Armenia KYC, KYB & AML compliance checklist
A practical, source-linked checklist for implementing KYC, KYB and AML requirements in Armenia.
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- Last reviewed:
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- Version 1.0
Portable implementation guide
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11 control areas · 40 implementation checks
Last reviewed: 9 November 2026 · Version 1.0
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What does the Armenia compliance checklist cover?
The Armenia checklist translates primary KYC, KYB and AML rules into 11 control areas and 40 implementation checks. It identifies the relevant authorities, customer and beneficial-owner controls, reporting duties, recordkeeping expectations and evidence teams should retain.
Key regulatory facts
- Primary AML law
- Law on Combating Money Laundering and Terrorism Financing
- FIU
- Financial Monitoring Center of the Central Bank
- General mandatory report
- Transactions above AMD 20 million, subject to statutory exceptions
- Real-estate mandatory report
- Transactions above AMD 50 million
- Suspicious reporting
- Same business day; if impossible, by 12:00 next business day under applicable rules
- Beneficial owner
- 20% ownership/participation, other actual control, then management fallback
- Records
- At least 5 years
- FATF public lists
- Not listed at October 2026
Implementation detail
Armenia compliance requirements and actions
Open each control area to review the requirement, recommended implementation action, evidence to retain and the primary-source citation used by the research team.
01Scope, authorities, and licensingClassify the activity and competent supervisor before launch.3 items+
Determine whether each activity is a reporting-entity activity.
- Implementation action
- Map banking, credit, payment, securities, insurance, gambling, legal, accounting, real-estate, precious-metals, crypto-asset and other services to the current statutory perimeter; do not transfer one sector's rules to another.
- Evidence to retain
- Perimeter memo, service map and source register.
- Primary citation
- AML/CFT Law, Articles 3-4
Obtain every required licence or registration.
- Implementation action
- Confirm Central Bank or other competent-authority requirements before banking, payment, electronic-money, securities, insurance, lending, exchange, gambling or crypto-asset activity.
- Evidence to retain
- Licence matrix, approvals, registrations and conditions.
- Primary citation
- Applicable sector legislation and Central Bank regulations
Use FMC and the correct supervisor.
- Implementation action
- Maintain a dated authority map and the prescribed reporting form, online channel and escalation route for the entity type.
- Evidence to retain
- Authority map, portal access and acknowledgements.
- Primary citation
- AML/CFT Law, Articles 10-11; sector reporting rules
02Governance and risk assessmentControls must be risk-based, approved and tested.3 items+
Document institutional and customer ML/TF/PF risk assessments.
- Implementation action
- Assess customer, beneficial owner, geography, product, service, transaction, delivery-channel, technology and group risks; update after material change.
- Evidence to retain
- Methodology, assessments, approvals and remediation.
- Primary citation
- AML/CFT Law, Article 4 and applicable Central Bank regulation
Maintain compliant internal legal acts and an internal monitoring function.
- Implementation action
- Document governance, responsible staff, CDD, screening, monitoring, reporting, training, quality assurance and independent review proportionate to risk.
- Evidence to retain
- Internal acts, appointments, training and test reports.
- Primary citation
- AML/CFT Law, Articles 23-24
Keep controls aligned with current FMC indicators and sector instruments.
- Implementation action
- Map official high-risk criteria, typologies and reporting rules to scenarios and review them after legal, product or risk change.
- Evidence to retain
- Rule inventory, mapping and change log.
- Primary citation
- AML/CFT Law; current FMC/Central Bank guidance
03Natural-person identificationCDD applies before relationships and occasional transactions, subject to narrow exceptions.5 items+
Identify and verify the customer before service.
- Implementation action
- Obtain required identity information and verify it using reliable independent sources before establishing a relationship or occasional transaction, unless a documented statutory delayed-verification condition applies.
- Evidence to retain
- Identity record, verification result and provenance.
- Primary citation
- AML/CFT Law, Article 15
Establish purpose and intended nature and monitor the relationship.
- Implementation action
- Record expected activity, source information where required and a risk classification; keep identity and profile information current.
- Evidence to retain
- Customer profile, risk decision and refresh history.
- Primary citation
- AML/CFT Law, Article 16
Identify the authorised person and validate authority.
- Implementation action
- Verify identity and documentary or legal authority before accepting instructions on behalf of a customer.
- Evidence to retain
- Representative KYC, mandate and validation.
- Primary citation
- AML/CFT Law, Articles 3 and 16
Apply CDD regardless of amount when suspicion or doubt exists.
