LSA law firm

Armenia may be attractive to foreign investors in the iGaming sector as a country with an active technological infrastructure in the region. However, iGaming licensing in Armenia and obtaining an internet gambling license should not be regarded as a simple or low-cost way to enter the international market.Rather, Armenia’s iGaming regulatory framework should be viewed as a relatively strict licensing regime, where requirements related to state fees, KYC/AML procedures, domain structure, advertising restrictions, and new legislative changes (hereinafter also referred to as the “New Law”) may create practical challenges for investors.In Armenia, gambling, internet gambling, and casino activities may be carried out by commercial organizations registered in Armenia based on the relevant license. In the case of internet gambling, activities may also be conducted based on the right to accept bets.Armenian gaming law establishes specific compliance requirements for iGaming businesses, and foreign investors should conduct legal due diligence before entering the Armenian market.1. Product classification must be determined before filing the license applicationThe first question for a foreign investor should not only be “how to obtain a license,” but also “which activity requires a license.”Armenian regulations distinguish between internet gambling, bookmaker activity, lotteries, and other types of gaming activities.Under the New Law, a separate license is required for each type of gaming activity, while bookmaker activity is regulated separately from internet gambling.This is particularly important for investors planning to combine casino games, live casino, sportsbook, betting, or other hybrid products on a single platform.An internet gambling license alone is not sufficient to conduct bookmaker activity.Accordingly, the product structure and classification should be legally determined before submitting the license application. Otherwise, the investor may face additional licensing requirements, business restructuring, delays, or potential liability risks.Proper product classification is one of the most important stages of obtaining an iGaming license in Armenia.2. The license is indefinite, but the financial burden is continuous and increasingAn internet gambling license is issued for an indefinite term. However, maintaining the license requires significant annual state payments.As of the date of this publication, the annual state duty amounts to AMD 600,000,000.In addition, an internet gambling operator must obtain the right to accept bets.For each AMD 100 billion in accepted bets, the state duty is calculated as the product of 175,000 times the base duty, amounting to AMD 175,000,000, multiplied by the applicable coefficient.The coefficients are established as follows:2.0 from 1 April 2025;3.0 from 1 January 2026;4.0 from 1 January 2027;5.0 from 1 January 2028.The duty must be paid by the fifth business day following the date on which the relevant threshold is reached. The payment is not refundable if the acquired right is not used.In practical terms, this means that investors must calculate in advance not only the cost of an Armenia iGaming license, but also the fees connected with betting volume.Under this system, costs are directly linked to the amount of accepted bets rather than only to profit or margin.Therefore, high-turnover but low-margin business models require specific financial stress testing before entering the Armenian market.3. The “.am” domain and website structure are key components of the licensing frameworkThe New Law also provides that internet gambling may only be organized through the official website and gaming applications specified in the license.Operating through websites or applications that are not listed in the license may be considered conducting licensable activity without a license.For foreign investors, this means that the domain strategy, brand strategy, and website or application structure must be planned in advance.An operator licensed in Armenia may provide services to non-Armenian residents; however, this must be done under the same brand name and through the “.AM” domain.A new domain may be considered a new website and may therefore require separate licensing.Therefore, when entering the Armenian iGaming market, investors must consider not only obtaining a gambling license, but also properly structuring the technical and legal infrastructure of the business.4. An Armenian license is not an international “passport”In substance, Armenian legislation does not establish a general prohibition preventing an internet gambling operator licensed in Armenia from providing services to foreign players.However, this does not mean that an Armenia gambling license automatically authorizes services in every jurisdiction worldwide.Investors must separately assess the regulations of the countries where players are located or where they are considered residents.This issue is particularly important from the perspective of:marketing activities;payment routing;player onboarding.Even where the activity is legally licensed in Armenia, violating the laws of the target jurisdiction may create legal risks in that country.Accordingly, Armenian iGaming licensing should be viewed as the legal basis for operating from Armenia, rather than as a worldwide authorization.5. KYC and payment models for foreign players must be structured before launchArmenian law requires operators, before granting access to internet gambling services, to identify customers and register their information in order to prevent participation by persons under the age of 21.In addition, customers conducting transactions