Financial Crime World

Armenia’s Anti-Terrorism Efforts Need Strengthening

Yerevan, Armenia - International experts have released a scathing report condemning Armenia’s efforts to combat terrorism and money laundering. The report highlights weaknesses in the country’s legal framework and inadequate implementation of existing laws.

The report notes that Armenia’s criminal provisions for money laundering are “basically sound” but lack clarity on how to prosecute the offense independently of predicate crimes. Additionally, legal persons are not subject to criminal liability under Armenian law, making it difficult to hold companies accountable for terrorist financing.

  • Lack of clarity in prosecuting money laundering offenses
  • No criminal liability for legal persons in terrorist financing cases

Anti-Terrorist Financing Laws

Experts call for amendments to broaden the scope of Armenia’s anti-terrorist financing laws to cover all nine conventions and protocols annexed to the Terrorist Financing Convention. The current provisions do not extend to situations where property or funds are provided to individual terrorists or organizations without the intention or knowledge that they will be used in a specific act of terrorism.

  • Limited scope of anti-terrorist financing laws
  • No coverage for situations involving individual terrorists or organizations

Confiscation Framework and Financial Secrecy Laws

The report highlights concerns over Armenia’s confiscation framework, which does not cover all FATF-designated predicate offenses and creates uncertainties in its application. The country’s financial secrecy laws have also been criticized for being restrictive and limiting law enforcement agencies’ ability to identify and trace property subject to confiscation.

  • Confiscation framework lacks coverage of all predicate offenses
  • Financial secrecy laws restrict law enforcement agencies’ abilities

Freezing Mechanism and AML/CFT Measures

Experts noted that Armenia’s freezing mechanism under UNSCR 1267 and 1373 is deficient, with assets only frozen for a limited period before domestic proceedings must be initiated. Additionally, the report highlights areas where Armenia’s anti-money laundering and combating financing of terrorism (AML/CFT) preventive measures fall short.

  • Deficient freezing mechanism
  • Shortcomings in AML/CFT preventive measures

Recommendations and Response from Armenian Officials

The report calls for Armenia to revisit its response to UNSCRs 1267 and 1373, strengthen its seizure and confiscation framework, particularly with respect to predicate offenses. It also recommends that the country provide guidance to financial institutions to improve the implementation of AML/CFT measures.

In a statement, Armenian officials acknowledged the report’s findings and vowed to address the concerns raised.

“We take these recommendations seriously and will work to strengthen our anti-terrorism and AML/CFT frameworks to ensure Armenia’s compliance with international standards,” said an official spokesperson.