Self-custodial wallet / non-custodial software in Armenia

Lack of Specific Legislation: There is no dedicated law in Armenia regulating virtual assets or stipulating licensing requirements for crypto businesses. This creates a significant degree of legal uncertainty for operators.

Central Bank's Stance: The Central Bank of Armenia (CBA) has consistently maintained a cautious and conservative stance on cryptocurrencies. It has issued warnings to the public about the high risks associated with virtual assets, emphasizing that cryptocurrencies are not legal tender in Armenia and are not regulated or supervised by the CBA. They do not recognize cryptocurrencies as a form of electronic money, payment instrument, or security.

Anti-Money Laundering and Counter-Terrorist Financing (AML/CFT) Law: This is the most significant piece of legislation relevant to virtual asset activities. Armenia, as a member of international bodies, adheres to FATF recommendations. The Law on Combating Money Laundering and Terrorist Financing (Հայաստանի Հանրապետության օրենքը «Փողերի լվացման և ահաբեկչության ֆինանսավորման դեմ պայքարի մասին») likely applies to entities dealing with virtual assets, even if not explicitly named as "VASPs" in the law. This means any entity facilitating the transfer, exchange, or custody of virtual assets would be expected to implement robust AML/KYC procedures.

Specifics: This law, originally adopted in 2004, has undergone several amendments. Crucially, amendments in 2022 specifically brought virtual asset service providers (VASPs) within the scope of obligated entities. This means VASPs are now subject to the same AML/CFT obligations as traditional financial institutions.

These amendments align Armenia with FATF Recommendation 15 on new technologies, which requires countries to regulate and supervise VASPs for AML/CFT purposes. The Travel Rule application to VASPs has been clarified as distinct from the core Recommendation 15 VASP regulatory requirements.

Identification and Verification of Identity:

Beneficial Ownership: Identify and take reasonable measures to verify the identity of the beneficial owner(s) of the customer, especially for legal entities and complex structures. This includes understanding the ownership and control structure.

Reporting Obligation: If a VASP knows, suspects, or has reasonable grounds to suspect that funds, virtual assets, or other assets are the proceeds of a criminal activity, or are related to terrorist financing, it must immediately file a Suspicious Transaction Report (STR) with the Financial Monitoring Center (FMC) of the CBA.

Period: Records related to customer identification data, beneficial ownership information, transaction data (including virtual asset addresses, transaction hashes, amounts, and timestamps), and any STRs filed must be kept for a minimum of five (5) years after the business relationship has ended or after the date of the transaction.

Sanctions Screening: Screen customers and transactions against national and international sanctions lists.

No specific "crypto custody license" exists. Armenia does not currently have a dedicated licensing regime for cryptocurrency custodians.

Armenia has specific laws and regulations, including the Law on Crypto-Assets (adopted May 29, 2025), that regulate crypto-asset service providers (including custodians) licensed by the Central Bank, with requirements for AML, transaction monitoring, record retention, and client protections, though explicit client asset segregation mandates are not detailed in the provided evidence.

Payment System Regulations: If a crypto-related service involves the processing of fiat currency (e.g., converting AMD to crypto or vice versa), it may inadvertently trigger requirements under the Law on Payment and Settlement Systems and Payment Organizations, potentially requiring a license for a payment organization or payment system operator from the CBA.

Evidence fact am.licensing.exchanges-crypto-to-crypto-generally-unregulated-operators-function not found (may have been renamed).

A criminal case under Articles 188 and 190 of the RA Criminal Code related to a crypto company was initiated, but the subsequent Armenian Court of Appeal ruling declaring the detention of businessman Samvel Karapetyan illegal indicates that the legal basis or enforcement of such detentions is not consistently upheld, undermining the characterization of a sustained proactive approach.

Examples of Seized Assets: Reports mention seizures of large sums in fiat currency, cryptocurrency, real estate, and luxury vehicles. For instance, some cases involved alleged damages amounting to tens or hundreds of millions of USD.