exceeding AMD 1 million must undergo identification procedures, and the operator must create and maintain a database containing their information.The payment model for foreign players is subject to specific requirements.Under the current legal framework, deposits into special gaming accounts, bets, and payment of winnings must generally be carried out through non-cash transactions in Armenian drams.Foreign currency may be used where:the player is not an Armenian citizen;the residence address provided by the player is outside Armenia;the transaction is conducted from a non-Armenian IP address;the payment is not made through a bank or payment and settlement organization licensed by the Central Bank of Armenia.In addition, gaming accounts must be funded through a bank account or card belonging to the player.Where Armenian bank accounts or cards are used, the operator must verify ownership according to the established procedure.Certain exceptions apply to accounts and cards issued by foreign banks; however, these exceptions do not eliminate the need to manage AML/KYC compliance risks.6. The New Law introduces additional capital, certification, and operational requirementsThe New Law introduces additional capital, certification, and operational requirements that foreign investors should carefully consider before entering the Armenian iGaming market.The principal provisions of the New Law will become fully applicable on the day following the completion of the sixth month after the selection of the gaming sector regulatory Operator. Licenses issued before that date must be brought into compliance with the requirements of the New Law within six months thereafter. Failure to comply with these requirements may result in the relevant licenses being deemed terminated.The New Law also requires an internet gambling organizer, throughout the validity period of the license, to maintain a deposit in a bank operating in Armenia equal to twice the amount of the annual state duty. This requirement creates an additional financial obligation for licensed operators and should be included in the investment planning and compliance strategy.In addition, gaming products must have certificates of conformity. For gaming products where winnings are determined through random number generators, the minimum programmed total payout must be 90 percent.The new regulatory framework also establishes important staffing and operational requirements. Gaming operations must be carried out by individuals holding valid operational certificates. The Operator will have a central role in issuing certificates of conformity or verifying the authenticity of certificates issued by international laboratories.For foreign investors, these requirements mean that regulatory compliance should be considered not only during the licensing process but also throughout the entire operational period of the business. Proper preparation of internal compliance procedures, technical systems, employee certification processes, and operational controls is essential for maintaining an Armenian iGaming license.7. Advertising should be treated as a separate compliance riskAdvertising of gambling, internet gambling, casinos, and their organizers is strictly restricted under Armenian legislation. Therefore, advertising compliance should be considered as a separate legal risk when developing an iGaming business strategy in Armenia.The current law prohibits advertising through methods not expressly permitted by law, the display of money or images of minors, messages directed at minors, and any content that creates the impression of regular or guaranteed income from gambling activities. Advertising materials must also include a warning regarding the risk of financial loss.For foreign investors planning international marketing campaigns, it is important to consider two regulatory layers: the rules of the target country and Armenian advertising regulations.Even where advertising is directed primarily at foreign markets, accessibility from Armenia may create additional compliance considerations. Therefore, operators should evaluate advertising channels, digital marketing strategies, affiliate programs, and promotional campaigns from both Armenian and foreign regulatory perspectives.A properly structured advertising compliance policy can help reduce regulatory risks and ensure that marketing activities remain aligned with Armenian gambling legislation and the requirements of foreign jurisdictions. ConclusionArmenian iGaming licensing may present opportunities for foreign investors seeking to establish operations in a technologically developing regional market. However, entering the Armenian internet gambling sector requires detailed legal analysis, regulatory planning, and comprehensive due diligence.Before beginning the licensing process, investors should have a clear product classification strategy, a financial model covering state duties and betting-related thresholds, a properly structured “.AM” domain and brand strategy, a KYC/AML compliance framework, a payment architecture, a legal assessment of target jurisdictions, and a plan for meeting the capital, technical, and operational requirements introduced by the New Law.Successful market entry depends not only on obtaining an iGaming license in Armenia but also on ensuring that the entire business model is properly structured at the intersection of Armenian legislation, international market requirements, and the evolving regulatory framework of the gaming industry.LSA Law Firm provides legal support in the iGaming sector, assisting foreign investors with licensing, compliance, gaming regulation, and business structuring in Armenia.

