YEREVAN, August 17. /ARKA/ New requirements for banks on managing risks of circumventing international sanctions came into effect in Armenia on August 12, 2026.
The relevant changes to the regulation “Minimum Conditions for Internal Control of Banks” were approved by the decision of the Council of the Central Bank of Armenia No. 21-N dated January 30, 2026. The document was officially published on February 11 and came into force six months later, on August 12, 2026.
According to the new requirements, banks must have risk-based systems and internal control procedures that allow them to identify, assess, suspend, or reject operations that carry the risk of circumventing international sanctions.
As part of this control, banks must conduct appropriate checks not only on their clients but also on the clients' counterparties, the bank's own counterparties, and all parties involved in transactions. Additionally, banks are required to assess risks associated with clients, the geography of operations, the services and transactions provided, counterparties, intermediaries, and service delivery chains.
Monitoring must take into account, in particular, geographical factors related to sanction regimes, the origin of goods, services, software, and technologies, information about individuals and organizations under international sanctions or related to them, as well as data on financial organizations subject to sanction restrictions.
Transaction data must be monitored before the transaction is executed and confirmed. If there are changes in the sanctions lists or updates to client information, the bank must conduct re-monitoring no later than one business day after the relevant change.
Notably, the document does not specify any particular country or sanction regime. International sanctions are referred to in the document as economic, financial, trade, and other restrictive measures imposed by states or international organizations.
The changes added a new chapter 15.1 “Management of the Risk of Circumventing International Sanctions” to the banking regulation. They also provide for the appointment of a responsible person within the bank for managing this risk, regular assessment of the effectiveness of control systems, and submission of relevant reports to the bank's board and executive body.
