Beneficial ownership transparency in Armenia: The current regime and next steps

  • Publication date: 13 July 2022
  • Author: Peter Low


As most data has only been recently submitted, it is therefore broadly up-to-date and thus also compliant with the OO Principle in this area. Armenia will likely face mounting challenges to maintain current data in the future, as the number of entities required to declare BO information continues to expand throughout the economy.

Armenia continues to make solid progress with its implementation of an economy-wide public BO register. In some areas – for example, publishing its data in line with BODS – the country is among the leading implementers worldwide. The major improvements recommended for the next iteration of the register and Armenia’s disclosure regime, include:

  1. Continue the rollout of requirements to disclose, ensuring that legislation obliging future BO declarations from new areas of the economy is fully implemented and enforced.
  2. Implement changes to the representation of data in BODS within the register.
  3. Adopt an iterative approach to the implementation of a more comprehensive verification system.
  4. Further increase the use and impact of data by allowing individuals with a non-Armenian IP address to access the data.
  5. Conduct periodic reassessments of its threshold levels and legal definitions in order to address any potential loopholes that illicit actors may find and begin to exploit.
  6. Conduct an analysis of data disclosures to identify areas in which quality issues most frequently occur and seek to rectify these.
  7. Increase investment in communication campaigns and other awareness-raising initiatives to help drive up compliance rates for future rounds of disclosures.
  8. Continue to build the capacity of the State Registry to conduct investigations into BO data submissions, and to integrate this functionality with a comprehensive verification system.

Of the various recommendations outlined in this scoping study, the ones that will have the greatest impact on impact of Armenia’s register are 1) ensuring that all sectors eventually disclose their BO data; 2) rectifying errors in the representation of information from declarations in the data in the register; and 3) developing a comprehensive verification system to check the data. Collectively, these three measures would significantly improve the quantity, quality, and usability of the data, and help cement Armenia’s role as a global model to follow in the area of beneficial ownership transparency.