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Armenia Country Summary

Sanctions

Medium Concern

FATF AML Deficient List

Lower Concern

Terrorism

Lower Concern

Corruption

Medium Concern

US State ML Assessment

Medium Concern

Criminal Markets (GI Index)

Lower Concern

EU Tax Blacklist

Lower Concern

Offshore Finance Center

Lower Concern

Please note that although the below Summary will give a general outline of the AML risks associated with the jurisdiction, if you are a Regulated entity then you may need to demonstrate that your Jurisdictional AML risk assessment has included a full assessment of the risk elements that have been identified as underpinning overall Country AML risk. To satisfy these requirements, we would recommend that you use our Subscription area.

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Anti Money Laundering

FATF Status

Armenia is not on the FATF List of Countries that have been identified as having strategic AML deficiencies

Compliance with FATF Recommendations

The last follow-up Mutual Evaluation Report relating to the implementation of anti-money laundering and counter-terrorist financing standards in Armenia was undertaken in 2019. According to that Evaluation, Armenia was deemed Compliant for 19 and Largely Compliant for 18 of the FATF 40 Recommendations. It was deemed Highly Effective for 0 and Substantially Effective for 6 with regard to the 11 areas of Effectiveness of its AML/CFT Regime.

Sanctions

The United Kingdom has implemented an arms embargo against Armenia, which prohibits the export, supply, or delivery of military goods and items that could be used in the Nagorno-Karabakh region or along the land border between Azerbaijan and Armenia. This embargo is enforced through the Export Control Order 2008, requiring all export and trade license applications for Armenia to be assessed on a case-by-case basis against the UK Strategic Export Licensing Criteria.

Criminality

Rating

0 (bad) - 100 (good)
Transparency International Corruption Index 47
World Bank: Control of Corruption Percentile Rank 57

Armenia is actively working to combat corruption through the establishment of various anti-corruption institutions and the implementation of a new anti-corruption strategy for 2023-2026. Despite these efforts, challenges remain, including public dissatisfaction with the pace of reforms, concerns over the effectiveness and independence of newly formed institutions, and the ongoing influence of powerful officials in both the political and economic spheres.

In terms of crime resilience, Armenia faces significant issues such as human trafficking, drug trafficking, and cybercrime, while also dealing with the influence of state-embedded actors and foreign criminal groups. However, the country has made strides in improving governance and state capacity, particularly in combating organized crime and enhancing judicial pressure on illegal activities, indicating a commitment to strengthening its resilience against crime.

Economy

Armenia's economy and investment climate have shown notable resilience and improvement, as evidenced by its favorable rankings in international business environment indices and significant foreign direct investment inflows, particularly from U.S. companies in sectors such as energy, mining, and technology. The government actively promotes foreign investment through a relatively open legal framework, minimal restrictions on foreign ownership, and various incentives aimed at attracting capital, although challenges such as a small market size, geographic isolation, and concerns about the rule of law and corruption persist. Despite these obstacles, Armenia's GDP growth has exceeded expectations, driven by sectors like trade and information technology, indicating a growing potential for investors willing to navigate the complexities of the local market.

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