Higher Risk
 
Medium Risk
 
Info n/a
 
Lower Risk
Bilateral exchange of information
Agreements in place?
    No
Tables & Rankings
Are there Sanctions in force against it? (UN/EU/US)
Y
?
Is it on FATF list of non-cooperative countries?
N
?
Is it on OECD list of uncooperative Tax Havens?
N
?
OECD - Implementation status of Tax Standard
 
?
Is it on EU 'white' list of equivalent jurisdictions?
N
?
Offshore Finance Center (Original IMF List)?
N
?
Is it on the US Secretary of Treasury list of jurisdictions of
Primary Money Laundering concern?
N
?
Is it on the US Secretary of State list of jurisdictions
identified to be supporters of International Terrorism?
N
?
Is it on US Department of State International Narcotics
Control Majors List?
N
?
US Dept of State Money Laundering assessment (INCSR)
M
?
Government Actions (For further info see INCRS below):
 
?
-  Criminalized Drug Money Laundering?
Y
 
-  Criminalized Beyond Drugs?
Y
 
-  Record Large Transactions?
 
 
-  Maintain Records Over Time?
Y
 
-  Report Suspicious Transactions?(NMP)?
Y
 
-  Egmont Financial Intelligence Units?
Y
 
-  System for Identifying/Forfeiting Assets?
Y
 
-  Arrangements for Asset Sharing?
N
 
-  Cooperates with International Law Enforcement?
Y
 
-  International Transportation of Currency?
Y
 
-  Ability to Freeze Assets w/o delay?
Y
 
-  Disclosure Protection "Safe Harbor"?
Y
 
-  Criminalized Financing of Terrorism?
Y
 
-  States Party to 1988 UN Convention?
Y
 
-  International Terrorism Financing Convention?
Y
 
 
Ranking
2011
Ranking
2010
 
Corruption (Transparency International)
129 (out of
183)
123 (out
of 178)
?
Ease of doing business (World Bank)
55 (out of
183)
48 (out of
183)
?
FATF 40 + 9 recommendations
Mutual Evaluation Report: 2009
Further Tables
C
L
P
N
N/A
    C  -  Fully Compliant ,   
    L  -  Largely Compliant,    
    P  -  Partially Compliant    
    N  -  Non-Compliant
6
20
17
5
1
Legal Systems
 
1. Money Laundering Offence
L
 
14. Protection & no tipping-off
C
2. ML offence – mental element and
corporate liability
L
 
15. Internal controls,
compliance & audit
P
3. Confiscation and provisional
measures
P
 
16. DNFBP – R.13-15 & 21
P
4. Secrecy laws consistent with the
Recommendations
P
 
17. Sanctions
C
5. Customer due diligence
P
 
18. Shell banks
L
6. Politically exposed persons
L
 
19. Other forms of reporting
C
7. Correspondent banking
C
 
20. Other NFBP & secure
transaction techniques
P
8. New technologies & non
face-to-face business
L
 
21. Special attention for
higher risk countries
L
9. Third parties and introducers
N
 
22. Foreign branches &
subsidiaries
C
10. Record keeping
L
 
23. Regulation, supervision
and monitoring
L
11. Unusual transactions
L
 
24. DNFBP - regulation,
supervision and monitoring
N
12. Designated Non-Financial
Businesses and Professions – R.5,
6, 8-11
N
 
25. Guidelines & Feedback
P
13. Suspicious transaction reporting
L
     
Institutional and other
measures
 
26. The FIU
L
 
31. National co-operation
L
27. Law enforcement authorities
L
 
32. Statistics
N
28. Powers of competent authorities
P
 
33. Legal persons –
beneficial owners
L
29. Supervisors
L
 
34. Legal arrangements –
beneficial owners
N/A
30. Resources, integrity and training
P
 
 
 
International Co-operation
 
35. Conventions
P
 
38. MLA on confiscation and
freezing
P
36. Mutual legal assistance (MLA)
P
 
39. Extradition
C
37. Dual criminality
L
 
40. Other forms of
co-operation
L
Nine Special
Recommendations
 
SR.I Implement UN instruments
P
 
SR VI AML requirements for
money/value transfer services
L
SR.II Criminalise terrorist financing
P
 
SR VII Wire transfer rules
L
SR.III Freeze and confiscate
terrorist assets
N
 
SR.VIII Non profit
organisations
P
SR.IV Suspicious transaction
reporting
L
 
SR.IX Cross Border
Declaration & Disclosure
P
SR.V International co-operation
P
 
 
 
*Please note that FATF deems that a country has significant aml deficiencies if
any of the 'Core' Recommendations, R1, R5, R10, R13, SRII, or SRIV are rated
either Partially of Non-Compliant. These are marked in red.

