Georgian law fully integrates the gambling sector into the national anti-money laundering and counter-terrorist financing framework. The practical takeaway is straightforward: casinos, slot salons, sportsbooks, and systemic-electronic platforms are obliged entities. They must operate risk-based programs that identify and verify customers and monitor behavior. These programs also require enhanced due diligence where warranted. They require the reporting of suspicious and specified threshold transactions to the Financial Monitoring Service of Georgia. They also require the retention of complete, auditable records.
The Scope
Gambling organizers fall within the scope of the Law of Georgia. The law is the Law on Facilitating the Prevention of Money Laundering and the Financing of Terrorism (the AML Law). The Financial Monitoring Service of Georgia (the FMS) is the financial intelligence unit. It receives suspicious activity reports as well as specified threshold and series reports.
The AML Law and FMS rules dictate what operators must identify, monitor, and report. Georgian gambling laws and ministerial instruments define where and how operators must capture, protect, and make data auditable. This includes player registration in systemic-electronic environments and procedures for deposits to and withdrawals from gaming accounts. Together, they create a single compliance perimeter spanning in‑venue and online activity.
Customer Due Diligence
The AML Law requires identification and verification of customers and, where relevant, beneficial owners, with enhanced measures when risks warrant. In-venue, identity checks at entry and at the cage should be supported by procedures that determine the purpose and nature of the relationship. These procedures should escalate enhanced due diligence when red flags appear. Enhanced measures typically include establishing sources of funds for high-turnover patrons, politically exposed persons, or customers whose behavior changes rapidly. Where appropriate, they also include establishing sources of wealth.
Systemic‑electronic operations demand robust remote onboarding. Georgian rules permit electronic identification and verification where technical and procedural safeguards are met. In practice, operators should deploy reliable document capture and verification, liveness checks, and secure data transmission. They should also maintain audit trails that document each verification step end-to-end.
The gambling laws and ministerial rules require organizers to register players’ personal identification data when games are offered in systemic-electronic form. These records must be accurate, complete, and retrievable during inspections.
Eligibility controls are integral and have AML implications. It is prohibited for Georgian citizens under 25 to enter gambling premises or participate in gambling. For foreign citizens and stateless persons, the minimum participation age is 18. Onboarding and entry procedures should therefore capture age and citizenship accurately and enforce these thresholds, including online journeys.
Monitoring and Reporting
Ongoing monitoring is the backbone of an effective program. In land‑based venues, monitoring should reconcile buy‑ins, chip or ticket movements, and cash‑outs, and should identify patterns such as minimal or no play, structuring through repeated sub‑threshold transactions, third‑party cash usage, and rapid swings inconsistent with the stated purpose of play. In online environments, attention should center on rapid deposit‑withdrawal cycles, multiple accounts linked by device or IP, unusual geographies, velocity anomalies,s and attempts to circumvent geofencing or age controls.
Reporting duties are clear. Operators must file suspicious transaction reports to the FMS when they know, suspect, or reasonably suspect that a transaction, attempted transaction or activity involves proceeds of crime, conceals beneficial ownership or otherwise raises AML/CFT concerns. In addition to suspicious reporting, obliged entities must record and report specified threshold transactions and series of transactions in accordance with the FMS’s rule. Systems should aggregate activity across tables, outlets, and online modules and submit reports electronically within defined timeframes.
Additionally, record‑keeping is a separate obligation. Operators must retain identification data, verification artefacts, risk assessments, monitoring outputs, and all reporting files for the statutory period. Records must be protected against alteration or loss and be readily retrievable during inspections. Where third‑party systems are used, the operator remains responsible for data completeness and audit trails.
Systemic‑Electronic Specifics
Online operations introduce distinct AML design needs. Player registration, identification, and verification are mandatory, and the processes must be secure, repeatable,e and auditable. Platforms and critical products are subject to technical standards and integration within a government‑mandated control system operated by a selected person. For AML, this architecture helps by imposing common data structures and integrity checks that support monitoring, reporting, and audits.
Payment flows must align with ministerial procedures for gaming account funding and withdrawals. Operators should ensure platform logs capture the full lifecycle of player account events and financial transactions, with consistent time stamps and identifiers. Reconciliation between platform ledgers and payment service provider statements should be tight, with exceptions investigated and documented.
Supervisory themes are consistent across obliged entities. Georgian authorities expect clear documentation of identification and verification, articulation of the relationship’s purpose and nature, proportionate application of enhanced due diligence, effective ongoing monitoring, timely reporting,g and robust record‑keeping. Administrative fines, remediation orders, and, in serious or repeated cases, suspension or revocation of permits are realistic outcomes where programs fall short.