Armenia to Limit Cash Payments

The Armenian Parliament passed a bill setting amendments to the law “On non-cash payments” and a number of related laws. Under new changes, all transactions exceeding AMD 300,000 (approx. USD 700) made by individuals in Armenia are to be carried out noncash.

The regulations apply to payments for goods, sale, and purchase of property, use of goods, execution of work, provision of services, payment of salaries, etc. There are certain areas where the threshold is zero, such as budgetary receipts and payments, health care, education and legal services. For transactions, requiring state registration of rights, the threshold is 500,000 AMD.

For some payments, the regulations will come into force – in 2022 for the capital Yerevan, and in 2023 for provincial towns, and in 2024 throughout Armenia. In case of non-compliance with the requirements, the contract will be considered invalid․

According to officials, the AMD 300,000 threshold was chosen based on the results of studies and the actual volume of transactions. It is also noted that the transition to cashless payments is part of a plan to shift to a digital economy.

Armenia is not the only country in the world with cash payment limits.

  • In France, cash payment limits are based on residency. Cash payment limits for residents are EUR 3,000 and for non-residents acting as consumers, is EUR 15,000.
  • In the UK the consumers can make cash payments without any limits. The traders, however, need to register themselves with tax authorities as “High-Value Dealers” if accepting cash payments over EUR 15,000.
  • Bulgarian regulations limit cash transactions up to 10,000 leva (approx. EUR 5,112). If the transaction is over that limit, then the payment should be made by bank transfer. The same applies also in any case where the purchase price is over EUR 5,112, and payment is made in parts.
  • Spain, since November 2012, the limit is EUR 2,500 for residents and EUR 15,000 for non–residents. If the amount is higher, the payment should be done by bank. Failure to follow this precept might result in a fine of up to 25% of the total transferred amount.

In respect of regulations in Armenia, it should also be highlighted that the above-mentioned regulations are far too broad to cover all possible scenarios, necessitating a more precise approach in each circumstance. However, one thing is certain; they will create and promote a new non-cash payment culture in Armenia.

The Ad Hoc Committee in Edmond Khudyan and Arin Capital & Investment Corp v Armenia (ICSID) is constituted.

June 1, 2022. The ad hoc Committee in Edmond Khudyan and Arin Capital & Investment Corp v Armenia (ICSID Case No. ARB/17/36, Annulment Proceeding) is constituted in accordance with Article 52(3) of the ICSID Convention.

Its members are:

Christopher Greenwood (British), President;
Tina Cicchetti (Canadian/Italian), and
Ucheora Onwuamaegbu, PhD (British/Nigerian).

All members appointed by the Chairman of the Administrative Council.

Party Representatives:


Redbridge, Yerevan, Armenia
Dr. Gevorg Tumanov.

Hughes Hubbard & Reed LLP, Washington, D.C., U.S.A.
Mr. James Boykin, and Mr. Alex Bedrosyan.


Office of the Representative of the Republic of Armenia before the European Court of Human Rights, Yerevan, Armenia.

What Is a Grandfather Clause?

A grandfather clause, or legacy clause, is an exemption that allows persons or entities to continue with activities or operations that were approved before the implementation of new rules, regulations, or laws. Such allowances can be permanent, temporary, or instituted with limits.


  • A legacy clause is a provision that allows people or entities to follow old rules that once governed their activity instead of newly implemented ones, often for a limited time.
  • The “grandfather clause” term originated during the U.S. Civil War era and referred to statutes enacted in the South to suppress African American voting.
    Legacy clauses can be permanent, temporary, or instituted with limits.
  • Legacy clauses often apply to zoning laws when the purpose of a development changes.

An Example of a Grandfather Clause in Armenia.

The Law of Armenia on Foreign Investments. Article 7. “In the event of amendments to the foreign investment legislation of the Republic of Armenia, the legislation that was effective at the moment of implementation of investments shall be applied, upon the request of a foreign investor, during a five years period from that moment.”

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