YEREVAN, August 17. /ARКА/. As of August 12, 2026, new regulations for banks regarding the management of risks associated with evading international sanctions have been implemented in Armenia.
The amendments to the regulation titled “Minimum Conditions for Implementing Internal Control in Banks” were sanctioned by Resolution No. 21-N from the Board of the Central Bank of Armenia on January 30, 2026. This document was officially released on February 11 and became effective six months later, on August 12, 2026.
Under the new regulations, banks are required to establish risk-based internal control systems and procedures to identify, assess, suspend, or reject transactions that may risk circumventing international sanctions.
As part of these controls, banks must perform due diligence not only on their clients but also on the clients’ counterparties, the bank’s own counterparties, and all parties involved in the transactions. Furthermore, banks are obligated to evaluate risks related to clients, the geographical aspects of transactions, the services and transactions offered, counterparties, intermediaries, and service delivery chains.
Monitoring must specifically consider geographic factors linked to sanctions regimes, the origin of goods, services, software, and technology, as well as information regarding individuals and organizations that are subject to or associated with international sanctions, and details about financial institutions facing sanctions restrictions. The currency and location of transactions are also under scrutiny.
Transaction data must be monitored prior to execution and confirmation. Should there be any changes to sanctions lists or updates to client information, the bank is required to re-evaluate no later than one business day following the relevant change.
The document does not single out any specific country or sanctions regime. International sanctions are defined in the document as economic, financial, trade, and other restrictive measures imposed by states or international organizations.
A bank must consider those sanctions regimes that, given the nature of its activities, may directly or indirectly affect its operations. The amendments supplemented Bank Regulation 4 with a new Chapter 15.1, “Managing the Risk of Circumvention of International Sanctions.” They also stipulate the appointment of a person responsible for managing this risk, regular assessment of the effectiveness of control systems, and the provision of relevant reports to the bank’s board and executive body.-0-