- Implementation action
- Refresh or complete CDD where information is doubtful, circumstances change or ML/TF suspicion arises; follow reporting and tipping-off controls.
- Evidence to retain
- Trigger log, refreshed evidence and decision.
- Primary citation
- AML/CFT Law, Articles 7, 15-16
Stop or refuse where required CDD cannot be completed.
- Implementation action
- Do not establish or continue the relationship or complete the transaction where the law prohibits service; assess whether an FMC report is required.
- Evidence to retain
- Failure record, decision and reporting assessment.
- Primary citation
- AML/CFT Law, Articles 16 and 27
04KYB and beneficial ownershipVerify existence, authority, ownership and actual control.4 items+
Verify the legal person or legal arrangement.
- Implementation action
- Obtain reliable registry and constitutional evidence, business purpose, management, representation and ownership/control structure.
- Evidence to retain
- Registry extract, governing documents and validation.
- Primary citation
- AML/CFT Law, Articles 15-16
Apply the statutory beneficial-owner cascade.
- Implementation action
- Identify natural persons with direct or indirect 20% or more voting ownership or capital participation, persons with other actual control, and the management fallback where no such natural person exists under the current law.
- Evidence to retain
- Ownership chart, control analysis, identities and fallback rationale.
- Primary citation
- AML/CFT Law, Article 3(1), beneficial-owner definition
Identify parties to trusts and similar arrangements.
- Implementation action
- Map settlor, trustee, protector where applicable, beneficiaries or class and every other ultimate controller under the current legal test.
- Evidence to retain
- Arrangement documents, role map and verification.
- Primary citation
- AML/CFT Law, Articles 3 and 16
Reconcile the beneficial-owner declaration with CDD.
- Implementation action
- Compare the State Registry declaration, customer evidence and reliable independent sources; investigate discrepancies rather than relying solely on the declaration.
- Evidence to retain
- Declaration, registry result, discrepancy log and resolution.
- Primary citation
- AML/CFT Law, Article 9; State Registration Law
05PEPs, EDD, and remote onboardingHigher-risk relationships need enhanced controls.3 items+
Identify PEPs, family members and close associates.
- Implementation action
- Screen customers and beneficial owners; obtain senior-management approval, establish source of wealth/funds and apply enhanced monitoring where required.
- Evidence to retain
- Screening, classification, approval and corroboration.
- Primary citation
- AML/CFT Law, Article 16; applicable Central Bank regulation
Apply enhanced due diligence for higher risk.
- Implementation action
- Obtain additional identity, ownership, purpose, source and transaction evidence and increase monitoring proportionately.
- Evidence to retain
- EDD checklist, evidence, approval and monitoring plan.
- Primary citation
- AML/CFT Law, Article 16
Control non-face-to-face onboarding.
- Implementation action
- Apply current FMC/Central Bank safeguards, authentication and risk mitigation; preserve liveness, fraud, exception and test evidence.
- Evidence to retain
- Method assessment, session record and tests.
- Primary citation
- AML/CFT Law, Article 16; current minimum-requirements regulation
06Monitoring and suspicious reportingDetection and reporting must meet event-specific timing.4 items+
Monitor relationships and document unusual activity analysis.
- Implementation action
- Detect inconsistent, complex, unusual, attempted and high-risk activity and document facts, rationale, source information and outcome.
- Evidence to retain
- Scenarios, alerts, analysis, tuning and governance.
- Primary citation
- AML/CFT Law, Articles 7 and 16
Report suspicious transactions, attempts and relationships to FMC.
- Implementation action
- Use the prescribed sector form and channel during the same business day or, where the applicable rule permits because same-day filing is impossible, by 12:00 of the next business day.
- Evidence to retain
- Suspicion timestamp, report, receipt and exception rationale.
- Primary citation
- AML/CFT Law, Articles 7-8; applicable sector reporting rule
Apply suspension or rejection controls where legally triggered.
- Implementation action
- Classify the transaction, apply the financial institution's statutory suspension authority or FMC instruction and preserve the exact timing and release basis.
- Evidence to retain
- Hold timestamp, report, instruction and release record.
- Primary citation
- AML/CFT Law, Articles 26-27
Prevent tipping off and protect reports.
- Implementation action
- Restrict access and communications concerning suspicious reports, analysis and FMC instructions except where law permits.
- Evidence to retain
- Access controls, communication review and training.
