers from 3.4 million bets in the second half of 2025, which gives an insight into state legislators’ concerns about missed revenues, risks to the sports betting ecosystem, and the lack of con- sumer protections. At the time of writing (November 2025), Polymarket opened a market on whether pre- dictions would be banned in 2025, with a 40% chance (marking an increase from 10% the previous month). Also in November 2025, Flutter and DraftKings left the American Gaming Association owing to their predic- tion market plans.
Emerging markets Emerging gambling markets continue to transform the global landscape and spark enthusiasm, particu- larly given the higher costs of operations and compli- ance in mature regulated markets. As newer markets emerge, they offer significant opportunities and risks to gambling businesses. In January 2025, after a turbulent period, Brazil regu- lated online betting. In North America, online gambling is expected to launch in Alberta in 2026. Nigeria con- tinues to be at the forefront of Africa’s booming gam- bling market. In the Middle East, all eyes remain on the UAE, as the regulator has indicated online gambling will be live before the end of 2025. Closer to home in Europe, the role of the newly established Irish gam- bling regulator will continue to expand as the country transitions to the new regime.
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ARMENIA Law and Practice Contributed by: Roustam Badasyan, Artur Manukyan, Marianna Grigoryan and Davit Baklachyan Badasyan Consulting LLC
Russia
Georgia
Armenia
Yerevan
Azerbaijan
Turkey
Iran
Contents 1. Introduction p.12 1.1 Current Outlook and Recent Changes p.12 2. Jurisdictional Overview p.12 2.1 Online Gambling p.12 2.2 Land-Based Gambling p.13 3. Legislative Framework p.13 3.1 Key Legislation p.13 3.2 Definition of Gambling p.14 3.3 Definition of Land-Based Gambling p.15 3.4 Definition of Online Gambling p.15 3.5 Key Offences p.15 3.6 Penalties for Unlawful Gambling p.16 4. Licensing and Regulatory Framework p.16
4.1 Regulatory Authority p.16 4.2 Regulatory Approach p.17 4.3 Types of Licences p.17 4.4 Availability of Licences p.17 4.5 Duration of Licences p.17 4.6 Application Requirements p.17
4.7 Application Timing p.18 4.8 Application Fees p.18
4.9 Ongoing Annual Fees p.18 4.10 Personal Licensing p.18 5. Land-Based Gambling p.19
5.1 Premises Licensing p.19 6. Online Gambling p.19 6.1 B2C Licences p.19 6.2 B2B Licences (Suppliers, Software, Etc) p.20 6.3 Affiliates p.20 6.4 White Labels p.20 6.5 Technical Measures p.20 7. Responsible Gambling (RG), Also Known as Safer Gambling (SG) p.20 7.1 RG Requirements p.20 7.2 Gambling Management Tools p.21 8. Anti-Money Laundering (AML) p.21 8.1 AML Legislation p.21 8.2 AML Requirements p.21
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ARMENIA CONTENTS
9. Advertising p.22 9.1 Regulatory/Supervisory Agency p.22 9.2 Definition of Advertising p.22 9.3 Key Legal, Regulatory and Licensing Provisions p.22 9.4 Restrictions on Advertising p.22 9.5 Sanctions/Penalties p.22 10. Acquisitions and Changes of Control p.23 10.1 Disclosure Requirements p.23 10.2 Change of Corporate Control Triggers p.23 10.3 Passive Investor Requirements p.23 11. Enforcement p.23 11.1 Powers p.23 11.2 Sanctions p.23 11.3 Financial Penalties p.24 12. Tax p.24 12.1 Tax Rate by Sector p.24
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ARMENIA Law and Practice Contributed by: Roustam Badasyan, Artur Manukyan, Marianna Grigoryan and Davit Baklachyan, Badasyan Consulting LLC
Badasyan Consulting LLC is a Yerevan-based ad- visory firm, founded in 2024, and brings together experienced professionals from both the private and public sectors. The firm is dedicated to simplifying complex legal, tax, and compliance matters for busi- nesses operating in Armenia and beyond. Badasyan Consulting is particularly active in assisting domestic and international clients with transaction structuring, corporate governance, tax consultancy, and regu- latory matters. The firm is led by seasoned experts with backgrounds in academia, public policy, taxa- tion, and international law, enabling it to deliver so-
lutions that strike a balance between legal accuracy and strategic business insight. Known for its client- focused and discreet approach, the firm is commit- ted to providing high-quality, reliable service tailored to the specific needs of each client. Its diverse client base includes multinational enterprises and high- growth companies across communications, finance, technology, and related sectors. Badasyan Consult- ing continues to build a reputation for excellence, in- tegrity, and practical problem-solving in a fast-evolv- ing legal landscape.
