Armenia – Know Your Customer (KYC) Rules

 

 

Armenia is not a regional financial center and is not believed to be at major risk for money laundering and terrorist financing. However, governmental corruption, an organized crime presence and a large shadow economy make the country vulnerable. The major sources of laundered proceeds stem from theft, tax evasion and fraudulent financial activity, particularly transactions with forged credit cards. Money laundering in Armenia generally takes place through the banking system, through informal remittances from Armenians living abroad, and through high-value transactions such as real estate purchases.

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KNOW-YOUR-CUSTOMER (KYC) RULES:

 

Enhanced due diligence procedures for PEPs:

 

PEP is an abbreviation for Politically Exposed Person, a term that describes a person who has been entrusted with a prominent public function, or an individual who is closely related to such a person. The terms PEP, Politically Exposed Person and Senior Foreign Political Figure are often used interchangeably

    • Foreign PEP: YES
    • Domestic PEP: NO

Armenia – KYC covered entities

 

The following is a list of Know Your Customer entities covered by Armenian Law:

    • Banks, credit bureaus, and exchange houses
    • Real estate agents
    • Notaries, lawyers, accountants, and auditors
    • Dealers in artwork and precious metals and stones
    • Organizers of auctions
    • Casinos, lotteries, and internet gaming
    • Trust and company service providers
    • the State Cadaster and the State Registry

Armenia- Suspicious Transaction Reporting (STR) Requirements:

 

Number of STRs received and time frame: 162 from January to November 2011

Number of CTRs received and time frame: 122,416 from January to November 2011

The following is a list of STR covered entities covered by Armenian Law:

    • Banks, credit bureaus, and exchange houses
    • Real estate agents
    • Notaries, lawyers, accountants, and auditors
    • Dealers in artwork and precious metals and stones
    • Organizers of auctions
    • Casinos, lotteries, and internet gaming
    • Trust and company service providers
    • the State Cadaster and the State Registry

MONEY LAUNDERING CRIMINAL PROSECUTIONS/CONVICTIONS:

 

Prosecutions: Four from January to November 2011
Convictions: Two from January to November 2011

 

ENFORCEMENT AND IMPLEMENTATION ISSUES AND COMMENTS:

Armenia followed its first successful money laundering prosecutions in 2009 with additional prosecutions in 2010 and 2011.
There have been no known cases of terrorist financing in Armenia.
Armenia should criminalize tipping off.