Armenia Compliance Report

Generated 2026-09-22

Framework In Development

Regulatory Overview

Regulatory Status: Active legislative/regulatory process underway
Key Regulator(s): Central Bank of Armenia, Investigative Committee of Armenia
Primary Legislation: Law on Payment and Settlement Systems and Payment Organizations (Armenian): http, Law on Combating Money Laundering and Terrorist Financing, Armenia's AML/CFT law has been significantly amended (e.g., in 2025) to expand i, European Union Directive 2015/849, Law No. 108-N on Virtual Asset Services, 15 March 2021, Armenian Value Added Tax Law, Law No. 93-N, 5 July 2020, Income Tax Law, Law No. 110-N, 10 December 2018
Travel Rule: Not adopted — Threshold: ,
Tax Reporting: Tax Resident: Individuals present in Armenia for 183 days or more within a 12‑month period.. Non‑Resident: Earns income from Armenian sources without meeting residency criteria; taxed at the flat rate of 12 % on that specific income.

Key Facts

aml Law of the Republic of Armenia on Combating Money Laundering and Terrorist Financing (ՀՀ օրենքը «Փողերի լվացման և ահաբեկչության ֆինանսավորման դեմ պայքարի մասին»): This is the primary legislation. It mandates financial institutions, including VASPs, to implement robust AML/CFT measures, which inherently include sanctions screening. Specifics: This law, originally adopted in 2004, has undergone several amendments. Crucially, amendments in 2022 specifically brought virtual asset service providers (VASPs) within the scope of obligated entities. This means VASPs are now subject to the same AML/CFT obligations as traditional financial institutions. These amendments align Armenia with FATF Recommendation 15 on new technologies, which requires countries to regulate and supervise VASPs for AML/CFT purposes. The Travel Rule application to VASPs has been clarified as distinct from the core Recommendation 15 VASP regulatory requirements. Regulations and Decisions of the Central Bank of Armenia (CBA): The CBA issues specific rules and guidelines that obligated entities, including VASPs, must follow to comply with the AML/CFT Law. These provide practical guidance on implementing customer due diligence, suspicious transaction reporting, and record-keeping. Under Armenia’s Law on Crypto-Assets (HO-159-N), the Central Bank of Armenia (CBA) issues mandatory licensing and AML/CFT requirements for VASPs/CASPs, including comprehensive internal rules and procedures, moving beyond mere sub-legal acts to statutory obligations. Role: The CBA is the main financial regulator in Armenia and is responsible for licensing, supervision, and enforcement of AML/CFT requirements for financial institutions, and now, VASPs. It sets the regulatory framework and conducts oversight to ensure compliance. The Financial Monitoring Center of the Central Bank of Armenia now performs comprehensive regulatory, supervisory, and consumer rights protection functions within Armenia’s financial system. Role: The FMC acts as Armenia's Financial Intelligence Unit (FIU). It is responsible for receiving, analyzing, and disseminating suspicious transaction reports (STRs) to law enforcement agencies for investigation. Obligated entities, including VASPs, must report all suspicious activities to the FMC.
custody No specific "crypto custody license" exists. Armenia does not currently have a dedicated licensing regime for cryptocurrency custodians. In Armenia, Virtual Asset Custody Providers (VACPs) are now subject to specific licensing and operational/security requirements under the updated Law on Combating Money Laundering and Terrorism Financing, making the original statement about the absence of a custody license inaccurate. Armenia has specific laws and regulations, including the Law on Crypto-Assets (adopted May 29, 2025), that regulate crypto-asset service providers (including custodians) licensed by the Central Bank, with requirements for AML, transaction monitoring, record retention, and client protections, though explicit client asset segregation mandates are not detailed in the provided evidence. In traditional finance, such rules are standard to protect client funds in case of bankruptcy or mismanagement. The absence of specific crypto regulations means these protections do not explicitly extend to digital assets held by crypto service providers. Armenia imposes licensing and capital requirements for cryptocurrency custodians, but no mandatory insurance or bonding. This means that clients would likely have no recourse through a regulatory-mandated insurance scheme in the event of theft, loss, or insolvency of a crypto custodian. No specific mandates. There are no specific regulatory mandates or technical requirements for cryptocurrency custodians regarding the use of cold storage (offline storage) for digital assets. Custodians might implement cold storage as a best practice for security, but it is not a legal obligation.
