NEW REQUIREMENTS FOR MANAGING INTERNATIONAL SANCTIONS CIRCUMVENTION RISKS
On August 11, amendments to a number of regulatory acts of the Central Bank came into force, which establish requirements to have internal control systems designed to manage international sactions risks for Payment and Settlement Companies, Insurance Companies, Banks, Investment Companies, Central Depository, and Investment Fund Managers.
The new regime operates alongside the existing AML/CFT framework and covers economic, financial and trade restrictive measures applied by international organisations and states, excluding the lists established under the Law on Combating Money Laundering and Terrorism Financing.
The financial organizations listed above must appoint a responsible person who is already registered with the Central Bank as a manager, develop a methodology and procedures for managing sanctions-evasion risks, conduct a risk assessment at least annually, and submit reports on a semi-annual basis.
More:
https://www.cba.am/hy/Board-decisions/9539/
https://www.cba.am/hy/Board-decisions/9561/
https://www.cba.am/hy/Chairman's-decisions/9557/
https://www.cba.am/hy/Board-decisions/9537/
https://www.cba.am/hy/Board-decisions/9559/
https://www.cba.am/hy/Board-decisions/9541/
NEW REGULATIONS FOR CRYPTO-ASSET SERVICE PROVIDERS
On 11 August 2026 the Central Bank for public consultation a draft Board decision establishing Regulation 7/07 "Rules and requirements for the activities of crypto-asset service providers".
It has been prepared on the basis of the Law on Crypto-assets and is addressed to crypto-asset service providers operating in Armenia, as well as to investment companies and banks in respect of the services covered by Article 18 of that Law.
The draft establishes rules governing customer relationships, the conclusion of agreements and the provision of information, requirements for the safekeeping of customers’ crypto-assets and funds, as well as rules applicable to specific services, including the operation of trading platforms, custody, transfer and placement of crypto-assets, portfolio management, and the provision of advisory services. The draft.
NEW OPPORTUNITIES FOR THE INTERNATIONAL PROTECTION OF TRADEMARKS
On July 8, 2026, Saudi Arabia became the 117th member of the Madrid System by depositing with WIPO its instrument of accession to the Protocol Relating to the Madrid Agreement Concerning the International Registration of Marks.
Eligible applicants and trademark owners from Saudi Arabia will be able to use the Madrid System to seek trademark protection in other countries that are members of the Madrid Protocol. At the same time, applicants and trademark owners from other Contracting Parties to the Protocol, including Armenia, will be able to designate Saudi Arabia in their international applications as a country in which trademark protection is sought.
In connection with Saudi Arabia’s accession to the Madrid System, the following specific features will apply.
With respect to Saudi Arabia, the time limit for notifying a provisional refusal of trademark protection will be 18 months instead of the standard 12-month period.
A separate individual fee will apply when trademark protection is sought in Saudi Arabia, in place of the supplementary and complementary fees otherwise applicable under the Madrid System.
Since Saudi Arabian legislation does not provide for the division or merger of trademark registrations, requests for such division or merger in respect of Saudi Arabia may not be filed under the Madrid System.
The Madrid Protocol will enter into force with respect to Saudi Arabia on October 8, 2026. More here.
CONDUCTING PRELIMINARY COURT HEARINGS VIA VIDEOCONFERENCE
The Ministry of Justice has announced that it is developing a draft law proposing that preliminary court hearings in civil and administrative cases conducted electronically be held via videoconference.
Under the draft, preliminary court hearings held via videoconference will be conducted through the existing electronic judicial proceedings system.
Special rules governing the conduct of preliminary hearings will also be developed to ensure that such hearings are conducted without interruption.
Our team will keep you informed of further developments regarding the draft.
NEW REGULATIONS ON THE USE OF ELECTRONIC MONEY
As of 5 August 2026, amendments to Regulation 16.02 “The Procedure and Conditions for the Issuance and Servicing (Circulation) of Electronic Money and Requirements for Transactions with Electronic Money” have entered into force.
Under the amendments, it is no longer mandatory to have a bank account or payment card in order to open an electronic money account (wallet). At the same time, electronic money accounts (wallets) may now be funded and electronic money can be redeemed both through cashless and cash transactions.
The requirement for the issuer to establish a separate procedure for customer identification and customer due diligence, as well as a separate identification procedure using a payment card, has been removed.
Customer identification and the necessary due diligence will be carried out in accordance with the requirements of applicable legislation, including the requirements set out under the Law of the Republic of Armenia on Combating Money Laundering and Terrorism Financing. More here.
NEW TEMPLATE FORMS OF AGREEMENTS NOT REQUIRING NOTARIZATION
The Government of the Republic of Armenia has adopted a decision amending the decision “On Approving the Model Forms of Agreements Not Requiring Notarization”, thereby expanding the scope of model forms of agreements that do not require notarization.
In particular, the following model forms have been introduced:
- a mixed agreement for the sale and purchase of immovable property and mortgage, involving a bank or a credit organization authorized to provide mortgage loans; and
- a mixed agreement for the purchase of the right to acquire immovable property under construction and mortgage, involving a bank or a credit organization authorized to provide mortgage loans.
The amendment provides for the possibility of entering into the relevant agreements without notarization by having the parties electronically sign the respective model forms.
The Decision will enter into force following the installation and launch of the relevant functionality within the electronic system of the official website of the State Committee of the Real Estate Cadastre.
INTRODUCTION OF REVERSE MORTGAGES AND SPOUSAL OWNERSHIP RIGHTS
Due to the introduction of the reverse mortgage framework, the National assembly has adopted a draft law providing for amendments to the Civil Code and related legislation.
Unlike a conventional mortgage, under a reverse mortgage, a person who has reached retirement age may mortgage their property to a bank or a credit organization authorized to provide mortgage loans and receive an amount corresponding to the value of the property. At the same time, the person retains ownership of the property and the right to use it.
Under a reverse mortgage, the borrower’s debt to the bank or credit organization authorized to provide mortgage loans becomes due for repayment when the borrower:
dies,
disposes of the property, including by selling it,
ceases to reside in the relevant apartment or house.
In addition, a new type of right “spousal ownership right” is being introduced. It allows property acquired during marriage to also be registered as the property of a spouse.
In such a case, following the death of one spouse, the surviving spouse may continue to fully possess, use, and dispose of the apartment or house without the need to immediately divide the property with the other heirs. More here.
NEW REGULATORY AUTHORITY FOR PERSONAL DATA PROTECTION
At the initiative of the Government, it is proposed to establish a new competent authority for personal data protection (hereinafter, the “Competent Authority”), compliant with international standards, to replace the existing Personal Data Protection Agency.
In this connection, it is necessary to adopt a new law governing the Competent Authority to be established and to define the legal framework for its formation, operation and independence.
In particular, it is proposed to:
to provide that the Competent Authority will be independent and will not be part of any government agency or ministry.
establish the procedure for the formation of the Competent Authority, the appointment of its members and the exercise of their powers,
provide safeguards ensuring the proper functioning of the Competent Authority,
establish service in the field of personal data protection as a separate type of public service,
ensure the availability of the financial, material, technical and other resources necessary for the proper functioning of the Competent Authority.
At the same time, legal regulations are being introduced concerning the institutions of Data Protection Impact Assessment (DPIA) and the Data Protection Officer (DPO).
The Competent Authority will oversee compliance of personal data processing with the law and apply administrative sanctions prescribed by law in cases of violations. More here.