Armenia - Revenue Committee

(Section: "Markets and Jurisdictions")

1) Market picture and organ roles

State Revenue Committee (SRC) - administration of taxes and special fees, desk/field control, sanctions, electronic reporting.
Profile Ministry (financial and economic block) - gambling policy, admission rules and technical requirements.
Central Bank/Finmonitoring - national AML/CFT system (AML/CFT), STR/SAR methodology.
Police/cyber units - suppression of illegal activities, domain/payment locks.
Municipalities/communities - urban planning and address issues for offline.

2) Admission model: offline and online

Offline

Casinos, gaming salons, bookmakers - by address permissions. For casinos and halls, geographical restrictions apply (accommodation in certain resort/border zones and outside strict radii from socially significant objects).
Requirements: reliability of premises, CCTV, cash discipline, access/age control, personnel training.

Online

Remote services (casino/slots, betting, poker) - subject to license, certified platform and integrations for supervision and reporting.
Key persons and owners undergo fit & proper, beneficiaries and sources of funds are disclosed.
Local presence: resident legal entity, settlement accounts assigned responsible for AML/RG/interaction with the regulator.

3) Restrictions and prohibitions

Age threshold: participation is allowed only for adults, with verification of the document upon entry/registration; an increased threshold can be used for individual verticals (to be specified in the current acts).
Prohibition of access: persons from registers of self-exclusion/restrictions, as well as categories defined by law (by court decision, guardianship, etc.).
Offline geography: casinos/halls - in approved locations (resort cities/special areas); SST - by address permissions with restrictions on distances and operating mode.
Bypasses: responsibility for the use of proxies/mirrors, gray payment routes, aggressive lead generation schemes.

4) Taxes and fees (high level)

• Online verticals: as a rule, the GGR/NGR base (bets − wins) with local rules for reflecting bonuses, void/cashout/cancellations; monthly declarations.
• Ground sector: special tax/levy by type (casino/machines/wagers), often with fixed payments for gaming seats (table/machine) and/or interest elements; monthly/quarterly reporting.
• Corporate income tax - according to the general regime. VAT usually does not apply to bets/winnings, but is valid for related services (IT, marketing, hosting, outsourcing).
• Accounting: separately offline/online and by products; Traceability of bonuses and adjustments is mandatory.

5) AML/KYC and identification

KYC/KYB: verification of identity/age, address, beneficiaries; sanctions/RAP; source of funds (SoF) under triggers.
Payment means: confirmation of ownership, ban on anonymous channels.
Transactional monitoring: limits, atypical patterns, connection of accounts/cards/devices; mandatory escalation of STR/SAR to financial monitoring.
Storage: retention of KYC dossiers/journals, data protection (GDPR-compatible level); regular training of AML personnel.

6) Responsible Gaming (RG) and self-limiting

RG tools: deposit/loss/time limits, timeouts, "cooling," self-control panel, help contacts.
Self-exclusion/registry: centralized mechanism; the operator is obliged to check the status at registration, entry and before key transactions and not direct marketing to the self-excluded.
Early signals: pursuit of losses, frequent deposits, night activity - the basis for the intervention of the RG team.

7) Advertising, promo and affiliates

Prohibitions: targeting minors/vulnerable groups; misleading promises of "guaranteed winnings"; incorrect "free" offers.
Mandatory elements: RG-markings, noticeable T&C bonuses (wagers, terms, mouthguards), indication of age restrictions.
Affiliates: only allowed for licensed brands; requires a compliance log (screenshots/URL/dates/geo), creative whitelisting, quick recall mechanism.
Responsibility: promotion of unlicensed sites/mirrors - the basis for prescriptions and fines.

8) IT loop and supervisory access

Certification: RNG/game modules, platform/wallet, settlement modules, reporting showcases.
Logging: immutable WORM logs along the chain "rate → calculation → payment → adjustment," time synchronization.
API/uploads: secure channels, surveillance test accounts, compatibility with SRC formats.
Reliability/Information Security: DR/BCP (target RPO/RTO), redundancy, encryption at rest/in transit, RBAC/SoD, regular penetration tests/scans.