enforcement Entity Targeted: Individuals and organized criminal groups involved in establishing and operating large-scale fraudulent cryptocurrency investment schemes, often promising high returns from "mining farms" or fake trading platforms. Violation Type: Large-scale fraud (often under Article 178 of the Criminal Code of Armenia), money laundering (Article 190), illegal entrepreneurship (Article 188), and sometimes other related criminal offenses. Outcome: Multiple arrests of individuals involved, ongoing criminal proceedings, freezing and seizure of assets, and international cooperation to track down perpetrators and recover funds. As these are complex criminal cases, final verdicts and sentences can take significant time. Armenian authorities are conducting mass raids and investigating nearly 40 individuals for money laundering, indicating that the situation has progressed beyond the initial multiple arrests and asset freezes described in the claim.
general Enhance AML/KYC Protocols: Implement multi‑layered identity verification and real‑time transaction monitoring to mitigate illicit activity risks. Engage with Regulatory Authorities: Regularly consult the NCRPS for updates on licensing requirements and compliance expectations. Prepare for Stablecoin Regulation: Proactively assess potential regulatory impacts of stablecoins and develop compliant issuance frameworks. PwC Tax Summary: Taxes on Personal Income in Armenia U.S. Expat Tax Guide: US Expat Taxes for Americans Living in Armenia Wikipedia Overview: Taxation in Armenia Freelance Tax Guide (Mellow): Freelance and Taxes: Armenia EU AML Directive Implementation: Anti-money laundering and countering the financing of terrorism at ...
licensing Regulator/Enforcement Body: Investigative Committee of Armenia, Prosecutor General's Office of Armenia, often in cooperation with law enforcement agencies from other countries (e.g., Russia, Georgia, US). Direct Fines: Not a simple "penalty amount" like a regulatory fine. These are criminal cases. Penalties typically involve arrests, pre-trial detention, asset freezes/seizures (often multi-million dollar amounts in various currencies and cryptocurrencies), and eventual criminal conviction leading to significant prison sentences and restitution orders. Examples of Seized Assets: Reports mention seizures of large sums in fiat currency, cryptocurrency, real estate, and luxury vehicles. For instance, some cases involved alleged damages amounting to tens or hundreds of millions of USD. Ongoing investigations and arrests in darknet- and drug‑trafficking cases have been reported continuously over multiple years, with prominent cases in late 2022 and early 2023 as well as in subsequent years, including 2024 and beyond. News.am (Armenian news agency) - October 2022: Report on an alleged crypto fraud scheme involving Russian citizens in Armenia. A criminal case under Articles 188 and 190 of the RA Criminal Code related to a crypto company was initiated, but the subsequent Armenian Court of Appeal ruling declaring the detention of businessman Samvel Karapetyan illegal indicates that the legal basis or enforcement of such detentions is not consistently upheld, undermining the characterization of a sustained proactive approach. Arka.am (Armenian news agency) - January 2023: Report on a criminal case involving large-scale fraud through a fake crypto investment company. This article discusses specific crypto fraud cases, but the cited enforcement actions are being pursued by U.S. federal and state authorities, not the Armenian Investigative Committee.
securities Central Bank of Armenia (CBA): The primary authority overseeing financial markets and monetary policy in Armenia. Website: https://www.cba.am Armenia Stock Exchange (AMX): Operates under CBA regulation, facilitating trading of traditional securities including stocks and bonds. Website: https://amx.am Law on the Central Bank of Armenia: Provides the legal basis for financial regulation, including oversight of monetary instruments and capital markets. Official Gazette Reference: RA Legislative Assembly, Law No. 28-N dated March 12, 2004. Law on Securities Markets: Governs the issuance, trading, and settlement of securities within Armenia. Official Gazette Reference: RA Legislative Assembly, Law No. 112-XII dated November 26, 2015. Armenia is a member of the OECD (Organisation for Economic Co-operation and Development) and participates in FATF (Financial Action Task Force) recommendations, indicating alignment with global AML/CFT standards. OECD Membership FATF Status Entities engaged in the issuance or trading of securities must obtain authorization from the CBA. Armenia enacted a Law 'On Crypto-Assets' (HO-159-N) in May 2024, establishing a licensing framework for cryptocurrency exchanges and other crypto-asset service providers, effective as of 2025. Trading, issuing, and settlement of traditional securities on AMX.
