AML Requirements for Gambling Operators in Georgia

Every company holding a Georgian gambling permit, including the new international online permits, is an accountable person under Georgia's anti-money laundering law. This post covers what that means in practice for an operator in Tbilisi: who supervises you, when a player must be verified, which reports go to the Financial Monitoring Service and by when, and what your compliance officer and records must look like.

Who Georgia's AML Law Covers

The Law on Facilitating the Prevention of Money Laundering and Terrorism Financing lists "lottery organisers and organisers of games of chance or prize games" among its accountable persons (Art. 3(1)(b.b)). The definition turns on the activity, not the permit type, so a land casino, a domestic sportsbook and a holder of the international online permits created in 2026 are all covered.

The gambling law repeats the point. Article 29(1) obliges every organiser to perform its AML duties and report to the Financial Monitoring Service, and Article 29(1³) extends listed organiser duties, the AML duty among them, to platforms and studios holding the B2B supply permit for gambling products.

When You Must Verify a Player

Article 11(3) of the AML law sets the gambling triggers. An online operator applies due diligence when it establishes the business relationship, which the law defines as registering the customer as a player, so every online account is checked whatever it deposits. A land venue applies it when it receives funds, pays winnings or pays out funds above about €1,700, in one transaction or several linked ones.

A suspicion of money laundering or terrorism financing triggers the checks at any amount (Art. 11(4)). The measures themselves are in Article 10(1): identify the player and verify the identity against a reliable, independent source; identify any beneficial owner, the person on whose behalf the account is really used; establish the purpose and intended nature of the relationship; and monitor it for as long as it lasts. Gambling organisers must also link what they learn from these checks to the player's transaction history (Art. 12(7)).

The gambling law adds its own layer. Every online player is registered, identified and verified by identity document, verified again every year, and may not transfer funds to another player's account (Art. 29(1)). The player registration and verification rules are one of the documents filed with the permit application, so getting a gambling license in Georgia means having the AML onboarding flow written before the Revenue Service sees it.

Enhanced checks for higher-risk players

Higher-risk players get enhanced measures under Article 18: more information on their assets and activity, more frequent updates of their data, more detail on the purpose of their transactions, and management approval to start or continue the relationship. For a politically exposed person, Article 21 adds reasonable measures to establish the source of their wealth and funds and enhanced ongoing monitoring, and the same treatment applies to their family members and close associates.

Players located in a high-risk jurisdiction also get enhanced measures proportionate to the risk (Art. 19(2)). For an international permit holder, whose players are all foreign citizens and mostly live abroad, that check matters on every registration.

What Goes to the Financial Monitoring Service

The reporting rules sit in the AML law and in the FMS Rule on record-keeping, storage and reporting (Order No. 1 of 5 June 2020, amended to November 2025). Gambling organisers file threshold reports on large transactions and suspicious transaction reports at any amount.

Reports go through the FMS online submission system and count as filed only once the system marks them "confirmed" (Rule Art. 8). The threshold is fixed in Georgian currency, so its euro value moves with the exchange rate; about €17,200 is the figure at the October 2026 rate. A suspicious report does not require you to know where the money came from, and it is filed even when the suspicion is not tied to one transaction (Rule Art. 3(5)).

The Compliance Officer and Internal Controls

Article 29 requires internal policies, rules and systems proportionate to your risks, and a written internal instruction approved by management. The instruction covers the compliance officer's rights and duties, rules for hiring qualified and reputable staff, a continuous training programme, and an independent audit function that tests whether the system works.

The compliance officer, or the head of the compliance unit, must hold a position at senior management level and report to a named member of the board or management who answers for AML effectiveness (Art. 29(4)-(5)). The officer decides alone whether to file a suspicious report, and the company must protect the officer from pressure or retaliation (Rule Art. 3(4)).

The FMS Rule also requires a software system to detect suspicious transactions, sized to your volume and risk (Art. 3(1)), and measures to catch complex, unusually large and linked transactions (Art. 3(10)). The same AML programme is among the documents a bank asks for before opening a bank account for a gambling company.

Records You Keep and for How Long

Due diligence data, the results of your analysis, account files and business correspondence are kept for 5 years after the relationship ends or the one-off transaction takes place (AML law Art. 27(1)). Transaction records are kept for 5 years too, in the form the FMS Rule sets out for each one: the type and purpose of the transaction, place and date, form and term, amount and currency, and the identity of the customer, the counterparty and the person it benefits (Rule Art. 11(1)).

The gambling law separately requires copies of players' identity documents to be kept for 5 years (Art. 32(3)). Threshold reports fall due within days of each large transaction while gambling tax is filed monthly, which is why our accounting for gambling companies in Georgia runs the AML reporting calendar alongside the tax one.

Supervision and Penalties

The Ministry of Finance inspects accountable persons at a frequency set by their risk, rates that risk periodically, issues guidance, and must define and apply supervisory measures when an accountable person breaches the law or the rules made under it (AML law Art. 38). We have not located a published Ministry of Finance fine schedule for gambling organisers, so as of October 2026 we quote no amounts.

The AML duty is also written into the gambling law's list of operator obligations (Art. 29(1)), and Article 37¹ of that law sets the fine for an international permit holder at about €6,900. Whether an AML lapse is also pursued as a permit breach is not settled by the texts, but under the Law on Licences and Permits an unremedied breach of permit conditions is fined, then fined at triple the amount, then tripled again, and ends in revocation (Art. 34).

AML for Georgian Gambling Operators FAQ