Beneficial ownership transparency in Armenia: scoping study
List of Recommendations
Public access to a central register
- Armenia should further improve the accessibility and utility of future BO disclosures by publishing in “open data” format and enabling bulk downloads.
- BO definitions in Armenian legislation should be harmonised as much as possible and plans made for the periodic evaluation and revision of threshold levels.
- Clear guidance should be provided to disclosing entities regarding their reporting obligations for politically exposed persons (PEPs) and “affiliated persons”.
- Drafting of economy-wide disclosure regulations should begin as soon as possible and aim to cover the overwhelming majority of companies registered in the country.
- Armenia should use an agile development methodology for its BO software, using mining sector disclosures to test the system’s handling of structured data.
- In the first iteration of the economy-wide register, reporting requirements should be made simpler, requiring only data submissions for beneficial owners and first level entities in an ownership chain.
- Unique IDs (including country-level IDs) for people and entities should be collected and published.
- Plans should be created for future enhancement and expansion of data verification systems in the forthcoming electronic register.
- A feedback mechanism should be incorporated into the public register that allows all users to report suspected inaccuracies.
Up-to-date and auditable
- Armenia should retain and publish information regarding changes in a company’s beneficial owners.
- The start date on which BO arrangements began should be included in future declarations, and this field should be made mandatory in Armenia’s software.
Sanctions and enforcement
- Armenia should create a roadmap for implementation of a sanctions regime for non-extractive sector firms that fail to comply with BO disclosure requirements.
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