The birth of a child is the most anticipated, emotional, and life-changing event in life. However, when this long-awaited journey takes place through a surrogacy (gestational carrier) program, it is accompanied by numerous complex legal issues, legal restrictions, and documentation requirements related to surrogacy in Armenia and its legal support process.In this responsible process, your only task should be to prepare with love for the arrival of your baby, while all legal risks and documentation matters should be entrusted to professionals. The LSA Law Firm is ready to ensure the legal security of your family from the very beginning of the program until the issuance of the birth certificate, providing full legal support for surrogacy in Armenia.Why specialized legal assistance is necessaryThe surrogacy process in the Republic of Armenia is regulated by clear legislation, however every case is unique and requires a surrogacy agreement and legal support.Without a properly drafted, professional and comprehensive agreement, both intended parents and the surrogate mother may face unpredictable and serious legal issues related to surrogacy regulation in Armenia.These may include:·         artificial difficulties in obtaining a birth certificate at medical institutions and civil registry offices;·         incomplete fulfillment of financial or organizational obligations between parties;·         psychological and legal disputes in the future.Legal regulation: who may participateIn Armenia, surrogacy-related relations are regulated by the Civil Code of the Republic of Armenia and the Law on Reproductive Health and Reproductive Rights.1. Who may use surrogacy programsThe program is available to women or married couples with clear medical indications (such as inability to carry a pregnancy, absence or pathology of the uterus, repeated failed IVF attempts, etc.), confirmed by medical documentation within legal surrogacy support.2. Who can be a surrogate mother in ArmeniaUnder Armenian law, a surrogate mother must meet the following requirements:·         age between 20 and 38 years inclusive;·         at least one healthy biological child;·         no more than three previous deliveries;·         no more than one cesarean section;·         medical examinations with no contraindications;·         written consent of spouse if married;·         limitation: no more than two surrogacy participations.3. Key legal rulesNo genetic connection: the surrogate mother cannot be an egg donor and must not have any genetic relationship with the child.Parental rights: under the law, the legal parents are the individuals whose genetic material was used, provided a properly executed surrogacy agreement exists.Our legal servicesLSA Law Firm provides full and comprehensive legal support for surrogacy programs in Armenia (turn-key solutions), including surrogacy attorney services.Contract draftingWe prepare a surrogacy agreement where the following are clearly defined:·         rights and obligations of the parties throughout pregnancy;·         financial compensation and medical expenses;·         insurance and healthcare coverage;·         force majeure situations;·         lifestyle and behavioral rules for the surrogate mother.NotarizationUnder Armenian law, the surrogacy agreement is subject to mandatory notarization prior to embryo transfer (IVF/embryo transfer). We ensure full compliance with notarization requirements.Document collection and supportWe fully handle communication with medical institutions and state bodies, ensuring legal support at every stage.Birth certificate and civil registry processAfter the child is born, we complete the final registration of parental rights with civil registry authorities, ensuring registration without mentioning the surrogate mother in accordance with Armenian law.ConfidentialityLSA Law Firm guarantees attorney-client privilege and full protection of all information related to the surrogacy process.ConclusionTrust us with legal support for surrogacy in Armenia to ensure your path to parenthood is safe, lawful, and fully protected.

On 3 July 2026, the National Assembly of the Republic of Armenia adopted Law No. HO-398-N amending the Administrative Procedure Code of the Republic of Armenia. One of the provisions of the new law provides for the automatic termination of interim measures previously ordered by courts prohibiting the demolition of unauthorised constructions located on state- or municipally-owned land.The Law enters into force on 30 August 2026.The lawyers of LSA Law Firm consider that this regulation raises serious questions as to its compatibility with the Constitution of the Republic of Armenia. In the context of an administrative case currently pending before the Administrative Court, LSA has filed a motion requesting the Court to refer the issue of the constitutionality of the new regulation to the Constitutional Court.What Has Changed Under the New Law?Article 2(2) of Law No. HO-398-N provides that interim measures granted on the basis of applications submitted before the Law enters into force, which prohibit the demolition or dismantling of unauthorised constructions situated on state- or municipally-owned land, shall be deemed terminated upon the entry into force of the Law.Accordingly, the provision does not apply only to new court proceedings.The Law directly affects pending cases in which courts have already considered whether interim protection was necessary and have issued judicial acts temporarily prohibiting the demolition of the relevant property.Once the Law enters into force, such interim measures will cease to have effect by operation of law, without any fresh judicial assessment of the circumstances of the individual case.In LSA's view, it is precisely this mechanism that gives rise to a serious constitutional issue.Can the Legislature Nullify the Effects of an Existing Judicial Act?One of the key issues concerns compliance with the principle of separation of powers.Article 4 of the Constitution of the Republic of Armenia provides that state power shall be exercised on the basis of the separation and balance of the legislative, executive and judicial powers.Pursuant to Article 162 of the Constitution, justice in the Republic of Armenia is administered exclusively by the courts, and any interference with the administration of justice is prohibited.An interim measure is the result of the exercise by a court of its procedural powers. The court assesses the circumstances of a particular case and determines whether certain actions should be temporarily restricted pending the final resolution of the dispute.This therefore raises a fundamental question:Can the legislature, by adopting a new law, automatically terminate an interim measure previously ordered by a court in a specific case?LSA's position is that such regulation displays characteristics of legislative interference in the exercise of judicial power.Where