9) Checks and sanctions

Office: comparison of reporting and payments, analysis of GGR/NGR deviations, reconciliation of bonuses/void/cashout, audit of marketing and affiliates.
On-site/IT audit: inspection of logs/cash desks, sampling of transactions and sessions, staff interviews, verification of payment routes and offline geo-restrictions.
Measures: fines/additional charges, instructions to correct AML/RG/UX/advertising, blocking domains/payments, suspension/cancellation of permits.
Mitigation: voluntary disclosure of errors, corrective plans, strengthening of internal controls and training.

10) Entry roadmap (operator & provider playbook)

1. Strategy: choose verticals (casino/slots/bets/poker), channel (offline/online), target regions/locations.

2. Legal structure: local legal entity, beneficiaries and sources of funds; accounts in RA banks; Assign AML/RG/Reporting Owners

3. Licensing: a set of documents (fit & proper, financial stability, platform technical description, AML/RG policies, reporting scheme and information security).
4. IT: RNG/module certification, WORM logging construction, reporting showcases, API for SRC.
5. AML/KYC/RG: connection of sanctions/PEP providers, SoF procedures, limits and self-exclusion, RG case management registers.
6. Marketing/affiliates: pre-moderation of creatives, geo/age filters, compliance journal, quick recall.
7. UAT: tax/fee test cases, NGR/GGR correctness, limit overruns/self-exclusions, STR/SAR flow.
8. Go-Live: freeze configurations, runbook incidents, SLA with PSP/hosting/communication channels.
9. First 90 days: rhythm of declarations, reconciliation of otchetnost↔billing (<0.5%), internal audit AML/RG/IS.

11) Compliance checklists

Licensing and Finance

• Licenses/permits obtained; responsible persons appointed
• Declaration/payment calendar in SRC discrepancy control <0.5%
• Separate accounting by products and channels; correct reflection of bonuses/void/cashout

AML/KYC & RG

• KYC/KYB Policies, Sanctions/PEP, SoF; inspection logs
• Deposit/loss/time limits, timeouts; self-exclusion registry integration
• STR/SAR-procedures, shelf life of ACC/logs; personnel training

IT and Security

• RNG Certificates/Platforms; version control, secure SDLC
• WORM logs and time synchronization; DR/BCP tests
• Encryption at rest/in transit; RBAC/SoD; planned penetration tests/scans

Marketing & Affiliates

• RG markings, correct T&C bonuses, no "dark patterns"
• Compliance log (screenshots/URL/dates/geo); Quick Recall
• Banning promotions for unlicensed brands and mirrors

Offline geography

• Address compliance with approved zones/radii
• CCTV/cash desk/operating mode; failure and age control logs

12) First year KPIs

Fiscal: timely filing ≥99%; discrepancy otchetnost↔billing <0.5%.
AML/KYC: average verification time; share of false positives; SLA STR/SAR.
RG: proportion of players with active limits; Self-exclusion TTR <1 min; the proportion of RG complaints.
Information security: MTTR incidents; completion of DR tests; closing critical vulnerabilities.
Marketing: 100% self-excluded filtering; 0 violations for advertising and affiliates.

13) FAQ

Is it possible to open an online casino without a local legal entity?
No, it isn't. Need local license/permit and local infrastructure for interaction with supervision.

Are there any fixed payments for offline positions?
Yes, for the ground sector, fixed fees/charges for gaming seats and/or facilities apply, plus position reporting.

How to take into account bonuses in the tax base?
According to local methods for GGR/NGR: bonuses, cancellations, cashout/void are reflected transparently and traceable; errors lead to additional charges.

Is it possible to advertise "risk-free" offers?
No, it isn't. Honest T & Cs, banning misleading language and targeting vulnerable groups are required.

Note

Numerical rates, offline address areas, reporting forms and integration specifications are regularly updated. For legally significant decisions, check the current texts of laws/by-laws and methodological explanations of SRC and relevant departments in order to avoid additional charges, prescriptions and stops of operations.