Armenia's financial regulators have significantly tightened the country's AML regime. Companies operating in or through Armenian financial channels now face stricter obligations. Failure to adapt quickly carries real consequences: account restrictions, suspended transactions, and potential regulatory sanctions.
Armenia's updated anti-money laundering rules, effective from mid-2025, introduce reinforced know-your-customer (KYC) requirements and mandatory beneficial owner disclosure for all regulated entities. Companies holding bank accounts or credit facilities in Armenia must bring their documentation into compliance within prescribed deadlines. International businesses with correspondent banking relationships routed through Armenia are directly affected.
This alert explains what has changed, which companies are in scope, and what steps to take before the compliance deadline passes.
What changed – the regulatory update and effective date
Armenia's anti-money laundering legislation was amended to align the country's regime more closely with international standards set by the Financial Action Task Force (FATF). The amendments entered into force in mid-2025 and are being phased into operational practice by regulated entities through the second half of 2025 and into early 2026.
The core changes affect three areas. First, the threshold for mandatory beneficial owner identification has been lowered. Where ownership or control exceeds a reduced percentage trigger, the entity must register and verify the ultimate beneficial owner with the relevant supervisory authority. Second, ongoing customer due diligence obligations have been strengthened. Banks, payment institutions, and other reporting entities must now re-verify existing clients whose files were assembled under the prior, less demanding standards. Third, the definition of a karavarum kazmakerpov (politically exposed person) under Armenian financial regulation has been expanded, bringing a broader category of individuals within the enhanced due diligence perimeter.
Armenian banking legislation now requires that bank account opening procedures include documentary confirmation of source of funds for corporate clients above a defined transaction threshold. This applies at onboarding and, in the case of existing accounts, on a rolling review cycle. Institutions that fail to collect or verify the required documentation face regulatory enforcement by the Hayastani Hanrapetutyan Kentronakan Bank (Central Bank of the Republic of Armenia). This is the primary supervisory authority for AML compliance across the financial sector.
A further change affects correspondent banking relationships. Armenian banks maintaining correspondent accounts with foreign institutions must apply enhanced due diligence to those relationships. Foreign banks routing transactions through Armenian correspondents should expect requests for additional documentation and may encounter transaction delays during the adjustment period.
For companies relying on Armenian capital markets infrastructure, the updated rules also extend reporting obligations to securities intermediaries and custodians. Details on how these changes interact with investment activity are covered in our analysis of capital markets regulation in Armenia.
Who is affected – business categories and threshold criteria
The updated AML rules apply to a broad set of reporting entities. The following categories are directly in scope:
- Banks and credit organisations licensed by the Central Bank of Armenia
- Payment service providers and electronic money institutions operating in Armenia
- Securities brokers, investment firms, and custodians registered with Armenian financial authorities
- Insurance companies engaged in life and investment-linked products
- Legal and accounting professionals providing company formation, trust, or asset management services to clients in Armenia
International companies are affected in several ways. Any foreign entity holding a bank account or a credit facility with an Armenian-licensed institution must supply updated KYC documentation. This includes companies that opened accounts under prior rules and have not been asked to re-verify – those re-verification requests are now arriving, and non-responsive clients risk account suspension.
The beneficial owner disclosure requirement applies when a natural person directly or indirectly holds a controlling interest in a legal entity that is a customer of a regulated institution. The threshold sits at a level consistent with FATF recommendations. Where ownership is held through multi-layer holding structures – a common arrangement for international investors using Armenian entities – each layer must be documented back to the ultimate individual.
Foreign companies using Armenia as a transit jurisdiction for commercial payments or as a base for regional operations in the CIS are particularly exposed. Correspondent banking restrictions mean that a transaction chain involving an Armenian institution may be delayed or queried even if the Armenian entity is not the direct obligated party.
To receive an expert assessment of your AML exposure in Armenia, contact us at info@ferrazwhitmore.com.
What to do now – immediate actions and timeline
The compliance window is narrow. Regulated institutions are expected to complete re-verification of existing client files by early 2026. Companies that delay risk disruption to banking operations at a critical point. The following actions should be prioritised immediately.
Audit your beneficial ownership documentation. Identify every Armenian-licensed account or facility your group holds. Confirm whether the beneficial owner registered with the institution reflects the current ultimate natural person. Where group restructuring has occurred since the account was opened, the registered beneficial owner may be outdated.
Prepare source-of-funds documentation. For corporate accounts subject to transaction thresholds, assemble documentary evidence of the origin of funds. This typically means audited financial statements, board resolutions authorising transactions, and contracts underpinning the relevant payment flows.
Review correspondent banking chains. If your company routes payments through Armenian banks as part of a wider CIS payment infrastructure, map those chains now. Identify which correspondent relationships are subject to enhanced due diligence and ensure your counterpart banks have received adequate information about your entity.
Update internal KYC files. If your company is itself a reporting entity in Armenia. for example. A locally licensed financial intermediary. your internal KYC procedures must be updated to reflect the new thresholds and the expanded definition of politically exposed persons.
Engage local counsel promptly. The Central Bank of Armenia has issued supervisory guidance that supplements the legislative text. Navigating that guidance alongside the core amendments requires familiarity with Armenian banking regulation. Engaging a lawyer in Armenia with AML expertise early reduces the risk of procedural gaps in your compliance file.
Companies with parallel operations in Russia facing related AML developments should also review our alert on 2025 AML updates in Russia, as the two regimes share certain FATF-alignment characteristics while differing substantially in enforcement approach.
Detailed guidance on structuring compliant banking relationships in Armenia is available from our banking and finance practice in Armenia.
About Ferraz & Whitmore
Ferraz & Whitmore is an international law firm based in Lisbon, advising business clients across 46 jurisdictions. Our team combines Portuguese civil law expertise with English common law tradition to deliver cross-border legal solutions in banking, finance, and AML compliance. We advise international companies, financial institutions, and in-house legal teams on regulatory obligations in Armenia and across CIS markets. As an international law firm in Armenia's regional legal environment, we support clients in meeting AML, KYC, and beneficial owner requirements under Armenian financial legislation. Our practitioners have experience advising on compliance matters before the Central Bank of Armenia and in structuring correspondent banking and credit facility arrangements for cross-border clients. For a preliminary review of your AML compliance position in Armenia, contact us at info@ferrazwhitmore.com.
Disclaimer: This publication is provided for informational purposes only and does not constitute legal advice. The information herein should not be relied upon as a substitute for professional legal counsel tailored to your specific circumstances. Ferraz & Whitmore assumes no liability for actions taken or not taken based on the contents of this material. For advice regarding your particular situation, please contact info@ferrazwhitmore.com.
Published: April 24, 2026
Author: Anna Chen – Senior Associate, Asia-Pacific, Middle East & CIS
Anna Chen is a Senior Associate at Ferraz & Whitmore focusing on cross-border transactions, market entry, and dispute resolution across Asia-Pacific, Middle Eastern, and CIS jurisdictions. She supports international clients in navigating regulatory and commercial challenges in high-growth and emerging markets.