Criminal proceedings have already been initiated regarding the alleged violations committed during the declaration of ultimate beneficiaries: the importance and mechanisms of identification of ultimate beneficiaries were discussed at the seminar

There are already initiated criminal proceedings regarding the alleged violations committed during the declaration of ultimate beneficiaries. Thus, in order to reduce or exclude the risks of liability, the issue of primary significance in the ultimate beneficiary’s declaration process is the proper identification of the ultimate beneficiaries of the organizations (proper examination) and documentation of examination, however, companies at times do not attach much importance to this. This was stated by Lawyer Narine Beglaryan, a partner of the Concern Dialog law office, during a seminar organized by the company on identifying ultimate beneficiaries and submitting declarations.

The other speaker of the seminar, Lawyer Lilit Karapetyan, junior partner of Concern Dialog law office, stressed that in order to properly identify ultimate beneficiaries in organizations with a complex structure, professional abilities are required to avoid further problems or to have a legal basis if they arise.

During the seminar, the speakers presents details of the mandatory regulations related to the identification of ultimate beneficiaries ( proper examination) and the submission of declarations in accordance with the procedure stipulated by the RA Legislation.


Amendments to the Law “On State Registration of Legal Entities, Separated subdivisions of Legal Entities, Institutions and Individual Entrepreneurs” effective from January 1, 2023, pursuant to which new (annual) obligations were set for all legal entities registered in RA related to the submission of declarations on ultimate beneficiaries.

The Ministry of Justice has extended the deadline for submitting an ultimate beneficiary’s declaration until April 1.

The RA Law “On Administrative Offenses” stipulates a warning or a fine of up to AMD 100,000 for a person who has the duty to submit a declaration on ultimate beneficiaries for failure to submit information on ultimate beneficiaries within the time limit set by law, as well as for submitting information in violation of the law or carelessly submitting incorrect or incomplete information in the declaration.

And submitting false information in the declaration or concealing the information to be provided by the person who submitted the declaration regarding the ultimate beneficiaries may lead to criminal liability.

In addition, in case of failure to fulfill the obligation to submit confirmation or amended information about the ultimate beneficiaries for three consecutive years, as well as in case of repeated or gross violation of the rules of submitting a declaration, the State Register Agency of Legal Entities of the Ministry of Justice of the Republic of Armenia may apply to the court with the request to dissolve the legal entity.

Read the blog article prepared by Concern Dialog about the submission of declarations on ultimate beneficiaries:

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1 Charents str., Office 207 Yerevan, 0025, Armenia

+374 60 27 88 88 +374 10 57 51 21