Armenia is in 2025 at the very point of a long-term struggle to support the anti-money laundering (AML) and counter-terrorism financing (CTF) mechanisms. This change is closely associated with its interaction with the Committee of Experts on the Evaluation of Anti-Money laundering measures and the Financing of Terrorism (MONEYVAL) of the council of Europe. MONEYVAL conducted its sixth round of mutual evaluation with an assessment team of the country visiting Armenia to assess how well the country is able to effectively implement the AML/CFT framework, both in terms of legislation and institutional regulation and in terms of application and cooperation with other agencies.
The fact that Armenia is in a strategic location between Europe, Middle East and Asia brings both opportunities and threats. This nation has moderate exposure to financial crime especially in bank, real estate and non financial sectors like casinos and luxury goods. The reforms based on the ideas of MONEYVAL are essential thus acting as the means of modernisation of the regulation system in Armenia and its adaptation to the new worldwide standards.
The institutional framework underpinning Armenia’s anti-money laundering efforts
The AML/CFT framework in Armenia is based on an interconnected system governed at the center by the Central Bank of Armenia (CBA), and its respective agencies. The framework is created so as to promote transparency, compliance and accountability throughout the financial system.
Central Bank’s supervisory and enforcement role
The Central Bank of Armenia is still in the center of financial oversight and AML implementation. The CBA provides financial intelligence through its financial monitoring center (FMC), which is the national financial intelligence unit, insofar as it tracks reports of suspicious transactions and shares intelligence information with law enforcement. In 2025, the FMC has increased its capacity, whereby it relies on sophisticated data analytics and cross-border intelligence instruments to track illegal financial flows at a greater rate.
Continued law changes have provided the Central Bank with more sanctions prerogative over financial institutions that do not comply and extended the scope of AML to digital finance providers and non-banking intermediaries. These actions are in line with the previous suggestions of MONEYVAL to mitigate the weakness in the regulation of fintech operators and listed non-financial businesses and professions (DNFBPs).
Interagency coordination and national risk frameworks
The interdepartmental approach is one of the most noticeable improvements as identified by the assessment of MONEYVAL in the case of Armenia. Ministries, judicial representatives, law enforcement agencies, and participants of the private sector are now united by the Interdepartmental Commission, led by the CBA, to facilitate AML/CTF actions. This is to create uniformity among the institutions and provide real time response to rising risks.
The National Risk Assessment (NRA) in Armenia is still part of its AML structure. The new estimate, which is based on the 2014 baseline that estimated that illicit proceeds amounted to 42 billion AMD (some 106 million dollars), incorporates both financial, law enforcement, and private sector sources of information. It is an ongoing process that has developed under the guidance of MONEYVAL and aims to take more action in regards to risk-based approaches that put systemic blind spots at bay.
MONEYVAL’s evaluation and Armenia’s progress in 2025
The sixth round assessment by MONEYVAL has offered an overall analysis of the AML/CFT performance of Armenia with some positive achievements and points of further improvement.
Legislative and regulatory advances
As of 2023-2025, there were significant legislative changes in Armenia that were undertaken based on the recommendations of the MONEYVAL and FATF. These involve the imposition of stronger customer due diligence, the strengthening of the management of politically exposed persons (PEPs) and required record keeping to trace the complex financial transactions. The reforms also create proper procedures of freezing and seizure of assets that are connected to money laundering or financing of terrorism.
The initial conclusions of MONEYVAL, which have been published in the middle of 2025 are praising Armenia because it has managed to overcome past gaps in beneficial ownership disclosure and it has enhanced cooperation across the borders. Nevertheless, the report also emphasizes the necessity of stronger adoption of asset recovery solutions, as well as constant observation of the new technological developments, including cryptocurrencies, which are a new threat to the AML arena.
Stakeholder engagement and international collaboration
The mission of evaluation in Yerevan conducted by MONEYVAL included consultations with the top officials of the Central Bank, FMC, Ministry of Justice, and the law enforcement agencies, the representatives of commercial banks and professional associations. Such an inclusive process shows that Armenia is keen on transparency and can be subjected to external scrutiny.
According to the description of the evaluation by Central Bank Governor Martin Galstyan, it constituted a reiteration of the long-standing relationship that has existed between Armenia and MONEYVAL and the intention to promote integrity in the financial system. This is the focus of the government on instilling a compliance culture in both the government and the private sector as demonstrated by his statement.
The Co-operation with the European Union and the United Nations Office on Drugs and Crime (UNODC) has also increased whereby the global best practices and global technical assistance programs are being incorporated in order to enhance investigation and prosecution powers.
The strategic significance of MONEYVAL evaluations for Armenia and beyond
The role of MONEYVAL is not just compliance but a crucial factor in the promotion of the economic image and financial inclusion of Armenia into the world arena.
Enhancing financial sector integrity and economic stability
The reputations of Armenia acquired through MONEYVAL assessments help it to deal with the investment of foreign capital and to preserve correspondent banking. The country minimizes reputational risks by ensuring that its AML/CTF systems comply with the international standards and show its willingness to be involved in transparent financial transactions.
The reforms help in the economic stability of the economy in the long run. Restricting entry points to illegal financial flows does not only ensure that the financial system is not abused but also assists in securing tax money and enhancing citizen confidence towards financial institutions. Technical recommendations issued by MONEYVAL have thus been mixed with the overall economic and governance reform agenda in Armenia.
Regional cooperation and cross-border challenges
The AML activities of Armenia are influenced by the country’s geopolitics too. The country is placed among those jurisdictions which have been characterized with different degrees of financial transparency; it is at risk of cross-border smuggling, money laundering through trade, and the shadow economy. MONEYVAL has been used as a regulatory platform and diplomatic platform which promotes regional cooperation with its neighboring states by promoting joint training, information sharing, and collaboration on asset recovery.
The growing pressure on the idea of asset repatriation backed by international frameworks and bilateral agreements highlights the role that Armenia plays in the international drive against financial secrecy. This process is reinforced by the fact that MONEYVAL has helped in technical dialogue which has made the country compliant with the FATF Recommendation 38 on mutual legal assistance.
Armenia’s continuing journey toward stronger financial governance
The 2025 MONEYVAL assessment confirms that the current level of progress of AML/CFT in Armenia is based on structural reforms and long-term political determination. Although significant progress has been noted especially on risk assessment, institutional coordination and compliance monitoring issues, challenges of enforcement as well as compliance by the private sector still abound.
It is imperative that banks and other non-financial institutions should be keen on emerging risks. The ever-changing landscape of world finance that is informed by digital assets, offshore organizations, and international commerce necessitates adaptation. The continuous observation of Armenia by MONEYVAL will gauge its ability to sustain the reform process and implement its bold policies.
A test of endurance and international alignment
The partnership of Armenia with MONEYVAL in 2025 is an example of how international assessment systems can be used as a driver of domestic change. The process enhances the capacity of the institution, boosts trust of the population, and incorporates Armenia in the international financial governance system.
Yet the real measure of success lies not merely in meeting technical benchmarks, but in sustaining a culture of accountability and integrity that transcends compliance checklists. As Armenia continues refining its AML/CTF systems, its experience offers valuable lessons for other small and medium-sized economies navigating similar geopolitical and economic constraints.
The evolving relationship between MONEYVAL and Armenia underscores a central question for 2025 and beyond: how can smaller states balance sovereignty with international oversight while ensuring resilience against financial crime in an increasingly interconnected world?