Improving Anti-Money Laundering Efforts in Armenia

Key Points

• Progress and Challenges: Armenia has made significant progress in combating money laundering (ML) and terrorist financing (TF), but there are still areas that require improvement.
• Limited Risk Assessment: The country’s ML/FT risk assessment is limited to the analysis of convictions, which does not provide a comprehensive understanding of the overall criminal activity faced by Armenia.
• Vulnerabilities in DNFBPs Sector: There are vulnerabilities in the Designated Non-Financial Business and Professions (DNFBPs) sector, abuse of legal persons, corruption, shadow economy, and extensive use of cash that need to be addressed.
• Ineffective Use of Intelligence: Law enforcement authorities do not fully utilize intelligence generated by the Financial Monitoring Centre (FMC) in financial investigations.

Recommendations

1. Broaden ML Threat Assessment

Armenia should broaden its ML threat assessment to consider the magnitude and significance of overall criminal activity, including corruption and cross-border illicit flows.

2. Deepen Analysis of Vulnerabilities

The country should deepen its analysis of vulnerabilities, particularly those related to DNFBPs, abuse of legal persons, corruption, shadow economy, and extensive use of cash.

3. Enhance Use of FMC Intelligence

Law enforcement authorities should make full use of FMC intelligence in financial investigations and receive specialized training on using operational and strategic intelligence products.

4. Develop National Law Enforcement Policy

Armenia should develop a national law enforcement policy to investigate and prosecute ML offences.

These recommendations aim to improve Armenia’s understanding of its ML/FT risks, address vulnerabilities, and enhance the effectiveness of law enforcement authorities in combating ML and TF.