For FATF to remove a country from the regular follow-up process, it has to be rated
Compliant or Largely Compliant in the above mentioned Core Recommendations
and the following Key Recommendations: -        

R3, R4, R23, R26, R35, R36, R40, SRI, SRIII, SRV

Please also note that any risk assessment should take into consideration all
follow-up reports.
ARMENIA
KnowYourCountry
Sanctions:

In February 1992, the Organisation for Security and Co-operation
in Europe (OSCE) requested that all OSCE participating states
should introduce an embargo on 'all deliveries of weapons and
munitions to forces engaged in combat in the Nagorno-Karabakh
area'. This embargo is still in force.

____________________________________________________

Offshore Jurisdiction Blacklists:

Information unavailable.

____________________________________________________

US State Department Money Laundering Report - 2011:

Armenia is a not a regional financial center and is not believed to
be at major risk for money laundering and terrorist financing.
However, governmental corruption, an organized crime presence
and a large shadow economy make the country vulnerable. The
major sources of laundered proceeds stem from tax evasion and
fraudulent financial activity, particularly transactions with forged
credit cards. Money laundering in Armenia generally takes place
through the banking system, through informal remittances from
Armenians living abroad, and through high-value transactions
such as real estate purchases.

DO FINANCIAL INSTITUTIONS ENGAGE IN CURRENCY
TRANSACTIONS RELATED TO INTERNATIONAL NARCOTICS
TRAFFICKING THAT INCLUDE SIGNIFICANT AMOUNTS OF US
CURRENCY; CURRENCY DERIVED FROM ILLEGAL SALES IN
THE U.S.; OR THAT OTHERWISE SIGNIFICANTLY AFFECT THE
U.S.: NO

CRIMINALIZATION OF MONEY LAUNDERING:

“All serious crimes” approach or “list” approach to predicate
crimes: List approach

Legal persons covered: criminally: NO civilly: YES

CRIMINALIZATION OF TERRORIST FINANCING:

Ability to freeze terrorist assets without delay: YES

UN lists of designated terrorists or terrorist entities distributed to
financial institutions: YES

(Please refer to the Department of State’s Country Reports on
Terrorism, which can be found here: http://www.state.
gov/s/ct/rls/crt/)

KNOW-YOUR-CUSTOMER RULES:

Covered entities: Banks; exchange houses; real estate agents;
notaries, lawyers, accountants, and auditors; dealers in precious
metals and stones, and artworks organizers of auctions casinos,
prize games, and lotteries; trust and company service providers;
State Cadaster, and the State Registry

Enhanced due diligence procedures for PEPs: Foreign: YES
Domestic: NO

SUSPICIOUS TRANSACTION REPORTING REQUIREMENTS:

Covered entities: Banks; exchange houses; real estate agents;
notaries, lawyers, accountants, and auditors; dealers in precious
metals and stones, and artworks organizers of auctions casinos,
prize games, and lotteries; trust and company service providers;
State Cadaster, and the State Registry

Number of STRs received and time frame: 420 in 2010

Number of CTRs received and time frame: 132,249 in 2010

MONEY LAUNDERING CRIMINAL
PROSECUTIONS/CONVICTIONS:

Prosecutions: Nine in 2010

Convictions: Two in 2010

Assets forfeited: criminally: $1,433,194 in 2010 civilly: 0 in 2010

RECORDS EXCHANGE MECHANISM:

With U.S.: YES

With other governments/jurisdictions: YES

Armenia is a member of the Committee of Experts on the
Evaluation of Anti-Money Laundering Measures and the Financing
of Terrorism (MONEYVAL), a Financial Action Task Force (FATF)-
style regional body. Its most recent mutual evaluation can be
found here:

http://www.coe.
int/t/dghl/monitoring/moneyval/Countries/Moldova_en.asp

ENFORCEMENT AND IMPLEMENTATION ISSUES AND
COMMENTS:

In 2009, Armenia achieved its first successful money laundering
prosecutions, as courts convicted four defendants in three cases.
Money laundering prosecutions have continued in 2010. There
have been no known cases of terrorist financing in Armenia.
Armenia should prohibit bearer bank books, certificates of deposit
and other bearer securities, and should criminalize tipping off.
Armenia has prepared a package of legislative amendments to 17
laws to correct several deficiencies regarding its money
laundering and terrorist financing offenses and customer due
diligence procedures.

____________________________________________________

US State Dept Narcotics Report 2011 (introduction):

Armenia is not a major drug-producing country, and domestic
abuse of drugs is relatively modest. Because it lies along
smuggling routes between Asia and Europe, Armenia has
experienced some use as a transit country for drug trafficking.
However, Armenia is landlocked, and the two longest of its four
borders, those with Turkey and Azerbaijan, are closed. The
resulting limited transport options make the country a secondary
traffic route for drugs. However, two factors may be increasing
interest among traffickers to use Armenia as a primary transit
route: 1.) Turkish interdiction efforts may be forcing smugglers to
take other routes into Europe, and 2.) Armenia’s borders with
Russia and Georgia have been closed since 2008.