- Primary citation
- AML/CFT Law, Articles 5-6
07Mandatory reporting, wires, payments, and crypto-assetsThreshold reports and regulated products require separate controls.5 items+
Configure the general mandatory-reporting threshold.
- Implementation action
- Report transactions above AMD 20 million under the current rule, subject to the entity-specific scope and statutory or regulatory exceptions; do not treat this as a universal CDD threshold.
- Evidence to retain
- Threshold table, configurations, tests and reports.
- Primary citation
- AML/CFT Law, Article 5; FMC FAQ
Configure the real-estate reporting threshold separately.
- Implementation action
- Report covered real-estate transactions above AMD 50 million and apply the separate restriction on cash payment for the portion exceeding that threshold where relevant.
- Evidence to retain
- Legal classification, report and payment evidence.
- Primary citation
- AML/CFT Law, Articles 5 and 15; FMC FAQ
Carry and screen required wire-transfer information.
- Implementation action
- Apply current originator, beneficiary, intermediary, missing-data and screening controls for the institution's role.
- Evidence to retain
- Field matrix, samples, screening and repair queue.
- Primary citation
- AML/CFT Law, Article 20
Obtain payment-service authorization before launch.
- Implementation action
- Map each service to the Payment Systems and Payment Organizations Law; obtain the relevant Central Bank licence and electronic-money permission.
- Evidence to retain
- Product memo, licence result and conditions.
- Primary citation
- Payment Systems and Payment Organizations Law; Regulations 17/01-17/03
Apply the crypto-asset licensing transition accurately.
- Implementation action
- Classify the service under the Crypto-Assets Law; obtain Central Bank registration/licensing where currently required and document whether the statutory transition to 31 January 2027 applies.
- Evidence to retain
- Classification, licence/transition analysis and control tests.
- Primary citation
- Crypto-Assets Law; Central Bank crypto-asset provider guidance
08Targeted financial sanctionsUse live lists and freeze without prior notice.3 items+
Screen current UN and Armenian designations.
- Implementation action
- Screen customers, owners, representatives and transactions at onboarding, on list updates and throughout the relationship according to risk.
- Evidence to retain
- List version, logs and match decisions.
- Primary citation
- AML/CFT Law, Article 28
Freeze covered property immediately without prior notice.
- Implementation action
- Freeze property owned or controlled by listed terrorism or proliferation-related persons and property of persons acting for them; submit required information to FMC.
- Evidence to retain
- Designation, freeze timestamp, asset inventory and report.
- Primary citation
- AML/CFT Law, Article 28
Control permitted access, unfreezing and false positives.
- Implementation action
- Release or permit access only on documented legal authority and preserve every condition, decision and communication.
- Evidence to retain
- Authority decision, conditions and release record.
- Primary citation
- AML/CFT Law and implementing sanctions procedure
09Records and authority accessRecords must reconstruct decisions and transactions.3 items+
Retain CDD, account, correspondence and transaction records for at least five years.
- Implementation action
- Run the applicable period from relationship termination or transaction completion and preserve records in retrievable, evidentially usable form.
- Evidence to retain
- Retention schedule, archive and retrieval test.
- Primary citation
- AML/CFT Law, Article 22
Retain reports, analyses and non-reporting rationale.
- Implementation action
- Preserve suspicious and mandatory reports, supporting material and documented analysis of activity not ultimately reported for the statutory period.
- Evidence to retain
- Case archive, rationale and integrity controls.
- Primary citation
- AML/CFT Law, Articles 7-8 and 22
Produce records to FMC and supervisors lawfully.
- Implementation action
- Operate controlled retrieval, approval and production procedures that preserve confidentiality and evidence every authority request and response.
- Evidence to retain
- Request log, production, approval and receipt.
- Primary citation
- AML/CFT Law, Articles 10-11 and 22
10Privacy, biometrics, incidents, and transfersAML processing remains subject to privacy and security law.4 items+
Document lawful and proportionate processing.
- Implementation action
- Map purpose, legal basis, notice, minimization, accuracy, storage, rights and AML retention under the Personal Data Protection Law.
- Evidence to retain
- Data map, notices, legal-basis register and rights log.
- Primary citation
- Personal Data Protection Law
Protect biometric and special-category data.
- Implementation action
- Use biometric data only under an applicable condition and apply technical, organisational, access, accuracy, vendor and deletion controls.
- Evidence to retain
- Assessment, architecture, tests and approvals.
- Primary citation
- Personal Data Protection Law, including Article 19
Manage security incidents under current duties.
