1. Aram Orbelyan “Concern-Dialog” Law Firm Senior partner Georgia Gaming Congress, 2015

2. Anti money laundering and terrorism financing legislation International instruments Conventions FATF recommendations Others National legislation Laws Secondary legislation

3. The Financial Action Task Force (FATF) recommendation 22 The customer due diligence and record- keeping requirements set out in Recommendations 10, 11, 12, 15, and 17, apply to (a) Casinos – when customers engage in financial transactions equal to or above the applicable designated threshold.

4. The designated thresholds for transactions under FATF recommendation 22 Casinos USD/EUR - 3,000 Financial transactions above a designated threshold include situations where the transaction is carried out in a single operation or in several operations that appear to be linked

5. FATF Recommendation 10 Casinos should implement Recommendation 10 (customer due diligence (CDD)), including identifying and verifying the identity of customers, when their customers engage in financial transactions equal to or above USD/EUR 3,000. Conducting customer identification at the entry to a casino could be, but is not necessarily, sufficient. Countries must require casinos to ensure that they are able to link customer due diligence information for a particular customer to the transactions that the customer conducts in the casino.

6. FATF Recommendation 11 All necessary record on transactions shall be maintained for at least five years. All records obtained through CDD measures shall be kept for at least five years after the business relationship is ended, or after the date of the occasional transaction.

7. CDD measuresRisk assessmentReportMaintenance of records

8. NATIONAL LEGISLATION AND FATF RECOMMENDATION 22  Armenia  Georgia  Russia

9. Reporting (monitoring) entities Armenia Entities organizing Lotteries Entities organizing casinos Entities, organizing games of chance, including over internet Georgia Entities organizing lotteries Entities organizing gambling Entities organizing other commercial games Casino, including internet casino Russia Entities organizing betting Entities organizing gambling Entities organizing game of chance and lotteries, including over the internet

10. Transactions Armenia Purchase of chips (lottery tickets) Betting Providing or payment of the win Any financial transaction connected with abovementioned Georgia transaction concluded or implemented by the person and/or the series of concluded or implemented transactions aimed at partition of the transaction (its amount). an attempt to conclude or implement the transaction which, pursuant to written instructions of the FMS of Georgia, may be related to legalization of illicit income or funding of acts of terrorism. Russia получение денежных средств в виде платы за участие в лотерее, тотализаторе (взаимном пари) и иных основанных на риске играх, в том числе в электронной форме выплата денежных средств в виде выигрыша, полученнего от участия в лотерее, тотализаторе (взаимном пари) и ином основанном на риске игре, в том числе в электронной форме

11. Subject to report (monitoring) Armenia The transaction is suspicious The amount of non- cash transaction is equal to or exceeds 20 mln AMD The amount of transaction in cash is equal to or exceeds 5 mln AMD Georgia The amount of the transaction or the series of transactions exceeds GEL 30,000 (or its equivalent in other currency) (cash//non-cash) The transaction is suspicious Russia The amount of the transaction is equal or more than 600000 RUR or In foreign currency, equal or more than 600000 RUR when exchanged

12. Subject to identification Armenia Identification is required for transactions equal to or equivalent to 1 mln AMD Georgia the amount of the transaction (operation) exceeds GEL 3000 (or its equivalent in another currency); The client aims to carry out domestic or/and cross- border wire transfers that exceeds GEL 1500 (or its equivalent in another currency); Doubts arise regarding the veracity or adequacy of previously obtained client identification data; The transaction is suspicious Russia The amount of participation or the win from participation exceeds the amount of income, which is not subject to taxation under Tax Code of Russia

13. FATF Recommendation 28 Casino should be licensed Competent authorities should take the necessary legal or regulatory measures to prevent criminals or their associates from holding, or being the beneficial owner of, a significant or controlling interest, holding a management function in, or being an operator of, a casino Competent authorities should ensure that casinos are effectively supervised for compliance with AML/CFT requirements

14. Risk-based approach supervision AML/CFT supervision or monitoring General process Allocation of AML/CFT supervision resources Specific process National risk assessment (risks present in the country) Sectoral risk assessment (gambling business) Firm specific risk assessment (type of business, customers, products and services

15. Risk-approach measures  Professional team  Effective internal rules  Real risk assesment  Minimization of risks  Legal mechanisms of risk management  Cooperation with authorized state bodies

16. FATF Recommendation 35 Countries should ensure that there is a range of effective, proportionate and dissuasive sanctions, whether criminal, civil or administrative, available to deal with natural or legal persons covered by Recommendations 6, and 8 to 23, that fail to comply with AML/CFT requirements.

17. Sanctions Administrative (warning, fine) Criminal liability (imprisonment) Armenia Criminal liability (fine or imprisonment) Georgia Administrative (отзыв (аннулирование) лицензии, предупреждение, штраф) Criminal (fine, improsionment) Russia

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