The Council of Europe’s anti-money laundering body, MONEYVAL, has published its assessment of Armenia, finding stronger understanding of money-laundering and terrorist-financing risks, satisfactory national policies and strategies, and a robust regime for targeted financial sanctions related to terrorism and proliferation financing. At the same time, the report identifies material gaps in foreign-threat analysis, virtual-asset risks, real-estate risk assessment, operational cooperation, beneficial ownership transparency, money-laundering enforcement and asset recovery. Based on the effectiveness and technical compliance ratings, Armenia has been placed in the enhanced follow-up process. The report says Armenia generally provides high-quality and timely international cooperation and has become more proactive with foreign counterparts, particularly in corruption cases, although that approach is not applied systematically to associated offences such as drug trafficking. Controls to stop criminals and their associates entering the regulated financial sector are viewed positively, but supervision of virtual asset service providers and non-public investment funds needs further work, while oversight of designated non-financial businesses and professions was assessed as having limited effectiveness and weak sanctions. MONEYVAL also calls for completion of the beneficial-ownership register and verification of the information it contains. Armenia’s Financial Intelligence Unit was commended for stronger staffing, IT resources and intelligence output, but suspicious activity reporting from the private sector needs to improve, and investigators should place greater emphasis on the money-laundering dimension of criminal cases. Although reforms have increased money-laundering investigations and prosecutions, especially in corruption-related matters, prosecutions remain constrained by a restrictive interpretation of the offence and convictions are still low. The report further says seizure and confiscation results do not show that criminal-asset recovery is being pursued as a policy objective, despite a stronger framework including civil forfeiture, and it flags weaknesses in consistently identifying terrorist-financing activity where funds are raised through associated criminality. MONEYVAL has given Armenia a roadmap of key recommended actions to complete within three years and requires it to report back on the progress made.