- Implementation action
- Maintain detection, containment, assessment, documentation and authority/data-subject communication workflows without inventing a universal deadline not supported by the applicable rule.
- Evidence to retain
- Incident chronology, assessment, notices and remediation.
- Primary citation
- Personal Data Protection Law
Control international transfers and processors.
- Implementation action
- Confirm adequacy, authorization, consent or other applicable transfer condition and bind processors before access or transfer.
- Evidence to retain
- Transfer map, legal assessment, safeguards and contracts.
- Primary citation
- Personal Data Protection Law
11Practical evidence packsEvidence must reconstruct decisions end to end.3 items+
Maintain an onboarding pack.
- Implementation action
- Bundle identity, authority, KYB, beneficial ownership, PEP, sanctions, purpose, risk, privacy and approvals.
- Evidence to retain
- Complete sample and retrieval result.
- Primary citation
- Operational control supporting AML/CFT Law, Articles 15-16
Maintain reporting and sanctions case packs.
- Implementation action
- Link trigger, classification, decision time, report, receipt, suspension or freeze, confidentiality and authority communications.
- Evidence to retain
- Case pack, timeline and access record.
- Primary citation
- AML/CFT Law, Articles 7-8 and 26-28
Maintain a launch and legal-change pack.
- Implementation action
- Record perimeter, licences, thresholds, reporting, sanctions, privacy, vendors, source versions and control tests.
- Evidence to retain
- Signed pack, source register and approvals.
- Primary citation
- Official sources listed below
Primary-source register
15 sources used for this checklist
Use these links to verify the underlying legislation, regulator guidance, reporting procedures and international status statements.
- AML/CFT Law - current English working translationCentral Bank of Armenia · Primary legislation - official non-binding translation
- AML/CFT Law - current official textARLIS · Primary legislation - official repository
- Financial Monitoring CenterCentral Bank of Armenia · Official FIU portal
- FMC reporting and beneficial-owner FAQCentral Bank of Armenia · Official implementation guidance
- Financial-institution AML/CFT instrumentsCentral Bank of Armenia · Official regulatory index
- State Registration LawARLIS · Primary legislation - official registry framework
- Beneficial ownership declaration serviceNational Services Gateway · Official registry service guidance
- Payment organizations licensing guideCentral Bank of Armenia · Official licensing guidance
- Crypto-asset service providersCentral Bank of Armenia · Official licensing and transition guidance
- Personal Data Protection LawARLIS · Primary legislation - official repository
- MONEYVAL Mutual Evaluation of Armenia 2026FATF / MONEYVAL · Authoritative mutual evaluation
- FATF increased-monitoring statement - October 2026FATF · Authoritative current public-list status
- FATF call-for-action statement - October 2026FATF · Authoritative current public-list status
- Law on the Flag of the Republic of ArmeniaARLIS · Primary legislation - official flag-use rules
- Law on AdvertisingARLIS · Primary legislation - respectful state-symbol use
Direct answers
Armenia KYC, KYB and AML questions
Who receives AML reports?+
The Financial Monitoring Center of the Central Bank of Armenia.
When must suspicion be reported?+
Under the applicable sector rule, during the same business day or, where same-day filing is impossible, by 12:00 of the next business day.
What is the general mandatory-reporting threshold?+
Transactions above AMD 20 million, subject to the reporting entity's scope and current statutory or regulatory exceptions.
What is the real-estate threshold?+
Covered real-estate transactions above AMD 50 million; the law also restricts cash payment for the portion exceeding that threshold.
How is a beneficial owner identified?+
Apply the 20% ownership/participation and other actual-control tests, then the current management fallback where no natural person meets those tests.
How long are AML records retained?+
At least five years under Article 22, subject to lawful longer holds or sector requirements.
Do payment and crypto-asset providers need authorization?+
Payment organizations require applicable Central Bank licensing. Crypto-asset services are regulated and licensed, with a statutory transition for qualifying pre-existing providers through 31 January 2027.
Is Armenia on a FATF public list?+
No at the October 2026 statements. The 2026 MONEYVAL mutual evaluation must still inform risk assessment; absence from a public list is not a low-risk determination.
Research and review method
VOVE ID Compliance Research maps the regulatory perimeter, translates obligations into operational controls, links each material claim to a source and records the date and version of every review.
General information, not legal advice. Reviewed 9 November 2026. Confirm the controlling Armenian text, current FMC reporting forms and channels, sector rules, live sanctions lists, beneficial-owner filing practice, privacy requirements and licensing conditions with the competent authority and qualified Armenian counsel.