The US Government Agencies Point Out New Red Flags
The US Government Agencies Point Out New Red Flags that May Signal Evasion of Russia Sanctions. Common red flags can indicate that a third-party intermediary may be engaged in efforts to evade sanctions or export controls, including the following:
🚩Use of corporate vehicles (i.e., legal entities, such as shell companies, and legal arrangements) to obscure (i) ownership, (ii) source of funds, or (iii) countries involved, particularly sanctioned jurisdictions;
🚩A customer’s reluctance to share information about the end use of a product, including reluctance to complete an end-user form;
🚩 Use of shell companies to conduct international wire transfers, often involving financial institutions in jurisdictions distinct from company registration;
🚩 Declining customary installation, training, or maintenance of the purchased item(s);
🚩 IP addresses that do not correspond to a customer’s reported location data;
🚩 Last-minute changes to shipping instructions that appear contrary to customer history or business practices;
🚩 Payment coming from a third-party country or business not listed on the End-User Statement or other applicable end-user form;
🚩 Use of personal email accounts instead of company email addresses;
🚩 Operation of complex and/or international businesses using residential addresses or addresses common to multiple closely-held corporate entities;
🚩 Changes to standard letters of engagement that obscure the ultimate customer;
🚩 Transactions involving a change in shipments or payments that were previously scheduled for Russia or Belarus;
🚩 Transactions involving entities with little or no web presence; or
🚩 Routing purchases through certain transshipment points is commonly used to illegally redirect restricted items to Russia or Belarus. Such locations may include China (including Hong Kong and Macau) and jurisdictions close to Russia, including Armenia, Turkey, and Uzbekistan.
World Bank forecasts economic growth in Europe and Central Asia
The near-term economic outlook remains especially uncertain, with risks to the baseline forecast tilted to the downside. These risks include an additional tightening of global financial conditions, financial turmoil, and worsening energy shortages.In the South Caucasus, growth in 2023 is projected to halve to 3.3 percent. The forecast deceleration reflects weakening momentum after the strong rebound in 2021-22, the slowdown in the euro area.
The highest economic growth – 10,8% for 2022 in Armenia among European and Central Asian countries. Regarding other regional countries, Azerbaijan’s 2022 growth is at 4,2%, Georgia’s at 10%, and Turkey’s at 4,7%.

The highest economic growth – 10,8% for 2022 in Armenia among European and Central Asian countries. Regarding other regional countries, Azerbaijan’s 2022 growth is at 4,2%, Georgia’s at 10%, and Turkey’s at 4,7%.

New incentives for IT companies in Armenia
Armenia has made the IT sector a priority industry․ The system of granting tax incentives to IT startups first came into force in 2015 based on the law “On State Assistance to the Information Technology Sector”. It is designed to provide IT startups with tax breaks for the first years of their activity. Low rates set under the law are intended to provide motivated behavior for investment and reduce the risk of tax evasion. Tax break certificates are granted on a case-by-case basis by the Special Commission established by the Government.
Companies applying for a certificate must meet certain requirements, particularly:
In December 2022, amendments were made to the law, as a result of which the benefits program was extended:
✔️Certificate applications will be accepted until November 1, 2023.
✔️ Certificates issued up to and including December 31, 2018, are valid for a period of five years from the date of issuance.
✔️ Certificates issued after January 1, 2019, are valid until December 31, 2023, inclusive.
✔️ The possibility was made to establish other types of state support programs at the suggestion of the competent state body․
- They must be trade organizations or Private Entrepreneurs registered in the Republic of Armenia. The certificate cannot be applied to subsidiaries, economic associations, branch offices, or representatives of foreign legal entities.
- The number of employees should not exceed 30
- They shall not sell their fixed assets
- At least 70% of turnover must derive from the types of activities defined above, etc.
In December 2022, amendments were made to the law, as a result of which the benefits program was extended:
✔️Certificate applications will be accepted until November 1, 2023.
✔️ Certificates issued up to and including December 31, 2018, are valid for a period of five years from the date of issuance.
✔️ Certificates issued after January 1, 2019, are valid until December 31, 2023, inclusive.
✔️ The possibility was made to establish other types of state support programs at the suggestion of the competent state body․
Criminal liability of legal entities in Armenia
The concept of corporate criminal liability has developed and permeated into the legal regimes of countries around the world. After the adoption of the new Criminal Code, legal entities are already subject to criminal liability in Armenia.Here you can find some main points of criminal liability of legal entities under the new regulation:
- Without accounting for all the subtleties of application, under the new Armenian Criminal Code, legal entities are subject to criminal prosecution, if the crime is committed by a person who has the authority to affect the actions of a legal entity and who is acting on behalf of a legal entity and in its interests.
- The conviction of an individual does not exclude the criminal liability of a legal entity for the same crime.
- A legal entity is not subject to criminal liability if the shareholders have taken reasonably necessary means to prevent the crime.
- A legal entity is exempt from criminal liability:
- If it has eliminated the causes and conditions conducive to the commission of a crime (if any);
- Compensated for the damage caused and smoothed out other consequences of the alleged crime;
- Returned the property acquired as a result of the crime, including the income received.
- The new Code also provides measures that can be applied to legal entities, such as:
- Fine
- A temporary suspension of the right to engage in a certain sort of activity
- Compulsory liquidation
- Restriction on business activity in Armenia.