stablecoin Certain USD-backed 'Covered Stablecoins' are not classified as securities by SEC staff guidance, but no comprehensive formal classification exists for all stablecoins. Cryptocurrencies, including what would be considered stablecoins, are generally viewed by the CBA as high-risk, speculative assets and are not classified as e-money, payment tokens, or securities under existing financial legislation. They are also not recognized as legal tender. No specific reserve requirements for stablecoin issuers currently exist, as there is no framework regulating such issuance. No specific licensing regime for stablecoin issuers exists in Armenia. Companies dealing with virtual assets generally operate in an unregulated space from a financial services perspective, though they must comply with general business laws (e.g., company registration, tax laws). No specific legal framework or guarantees regarding redemption rights for stablecoin holders is in place. Redemption would likely depend on the terms and conditions set by the issuer, without the backing of specific Armenian financial regulations. No specific rules or regulations exist for algorithmic stablecoins, nor for any other type of stablecoin.
status The Armenian regulatory environment for cryptocurrencies and digital assets is currently evolving, with a focus on compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations. Licensing requirements for crypto-related businesses are being established, but specific guidelines are still under development. As of October 2023, no entities have been officially licensed for cryptocurrency services in Armenia. Tax treatment of cryptocurrency transactions in Armenia remains unclear, necessitating further clarification from tax authorities. Armenia is a member of the Financial Action Task Force (FATF) and adheres to its recommendations for AML/CFT measures. Armenia’s legal framework for digital assets is primarily guided by the Financial Intelligence Unit (FIU) and the National Bank of Armenia (NBA). The country has not yet enacted specific legislation targeting cryptocurrencies directly, leading to a reliance on existing financial regulations. Proposed amendments aim to incorporate virtual currencies within broader money transmission and securities laws. Entities engaging in cryptocurrency exchanges or wallet services may require licensing under the "Licensing Requirements for Professional Services" outlined by the Ministry of Finance.
tax Tax Resident: Individuals present in Armenia for 183 days or more within a 12‑month period. Non‑Resident: Earns income from Armenian sources without meeting residency criteria; taxed at the flat rate of 12 % on that specific income.
travel rule Armenia has been developing a legislative framework for virtual assets, with a draft Law on Virtual Assets under consideration, aiming to establish a defined category of virtual asset service providers [Moneyval 2022 MER, p. 176, 183]. However, this law has not yet been adopted by the National Assembly, contradicting claims from some secondary sources vlolawfirm.com. The existing primary legislation governing financial conduct and combating illicit finance is the Law of the Republic of Armenia HO-49-N "On Combating Money Laundering and Terrorism Financing," adopted on June 1, 2007, and subsequently amended [Arlis.am - Law HO-49-N, CBA.am - AML/CFT Law]. Virtual asset activities are currently subject to the general provisions of this law, particularly if they are deemed to perform financial activities that fall under the existing definition of financial institutions [Moneyval 2022 MER, p. 182-183]. The Armenian government has acknowledged the recommendations from the Financial Action Task Force (FATF) concerning virtual assets and VASPs [Moneyval 2022 MER, p. 176]. The draft framework aims to align with FATF standards, including the incorporation of Recommendation 16 (the Travel Rule) for crypto transfers vlolawfirm.com. Armenia's FATF/Moneyval Status: Armenia is a member of Moneyval, the Council of Europe's anti-money laundering body. Its 5th Round Mutual Evaluation Report (MER) was adopted in December 2022. Key findings relevant to virtual assets and VASPs include: Armenia is rated "Partially Compliant" for FATF Recommendation 15 (New Technologies) [Moneyval 2022 MER, p. 176]. The MER explicitly states: "Armenia does not have specific regulations for virtual assets (VAs) or virtual asset service providers (VASPs)." [Moneyval 2022 MER, p. 176]. It further notes: "The draft Law on Virtual Assets is under development, which aims to regulate the sphere of VAs and VASPs. Therefore, the immediate actions on VASPs have not yet been taken." [Moneyval 2022 MER, p. 183]. While VASPs are not explicitly defined as reporting entities, they are "covered by the general definition of financial institutions in the AML/CFT Law, if they perform a financial activity, such as currency exchange or money or value transfer, in which case they would be subject to AML/CFT obligations related to customer due diligence (CDD), record-keeping, and suspicious transaction reporting (STR)" [Moneyval 2022 MER, p. 182-183].

Sources

This report is AI-generated from publicly available regulatory sources. Last updated: 2026-09-06. View full profile