Despite the challenges facing Armenia due to the dual shocks of COVID-19 and the Nagorno-Karabakh conflict, the Armenian government’s commitment to eradicating corruption continues. Policy action and systemic change remain strong, and the government has pressed forward with legislative actions to establish investigative and judicial anti-corruption bodies. The government’s anti-corruption agenda is outlined in a 2019–2022 strategy and implementation plan. These documents establish a new anti-corruption institutional framework with separate entities tasked with preventive and investigative functions, set out specific measures for strengthening these functions, and prioritize strategic communication and public education to give citizens ownership of anti-corruption reforms.

The government took concrete steps in 2020 to establish and develop four key anti-corruption institutions: 1) the Corruption Prevention Commission (CPC), which conducts integrity checks on judges and other key justice sector personnel; 2) a civil asset forfeiture department within the Prosecutor General’s Office (PGO); 3) an anti-corruption court; and 4) a new anti-corruption investigative body. The CPC and PGO asset forfeiture department are already established, while the anti-corruption court and investigative body are expected to launch before the end of 2021. International experts are expected to play a role in the selection process for anti-corruption court judges and the head of the new anti-corruption investigative agency, which will serve to improve the legitimacy of the court’s judges and the investigative agency’s leadership.

The government has increased corruption investigations against mid- and high-level government officials since the 2018 revolution. Investigation targets include those appointed by the government that took power following the revolution.  Numerous high-ranking officials have stated publicly that corruption within their respective institutions will no longer be tolerated. Though some report that the government has mainly targeted ex-government officials in corruption investigations, there is no indication that Armenia’s anti-corruption laws are being applied by the post-revolutionary government in a discriminatory manner.  Armenia’s anti-corruption laws extend to all Armenian citizens.

Corruption remains a significant obstacle to U.S. investment in Armenia, particularly as it relates to critical areas such as the justice system and concerns related to the rule of law, enforcement of existing legislation and regulations, and equal treatment.  Investors claim that the health, education, military, corrections, and law enforcement sectors lack transparency in procurement and have in the past used selective enforcement to elicit bribes. Judges presiding over civil matters are still widely perceived by the public to be corrupt and under the influence of former authorities.  Anecdotal allegations of corruption or unethical behavior by sitting officials and associates, while less common than in the past, continue to arise and have dampened business sentiment. Although bribery is illegal in Armenia, the government does not actively encourage private companies to establish internal codes of conduct. Several multinational companies, select local companies, and foreign and local companies working with international financial institutions have implemented corporate governance mechanisms to tackle corruption internally.  However, such corporate governance principles are not widely implemented among local companies.

According to Transparency International’s 2020 Corruption Perceptions Index, Armenia made the second-best improvement in the world and received a score of 49 out of 100, ranking it 60th among 180 countries. This reflects an improvement by 17 places over 2019.

Armenia’s ability to counter, deter, and prosecute corruption has historically been hindered by the lack of robust enforcement of official disclosure laws meant to prevent corrupt officials from entering and retaining positions of authority and influence.  The objective and systematic scrutiny of declarations by government officials had been lacking due to dysfunction within the Commission on Ethics of High-Ranking Officials, but is gradually improving with the establishment of the CPC in November 2019. The CPC has inherited responsibility for scrutinizing officials’ declarations and is scheduled to launch a fully automated system for declarations of assets, income, and conflicts of interest. The CPC has also conducted integrity checks and issued opinions on nominees to public positions. According to international evaluations, Armenian authorities have limited capacities to investigate money laundering and bring such cases to prosecution.

Various laws prohibit the participation of civil and municipal servants, as well as local government elected officials such as mayors and councilors, in commercial activities.  However, powerful officials at the national, district, and local levels often acquire direct, partial, or indirect control over private firms. Such control is often exercised through a hidden partner or majority ownership of fully private parent companies. This involvement can occur through close relatives and friends. According to foreign investors, these practices reinforce protectionism, hinder competition, and undermine the image of the government as a facilitator of private sector growth.  Because of the historically strong interconnectedness of the political and economic spheres, Armenia has often struggled to introduce legislation to encourage strict ethical codes of conduct and the prevention of bribery in business transactions. In 2016, Armenia adopted legislation on criminal penalties for illicit enrichment and noncompliance or fraud in filing declarations.

Armenia is a member of the UN Convention against Corruption.  While not a party to the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions, Armenia is a member of the OECD Anti-Corruption Network for Eastern Europe and Central Asia and has signed the Istanbul Action Plan.  A monitoring report released by the OECD in 2018 cited Armenia’s lack of enforcement of anti-corruption laws, together with the continued presence of oligopolistic interests in the economy, as points of serious concern. The report contains a series of recommendations, including to take bold measures to ensure judicial and prosecutorial independence and integrity, introduce corporate liability for corruption offenses, investigate and prosecute high profile and complex corruption cases, and increase transparency and strengthen monitoring in public procurement.  Armenia is also a member of the global Open Government Partnership initiative.

No specific law exists to protect NGOs dealing with anti-corruption investigations.

Resources to Report Corruption

For investigating corruption:Investigation Department of Corruption, Organized and Official CrimesSpecial Investigation Service of Armenia13A Vagharsh Vagharshyan StreetYerevan, Armenia+374 11 900 002 press@investigatory.am 

For prosecuting corruption:Artur ChakhoyanHead of Department for Combating Corruption and Economic CrimesRA Prosecutor General’s Office5 V. Sargsyan StreetYerevan, Armenia+374 10 511 655 info@prosecutor.am

For financial and asset declarations of high-level officials:Haykuhi HarutyunyanChairpersonCorruption Prevention Commission24 Baghramyan StreetYerevan, Armenia hhcpcarmenia@gmail.com 

Watchdog organization:Sona Ayvazyan
Executive Director
Transparency International Anti-Corruption Center
12 Saryan Street
Yerevan, Armenia
+374 10 569 589
sona@transparency.am