Authors
Roustam Badasyan is a prominent Armenian lawyer at Badasyan Consulting LLC, with deep expertise in legal reform, tax administration, and complex corporate and regulatory matters. A former Minister
Artur Manukyan is a seasoned Armenian tax professional with over 25 years of experience in public finance, tax administration, and fiscal reform. A former Deputy Head of the State Revenue Committee, he was
of Justice and Chairman of the State Revenue Committee, he played a central role in Armenia’s gaming sector modernisation and public finance transparency initiatives. With over a decade of legal and governmental experience, he brings unique insight into multi-stakeholder negotiations, compliance frameworks, and institutional development. A licensed advocate and former senior associate at a leading law firm, Roustam holds an LLM and is widely published in corporate, tax, and mining law, both locally and internationally.
instrumental in modernising Armenia’s tax governance system, advancing electronic tax administration, and shaping key legislative reforms. He has represented government institutions before the National Assembly and international stakeholders, while also serving for many years on the Tax and Customs Appeals Commission. Artur now heads the tax consultancy practice at Badasyan Consulting LLC, advising businesses on complex tax and compliance matters.
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ARMENIA Law and Practice Contributed by: Roustam Badasyan, Artur Manukyan, Marianna Grigoryan and Davit Baklachyan, Badasyan Consulting LLC
Marianna Grigoryan is a multilingual Armenian lawyer at Badasyan Consulting LLC, with a strong focus on complex corporate, regulatory, and compliance matters. A New York- qualified attorney with an LLM from
Davit Baklachyan is a licensed Armenian advocate and director at Badasyan Consulting LLC, with notable expertise in litigation, regulatory compliance, and legal risk management. He previously led
NYU, she brings an international perspective and technical precision to cross-border transactions and legal risk analysis. Marianna has advised banks, businesses, and NGOs on a wide range of legal issues, including credit, M&A, cybersecurity, and anti-corruption policy. With a background in both private practice and legal reform work, she combines academic excellence with practical experience. Her publications span civil, criminal, and international law, and she is a trusted advisor to both domestic and multinational clients.
judicial protection efforts at Armenia’s State Revenue Committee, co-ordinating strategic litigation and regulatory review. Davit is pursuing a PhD in Law and lectures at Yerevan State University, where he also earned his LLM and LLB with honours. His practice combines academic depth with hands-on experience in both public and private sectors. He is a published author in the field of liability insurance law and regularly advises on corporate and administrative disputes.
Badasyan Consulting LLC “Aigy” Business Centre Tairov 24 Yerevan 0082 Armenia Tel: +374 (10) 300 888 Email: info@bnc.am Web: bnc.am
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ARMENIA Law and Practice Contributed by: Roustam Badasyan, Artur Manukyan, Marianna Grigoryan and Davit Baklachyan, Badasyan Consulting LLC
1. Introduction 1.1 Current Outlook and Recent Changes In 2024, the National Assembly of Armenia adopted the Law on the Regulation of Gaming Activities (known as the “Gaming Law”), which entered into force on 1 January 2025. The Law introduced the principles of responsible gambling and fair play, as well as geo- blocking mechanisms designed to prevent Armenian residents from participating in foreign gambling plat- forms. Furthermore, the Gaming Law stipulated that a register of restricted domains be maintained and shared with the Central Bank of Armenia to block related financial transactions. Gaming organisers are also required to host their online resources under the “.am” domain, a meas- ure aimed at enhancing regulatory control. Although these reforms are expected to improve supervision and compliance, their practical effect has yet to be fully observed due to the Law’s recent entry into force. Enforcement of consumer protection has intensified in parallel. In 2024, the Competition and Consumer Protection Commission (CCPC) imposed a landmark sanction on major online gaming activity organisers for unfair competition, including misleading advertis- ing practices targeting both users and non-users. Separately, the National Assembly adopted the Law on Crypto Assets on 29 May 2025 (effective 4 July 2025), while legislative work continues on a new Cybersecurity Law. Neither instrument introduces gambling-specific regulations. Institutionally, responsibility for developing and imple- menting state policy in the field of gaming activities has been transferred from the Ministry of Finance to the Ministry of Economy, which now serves as the principal authority exercising state oversight over the sector. The Operator A major structural innovation in Armenia’s reformed gaming regulatory framework is the introduction of the Operator, a distinct entity entrusted with wide- ranging technical, administrative, and monitoring functions. Operating under a model comparable to
public–private partnership (PPP) structures, the Oper- ator acts as an intermediary between the state and gaming organisers, facilitating operational oversight while remaining separate from the direct conduct of gaming activities. Its responsibilities include admin- istering the issuance, renewal, and suspension of operational certificates; certifying gaming products or validating international conformity certificates; ensuring the integration of gaming systems with the central monitoring centre; setting service fees within government-approved caps; and proposing technical standards and responsible gaming practices to the competent authorities. The Operator also conducts market monitoring, analyses risks, and provides rec- ommendations to the regulatory authorities regarding industry developments, regulatory improvements, and player protection mechanisms. The Government Resolution No 1149-N (“On the Pro- cedure for Conducting the Competition for Selecting the Operator of Gaming Regulation, the Procedure for Participation in the Selection Process through a Consortium, the Procedure for Concluding a Contract with the Operator, and the Grounds for Declaring the Competition Void”) provides detailed rules governing the selection and contracting of the Operator. It estab- lishes transparent criteria for participation, allows for consortium-based applications, and defines proce- dural safeguards for competition and contract con- clusion. Through this framework, Armenia has insti- tutionalised a hybrid model in which the Operator serves as a regulated partner of the state, managing certification, monitoring, and data access functions, while the government retains strategic and regulatory control over the gaming sector.