The Armenian Police Service's Department to Combat Illegal Drug
Trafficking (Anti-Drug Department) has accumulated a significant
database on drug trafficking sources, including routes and people
engaged in trafficking. Scarce financial and human resources,
however, limit the Police Service's effectiveness. The Armenian
government is currently reforming its border control system, which
is primarily under the purview of the Customs Service and the
paramilitary Border Guards. With U.S. assistance, Armenia is
implementing integrated border management practices that
should improve the authorities’ ability to detect shipments of illegal
drugs, as well as other types of contraband.

Resources for treatment of drug addicts have increased
significantly in the last several years, but the number of registered
addicts continues to rise sharply as well, partly because legislative
changes now allow drug abusers to seek help without fear of
prosecution. Armenia is a party to the 1988 UN Drug Convention.

For Full report, click here

____________________________________________________

US State Dept Trafficking in Persons Report 2012
(introduction):

(Tier 2)

Armenia is not a major drug-producing country, and because of
conservative social mores domestic abuse of drugs continues to
be relatively modest. Because it lies along smuggling routes
between Asia and Europe, Armenia continues to experience some
use as a transit country for drug trafficking. However, since
Armenia is landlocked and the two longest of its four borders
remain closed, the resulting limited transport options make the
country a secondary route for drug trafficking.

The Armenian Police have accumulated significant intelligence on
drug trafficking sources, including routes and people engaged in
trafficking. Scarce financial and human resources, however, limit
the police's effectiveness. The Armenian government continues to
reform its border control system, which falls primarily under the
purview of the Border Guards (a unit of the National Security
Service), Customs Service (a unit of the State Revenue
Committee), and Police. With U.S. assistance, Armenia continues
to develop and implement an integrated border management
regime that should improve its ability to detect shipments of illegal
drugs and other types of contraband.

Resources for treatment of drug addicts have increased in recent
years, but the number of registered addicts has also increased,
partly due to legislative changes that allowed abusers to seek
help without fear of prosecution. Armenia is a party to the 1988
UN Drug Convention.

For full report click here

____________________________________________________

US State Department Terrorism Report 2010

Overview: Armenia took a number of positive steps in the fight
against international terrorism, which included improvements to its
border security, significant changes to export control laws, and
participation by Armenian experts in internationally sponsored anti-
terrorism training courses.

Legislation and Law Enforcement: In recent years, Armenia has
achieved measured progress in improving its border security. This
progress has included the installation of radiation portal alarms at
all ports of entry including its main airport, the addition of sensors
for increased monitoring of Armenia's border with Georgia, and
significant legislative changes in its export control laws. The
Armenian Border Guard Service used the automated Border
Management Information System (BMIS) at all points of entry,
including a BMIS criminal and terrorist watch list updated by the
Armenian National Security Service (NSS). In November, the
heads of the Armenian NSS, Ministry of Defense, and State
Revenue Committee (Customs) established a new Border and
Customs Enforcement Operations Task Force to oversee and
further enhance border security operations. In November,
President Sargsian approved a National Integrated Border
Management Strategy.

Regional and International Cooperation: Armenia ratified the
International Convention for Suppression of Acts of Nuclear
Terrorism in 2010. Armenia participated in bilateral and
multilateral assistance, security, and training initiatives targeted at
strengthening its ability to counter terrorism, terrorist financing,
and the smuggling of illicit and hazardous materials. Armenia’s
activity in these initiatives in 2010 included the EU's South
Caucasus Integrated Border Management project, which will
provide funds to make major upgrades to several of Armenia's
border crossing points, thus facilitating enhanced integrated
border security operations.

Armenia continued to make progress in counterterrorism
cooperation with NATO. Armenia submitted a new Individual
Partnership Action Plan that noted Armenia's desire to continue
cooperation with NATO on counterterrorism issues, and it
participated in the Partnership Action Plan on Terrorism. This
participation included sharing intelligence and analysis with
NATO, enhancing national counterterrorism training capabilities,
and improving border security. NATO and Armenia also
cooperated on the establishment of a "situation center" in
Yerevan, which assisted in crisis management and
counterterrorism coordination.

In December, the OSCE hosted in Yerevan a national expert
workshop on countering terrorist use of the Internet and
comprehensively enhancing cyber-security.

Countering Terrorist Finance: In January, the Council of Europe's
Committee of Experts on the Evaluation of Anti-Money Laundering
Measures and the Financing of Terrorism (MONEYVAL) published
an evaluation report on Armenia. In the report, MONEYVAL noted
that the criminal provisions relating to terrorism financing are
broadly in line with international standards but further
amendments were necessary. The report added that the
continuing development of human and technical resources with
regard to terrorism financing remained an ongoing challenge.

____________________________________________________

Links:

Worldwide AML Legislation (International Bar Association)
-  Know Your Customer Provisions
Y
 
-  Criminalized Tipping Off?
N
 
-  Report Suspected Terrorist Financing?
Y
 
-  State Party to United Nations TOC?
Y
 
-  State Party to United Nations CAC?
Y
 
Local AML News / Sanctions
Tax Information
Business Information
Last Updated:   16 April 2012