Armenia: Scoping report on beneficial ownership transparency

This report contains our assessment of the beneficial ownership regime in Armenia, and analyses current and planned reforms using the Open Ownership principles. Open Ownership (OO)’s nine Principles of Effective Beneficial Ownership Disclosure provide a framework for implementing comprehensive beneficial ownership transparency reforms, and assessing and improving existing disclosure regimes. They seek to generate actionable and usable data across the widest range of policy applications.

The Principles describe a range of policy, legal, systems, data, and technology characteristics that support publication of easy-to-use, accurate, and interoperable beneficial ownership (BO) data. These Principles were developed through OO’s work developing the Beneficial Ownership Data Standard (BODS) and supporting almost 40 countries to advance BOT. The implementation of the Principles enables countries to meet and exceed relevant aspects of the Extractive Industries Transparency Initiative (EITI), Financial Action Task Force (FATF) and other international standards for disclosure.

Since the publication of OO’s August 2020 scoping study on BOT in Armenia, the country has completed its pilot for BO disclosures in the extractives sector and has continued to make notable advances across multiple implementation areas. The country has expanded the scope of its disclosures to cover all sectors by 2023, tightened its legal definitions, made a series of improvements to its data collection and publication systems, and became one of the first countries to publish data in line with BODS. Such positive and notable advances reflect the iterative approach to implementation — in terms of its policies and procedures, as well as its technical systems and software — that the country has continued to employ.

Moreover, Armenia has confirmed its participation in the Opening Extractives (OE) programme; a joint initiative of the EITI and OO, through which it will continue to receive enhanced technical assistance and support across the range of tasks involved in producing high quality beneficial ownership data. Support under OE will be provided at least until the end of the initial project phase in June 2023, with further technical assistance potentially also available up until 2025.

This report is intended to help inform the next stage of reforms and technical assistance on BOT that will be provided under the OE programme. The main recommendations include that Armenia should prioritise: continuing work to expand the entities required to submit BO data; addressing issues with its BODS representation of declarations; and developing more enhanced systems for data verification.