2. Jurisdictional Overview 2.1 Online Gambling
The regulatory framework in Armenia is generally licence-based and permissive, allowing both land- based and online operations subject to regulatory oversight by the competent governmental authority. The legislation distinguishes between the following regulated categories:
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ARMENIA Law and Practice Contributed by: Roustam Badasyan, Artur Manukyan, Marianna Grigoryan and Davit Baklachyan, Badasyan Consulting LLC
• games of chance; • internet games of chance; • bookmaker activity (including totalisers); and • lotteries. The following outlines the legal status of key sectors. Betting Classified as bookmaker activity. Permitted on the basis of a bookmaker licence and the right to accept bets. Operations may be conducted exclusively through the organiser’s official website and mobile applications indicated in the licence. Bingo Not expressly defined in primary legislation. Likely falls within games of chance or lotteries, depending on structure. Permitted when conducted under an appropriate casino or lottery licence. Casino Permitted both in land-based and online formats, sub- ject to licensing. Licensees must utilise certified gam- ing software and connect to the central monitoring system operated by the authorised state body. Lotteries Regulated under the Law on Lotteries and the Gaming Law. The Gaming Law explicitly prohibits the organi- sation of traditional lotteries (including instant (no- draw), draw-based, and combined formats) via elec- tronic means or internet access within the Republic of Armenia, while land-based lotteries remain permitted. Fantasy Sports Not specifically regulated under existing legislation. Where no monetary stakes or winnings are involved, such activity may fall outside the scope of gambling laws. If linked to real-money wagering, it would likely be considered a game of chance and would require licensing. Social Gaming Generally exempt from the Gaming Law. Intellectual or knowledge-based games organised through audio- visual media or the internet, which award prizes rather than winnings, are unregulated. If such games involve
in-app purchases convertible to monetary value or wagers, they become subject to gambling regulation. Poker Not separately defined in the legislation. Likely con- sidered a game of chance and therefore permitted only under a casino licence. Online poker is subject to the same licensing and monitoring requirements applicable to internet games of chance. Totalisers Recognised as a form of bookmaker activity involv- ing pooled betting on events. Permitted upon licens- ing under the same conditions as other bookmaker operations. 2.2 Land-Based Gambling In Armenia, both land-based and online gambling operate under the same overarching regulatory frame- work, although certain practical distinctions apply. Land-based gambling is physically restricted to des- ignated zones, including: • Tsakhkadzor; • Jermuk; • Sevan; • Meghri; and • specific free economic zones such as Zvartnots Airport in Yerevan. Large-scale projects approved by the government (with investments exceeding AMD40 billion) may also be permitted in other locations. Venues must comply with minimum distance require- ments from sensitive sites, such as schools, hospitals, and cultural centres, and are typically limited in size. Furthermore, all gaming products used must possess the required certification, ensuring compliance with Armenian legal and technical standards.
