Financial Crime World

Title: Armenian Businesses Navigating AML Regulations: Insights from MONEYVAL’s 2015 Report

Introduction

Armenia’s economy is making strides in adhering to international Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) regulations. In this article, we explore the key findings and recommendations for businesses from MONEYVAL’s 2015 report on Armenia’s progress in these areas.

Armenia’s Progress and Challenges

  • MONEYVAL’s assessment: Armenia’s legislative and regulatory framework for tackling money laundering and terrorism financing was commended for its high level of technical compliance with international conventions and the FATF 40 Recommendations, while there were areas for improvement.
  • Money laundering risks: The money laundering risks in Armenia are considered moderate, with swindling, theft, tax evasion, and corruption being the most significant threats. The threat of terrorism financing is very low due to minimal indications of private sector and non-profit organizations being misused for such purposes.
  • Law enforcement concerns: There are concerns about law enforcement’s ability to effectively use financial intelligence unit (FIU) notifications and convert intelligence into evidence. Few money laundering investigations and prosecutions have taken place, with a focus on self-laundering cases and minimal proactive parallel financial investigations for money laundering and predicate offenses.

Focus Areas for Improvement

Confiscation and Seizure

  • Concerns in the banking sector: The banking sector, which conducts the majority of financial transactions, is particularly vulnerable to money laundering. Members of the sector must ensure they maintain adequate risk assessments, implement customer due diligence, record-keeping, and reporting measures.
  • Confiscation challenges: Confiscation and seizure of proceeds, instrumentalities, and property of equivalent value pose areas of concern for Armenian law enforcement.

DNFBP Supervision

  • Regulation of non-financial businesses and professions: Real estate agents, dealers in precious metals and stones, lawyers, and accountants are among the professions identified as posing a higher risk of money laundering. Improved supervision and preventive measures are essential to mitigate these risks.

Conclusion

  1. Armenian businesses are expected to adhere to global AML and CTF regulations.
  2. Ongoing improvements are required in law enforcement, financial intelligence use, and DNFBP supervision as highlighted in MONEYVAL’s report.
  3. Stay informed of the latest regulations and best practices to protect businesses from reputational and legal risks.

By understanding these key points, businesses can navigate the AML and CTF regulatory landscape in Armenia more effectively.