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Beneficial ownership transparency in Armenia: scoping study

Contents

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.

Robust definitions

  • 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”.

Comprehensive coverage

  • 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.

Structured data

  • Armenia should use an agile development methodology for its BO software, using mining sector disclosures to test the system’s handling of structured data.

Sufficient detail

  • 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.

Verified data

  • 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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