SYSTEMIC AUDIT OF THE ARMENIAN FINANCIAL SECTOR

PARENT NODE: [ DEPT I: CORPORATE WATCHDOG ]

CASE ID: ARM-01-IDB

TARGET: ID Bank CJSC

REGULATOR: Central Bank of Armenia (CBA)

STATUS: 🔴 PHASE 4: STRATEGIC LITIGATION (Q1 2026)

1. EXECUTIVE SUMMARY: THE “SOVEREIGN VOID”

Why this case matters.

This audit exposes a critical vulnerability in the Republic of Armenia’s state architecture: The abdication of financial sovereignty.

Our forensic testing proved that private commercial banks have established a regime of “Compliance Supremacy,” where opaque internal policies (often dictated by foreign correspondent banks) legally supersede the Constitution of Armenia and the Civil Code.

The Thesis:

Armenia is currently a “Disconnected Jurisdiction.”

Residents are treated as “High Risk” by default. The regulator (CBA) acts as a passive observer, refusing to enforce public contracts. This creates a “Lock-in Risk” for any capital entering the country: easy to enter, difficult to utilize, and subject to arbitrary freezing.

2. THE INCIDENT (CASUS BELLI)

Chronology of the Violation.

DATE: September 12–13, 2025

LOCATION: ID Bank CJSC, Baghramyan Branch.

EVENT: Refusal to payout two incoming RIA Money Transfers (Total: €1,000 & $1,000) to a legal resident.

• The Violation: The Bank refused to execute the transfer citing “Internal Policy” regarding non-residents.
• The Malice:
  1. Refusal of Written Grounds: The Bank refused to provide a written reason for the rejection on site.
  2. Fabrication of Data: In a subsequent email response, the Bank falsely claimed the client had “incorrect citizenship data,” which they later admitted was a “technical error” (Ref: IDBank_response_2.pdf).
  3. The Control Group: On the same day (Sep 26), the same transfers were successfully paid out by two other agents (HayPost and AraratBank) without a single additional question. This proves the issue was not the client or the funds, but ID Bank’s arbitrary blockade.

3. THE REGULATOR’S ABDICATION (CBA)