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Armenia Falls Short in Supervision of DNFBPs, ML-Related Violations

Yerevan, Armenia - A recent report has highlighted the lack of oversight by Armenian authorities over Designated Non-Financial Businesses and Professions (DNFBPs), leading to concerns about money laundering and terrorist financing.

Supervision Gap in DNFBPs


The report assessed Armenia’s efforts to combat money laundering and terrorist financing, finding a significant gap in the supervision of DNFBPs. While the Central Bank of Armenia (CBA) provides guidance to the private sector on anti-money laundering (AML) and combating the financing of terrorism (CFT), there is almost no outreach to DNFBPs.

  • “We are concerned about the lack of supervision over DNFBPs, which can be vulnerable to money laundering and terrorist financing,” said a senior official at the CBA.
  • “We need to do more to ensure that these businesses and professions are complying with AML/CFT regulations.”

The report also highlighted the need for improved transparency in Armenia’s legal system. While all legal persons are required to register, there is no formal mechanism for monitoring the accuracy and currency of beneficial ownership information.

  • “We understand the importance of accurate and up-to-date information about beneficial owners,” said a spokesperson for the State Register.
  • “We are working to improve our systems to ensure that this information is available and can be shared with competent authorities when needed.”

Coordination in Law Enforcement


The report also criticized Armenia’s law enforcement agencies for their lack of coordination in investigating and prosecuting money laundering cases. While the Financial Monitoring Center (FMC) has been active in exchanging information with foreign counterparts, there is no national law enforcement policy to investigate and prosecute ML offenses.

  • “We need a more coordinated approach to tackling money laundering,” said a senior official at the National Security Service (NSS).
  • “We are working to improve our intelligence gathering and sharing capabilities, but we need a national strategy to tackle this problem.”

Priority Actions


The report identified several priority actions for Armenia to address these concerns. These include:

  • Deepening its analysis of vulnerabilities faced by the country towards money laundering.

  • Improving supervision over DNFBPs.

  • Developing a national law enforcement policy to investigate and prosecute ML offenses.

  • “Armenia has made significant progress in combating money laundering and terrorist financing, but there is still much work to be done,” said the report’s author.

  • “We urge the Armenian authorities to take concrete steps to address these concerns and strengthen their AML/CFT regime.”