3. Legislative Framework 3.1 Key Legislation
The gaming sector in Armenia is regulated through a framework of laws and normative legal acts. The
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ARMENIA Law and Practice Contributed by: Roustam Badasyan, Artur Manukyan, Marianna Grigoryan and Davit Baklachyan, Badasyan Consulting LLC
Prime Minister’s Resolution on Establishing the Composition and Rules of Procedure of the Interagency Competition Commission for the Selection of the Gaming Regulation Operator (No 670-L) This establishes the composition and procedural rules of the interagency commission responsible for select- ing the gaming regulation operator. Order of the Minister of Finance on Establishing the Procedure for Verifying That a Bank Account or Card Used by an Online Gaming Activity Organiser to Fund a Dedicated Gaming Account Belongs to the Player who is the Owner of that Dedicated Gaming Account (No 315-N) This sets out the procedure for verifying that the bank account or card used by an internet gaming activ- ity organiser to credit a dedicated gaming account belongs to the player who is the rightful owner of that account. Order of the Minister of Finance on Establishing the Procedure for Verifying the Banking Account or Card Provided for Crediting Funds to a Dedicated Gaming Account Belonging to a Player Who is a Citizen of the Republic of Armenia, Either Through Participation in a Lottery (Totaliser) or Through Individual Gaming Cards Provided by Gaming Activity Organisers for Conducting Bets or Games (No 317-N) This provides the verification procedure for bank accounts or cards used to credit funds to a dedicated gaming account belonging to Armenian citizen play- ers, whether through lotteries, totalisers, or individual gaming cards issued by gaming activity organisers. 3.2 Definition of Gambling The term “gambling” is not expressly defined under Armenian law. However, it falls within the broader scope of the term “game” as defined in the Law on the Regulation of Gaming Activities. According to this law, a game encompasses any of the following: a game of chance, an internet game of chance, a game organ- ised through bookmaker activity, or a lottery. Game of Chance This refers to any mechanised game, conducted through gaming products designed for programmed
key legislation and regulatory instruments are outlined here. Law on the Regulation of Gaming Activities (No HO-263-N) This establishes the regulatory framework for gam- ing activities, with the primary objectives of protecting players’ interests, enhancing oversight through elec- tronic management systems, and setting mandatory technical requirements for gaming products in line This governs the organisation and conduct of lotteries and provides for state supervision of such activities. Law on Games of Chance, Internet Games of Chance, and Casinos (No HO-1-N) This regulates the organisation and operation of games of chance, internet games of chance, and casinos, and establishes state oversight over these activities. Government Resolution on the Procedure for Conducting the Competition for Selecting the Operator of Gaming Regulation, the Procedure for Participation in the Selection Process through a Consortium, the Procedure for Concluding a Contract with the Operator, and the Grounds for Declaring the Competition Void (No 1149-N) This sets out the rules and procedures for conducting competitions to select the gaming regulation operator, including consortium participation, contract conclu- sion, and grounds for declaring the competition void. with international standards. Law on Lotteries (No HO-3-N) Government Resolution on Establishing the Procedure for Licensing the Organisation of Gaming Activities (No 855-N) This defines the licensing requirements and proce- dures for organising gaming activities in Armenia. Government Resolution on Establishing the Procedure for Approving the Rules for the Organisation and Conduct of Gaming Activities (No 310-N) This provides the process for approving rules govern- ing the organisation and operation of gaming activi- ties.
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ARMENIA Law and Practice Contributed by: Roustam Badasyan, Artur Manukyan, Marianna Grigoryan and Davit Baklachyan, Badasyan Consulting LLC
and/or mechanical play, that is based on risk and offers the opportunity to win. The winner is deter- mined by a specific program or mechanical system contained within the product, with the player’s direct or indirect participation. The term also covers live games, in which a dealer participates alongside the player (acting on behalf of the organiser to conduct or verify the outcome), or games in which multiple players participate simultaneously without a dealer (except mechanised games). Internet Game of Chance This means a game of chance organised via internet access using gaming products. Such games may also be conducted through physical gaming halls. Bookmaker Activity This refers to the organisation of accepting, recording, and paying winnings on bets placed on the possible outcomes of sporting, gaming, social, political, or oth- er events, as well as creating opportunities for players to place such bets (including through the granting of rights in any form). Bookmaker activity may also be conducted through a gaming hall. Lottery A lottery is defined as a public event during which the organiser conducts a drawing of a prize fund among participants. The outcome depends solely on chance and is not influenced by the organiser’s actions or will. Lotteries, too, may be organised through gaming halls. 3.3 Definition of Land-Based Gambling Under Armenian law, “gaming” broadly includes all forms of gambling activities. The legal framework does not differentiate between land-based and online gaming; thus, the statutory definition applies equally to both formats. 3.4 Definition of Online Gambling See 3.3 Definition of Land-Based Gambling . 3.5 Key Offences Administrative Offences The Armenian Code of Administrative Offences lists a number of breaches in the gambling sector that are subject to administrative penalties, as listed here.