a court, having examined the circumstances of a particular case, has considered it necessary to temporarily prohibit the demolition of a property, the termination of that measure should take place through the judicial procedure prescribed by law and with due consideration of the circumstances of the case, rather than automatically as a consequence of a subsequent legislative amendment.The Right to Effective Judicial ProtectionThe issue is not merely institutional.Article 61 of the Constitution of the Republic of Armenia guarantees everyone the right to effective judicial protection of their rights and freedoms.Article 75 of the Constitution requires the existence of legislative mechanisms and procedures necessary for the effective exercise of fundamental rights and freedoms.Interim measures constitute one of the key mechanisms for ensuring effective judicial protection.Their purpose is, among other things, to prevent a situation in which, by the time a final judgment is delivered, the restoration of the infringed right has become impossible or excessively difficult.This issue is particularly evident in disputes involving the demolition of immovable property.Where an individual challenges actions or decisions that may result in the demolition of a property, and the court temporarily prohibits the demolition pending resolution of the dispute, the automatic termination of that prohibition may allow the property to be demolished before a final judicial decision is rendered.If the court subsequently finds the individual's position to be well-founded, the property may by then no longer physically exist.In such circumstances, judicial protection risks becoming merely formal: a person may ultimately succeed in the proceedings, while restoration of the situation existing prior to the violation of their rights may no longer be possible.The Issue of Retroactive EffectA separate constitutional issue concerns the temporal application of the Law.Article 73 of the Constitution of the Republic of Armenia provides that laws and other legal acts which worsen a person's legal position shall not have retroactive effect.However, the new regulation expressly applies to interim measures ordered on the basis of applications submitted before the new Law enters into force.Persons who obtained judicial protection prior to the adoption of the new Law could legitimately expect the relevant judicial act to remain effective in accordance with the applicable procedural framework.The new Law changes the legal consequences of procedural acts that have already taken place and directly worsens the position of persons in whose favour a court had previously ordered interim protection.In LSA's view, this provides grounds for referring to the Constitutional Court the question of whether such regulation complies with the constitutional prohibition on giving retroactive effect to provisions that worsen a person's legal position, as well as with the principles of legal certainty and the protection of legitimate expectations.The Binding Force of Judicial ActsThe binding force of final judicial acts is another important consideration.The judiciary can effectively perform its constitutional function only where judicial decisions are binding on state bodies, local self-government bodies, public officials and other participants in legal relations.Where a subsequent legislative amendment automatically removes the effects of a judicial act adopted in a specific case, there is a risk of undermining the very principle of the binding force of judicial decisions.The issue becomes particularly sensitive where one of the parties to an administrative dispute is a state authority or a local self-government body.A legislative amendment may, in practice, improve the procedural position of a public authority during ongoing judicial proceedings while simultaneously depriving the opposing party of interim protection previously granted by the court.This raises a further question as to whether a fair balance between the parties to the judicial proceedings is being maintained.LSA Has Filed a Motion with the CourtThe issue has already developed into a practical procedural matter.An administrative case is currently pending before the Administrative Court of the Republic of Armenia in which the Court previously granted an application submitted on behalf of the party represented by LSA Law Firm and ordered an interim measure requiring the Yerevan Municipality to refrain from taking any action to demolish or dismantle the disputed property until the final decision concerning its legalisation enters into force.Following the adoption of Law No. HO-398-N, LSA's lawyers filed a motion requesting the Court to consider referring the matter to the Constitutional Court of the Republic of Armenia.The motion raises the question of whether the new legislative regulation complies with Articles 4, 61, 73, 75 and 162 of the Constitution of the Republic of Armenia.LSA's position is that there are substantiated doubts as to the constitutionality of a provision which, by operation of law, terminates an interim measure previously ordered by a court.Why Does This Issue Have Wider Significance?The constitutional issue extends far beyond a single administrative case.It concerns the fundamental relationship between the powers of the legislature and the judiciary, as well as the limits within which the legislature may amend procedural rules in relation to judicial proceedings that are already pending.Ultimately, several fundamental questions require clarification:whether the legislature may automatically terminate an interim measure previously ordered by a court in a specific case;whether such interference is compatible with the principle of separation of powers and the independence of the judiciary;whether effective judicial protection remains available where the disputed property may be destroyed before a final judicial decision is rendered;whether it is permissible to apply new legislation to interim measures ordered before that legislation enters into force; andwhether such regulation infringes the principles of legal certainty, legitimate expectations and the binding force of judicial acts.LSA Law Firm will continue to advocate for constitutional review of the new regulation and to closely follow the development of judicial practice in this area.If the Court concludes that the statutory grounds for referral to the Constitutional Court are satisfied, the compatibility of the disputed regulation with the Constitution of the Republic of Armenia may ultimately be assessed through constitutional adjudication.This publication constitutes a legal analysis of the legislative amendments and reflects the position of LSA Law Firm on the relevant issue. The final determination as to the constitutionality of the Law falls within the jurisdiction of the Constitutional Court of the Republic of Armenia.Co-authors: Arsen Sardaryan and Edgar Ayvazyan