• Failure or improper performance by public elec- tronic communications network operators provid- ing internet access services of their obligations, as prescribed by the Law on Regulation of Gaming Activities, to block access to websites of gaming interactive platforms organised in foreign states by entities that do not hold the relevant license required under the legislation of the Republic of Armenia – penalises the public electronic com- munications network providers for failure to carry out the geo-blocking obligations under the Gaming Law. • Violation of the requirements of the Law of the Republic of Armenia “On Combating Money Laundering and Terrorism Financing (the ”AML Law”)” and the legal acts adopted pursuant to that Law ‒ sanctions the head of a legal entity that is a non-financial institution, the responsible person of organisers of games of chance, internet games of chance, lotteries, or games organised through bookmaking activities, as well as an official of a state body vested with obligations under the AML Law for violating the requirements imposed upon such entities. • Use, without the relevant registration (licence), of unauthorised or legally prohibited words, as well as the use of certain words in a name, advertise- ment, or public offer by unlicensed persons, or any form of assistance in such advertising ‒ given that the Gaming Law prohibits the use, in the name of an organisation, trade name, trademark, website name, or signage, the words “game of chance” (including “casino” or “gaming hall”), “internet game of chance,” “lottery,” “bookmaking activity” (including “bookmaker’s office” or “totaliser”), as well as any of their derivatives or translations, the Code sets out penalties for such restricted use. • Carrying out activities in the areas of trade, public catering, restricted services, or household services without the requisite authorisation – prohibits oper- ating gaming and lottery facilities, or casinos after midnight without the required authorisation. Criminal Offences The Criminal Code establishes a few offences related to engaging in unlawful gambling:
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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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ARMENIA Law and Practice Contributed by: Roustam Badasyan, Artur Manukyan, Marianna Grigoryan and Davit Baklachyan, Badasyan Consulting LLC
monitoring system; (d) provision of market monitoring, data manage- ment, and analytical services; and (e) support for responsible and fair gaming prac- tices. The Operator also provides technical guidance, col- laborates with public authorities, and ensures the flow of information to the Competent and Supervi- sory Authorities, effectively acting as an operational arm of the state within a public-private partnership framework. 4.2 Regulatory Approach Armenia adopts a primarily prescriptive regulatory approach for the gambling sector. The framework is codified in the Law on Regulation of Gaming Activi- ties and relevant secondary legislation, prescribing detailed requirements for licensing, operational stand- ards, location constraints, technical compliance, and reporting obligations. 4.3 Types of Licences Under the Armenian regulatory framework, licences are principally categorised according to the type of gaming activity the organiser intends to conduct: • licence for the organisation of games of chance or internet games of chance; • licence for the organisation of bookmaking activi- ties; and • licence for the organisation of lotteries. 4.4 Availability of Licences Licences are generally available, subject to compli- ance with legal, financial, and operational require- ments. However, certain licences, such as those for organising games of chance or internet games of chance in Yerevan, or for large-scale investments, are limited by geographic zoning, minimum investment thresholds, and government approval. Online licences are available to gaming activity organisers who meet the technical and monitoring requirements prescribed by the Law on Regulation of Gaming Activities. 4.5 Duration of Licences Under the Government Resolution on Establishing the Procedure for Licensing the Organisation of Gaming
Activities, licences may be granted for an indefinite period, irrespective of the type of gaming activity. The Gaming Law provides for the suspension or revoca- tion of licences in specific circumstances, including breaches of the Gaming Law, failure to fulfil tax obli- gations, or non-compliance with requirements set out in the orders of the Supervisory Authority. Licences may also be terminated upon the organiser’s request. 4.6 Application Requirements Application requirements for both land-based and online organisers are set out in the Government Reso- lution on Establishing the Procedure for Licensing the Organisation of Gaming Activities. While the general framework applies to all applicants, there are distinct differences between land-based and online gambling activities. For land-based gambling, applicants must specify the location of the gaming hall. They are required to sub- mit proof of property ownership or the right to use the premises, including floor plans, certificates confirming the installation of fire safety and alarm systems, dec- larations regarding compliance with spatial standards and minimum distance requirements, or hotel classi- fication standards if the gaming hall is located within a hotel or motel. Online gambling applicants must disclose their offi- cial website, any gaming applications they use, and the locations of their servers. Where online gambling is conducted directly through a physical gaming hall, the hall’s address must also be provided, and the hall- specific requirements, including fire safety and surveil- lance, apply. The applicants must submit a certificate confirming website compliance and a declaration confirming the availability of a deposit in an Armenian bank equivalent to twice the annual state fee. All applicants, regardless of the type of activity, must submit: • tax clearance certificates confirming that there are no overdue liabilities; • the rules and regulations governing the conduct of gambling activities approved by the relevant man- agement body;
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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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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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