What Really Blocks an Armenian LLC for Founders From Iran, Bangladesh, Nigeria and Ethiopia: Entry, Registration or the Bank?

For a founder from Iran, Bangladesh, Nigeria or Ethiopia, the gate most likely to stop an Armenian LLC is the bank. Registration has no nationality bar, entry was eased on 16 June 2026, and since 12 August 2026 every Armenian bank must screen a company’s owners, beneficial owners and directors for sanctions risk before it opens an account. Passing one gate tells you nothing about the next, so each is set out separately below.

Gate 1: getting into Armenia

Iran: visa-free

Iranian citizens need no visa. Under the Armenia-Iran visa memorandum, in force since 10 August 2016, they may stay up to 90 days in any 180-day period, on any type of passport. Iran was never on Armenia’s invitation-only list.

Bangladesh, Nigeria and Ethiopia: the invitation-only list was repealed

All three countries were on Government Decision 329-N of 2008, the list of 57 states whose citizens could obtain an Armenian visa only at an embassy or consulate, and only on the basis of an invitation approved by the Ministry of Foreign Affairs. Government Decision 643-N, adopted on 14 May 2026, repealed that list with effect from 16 June 2026.

Our understanding, confirmed to us by the Ministry of Foreign Affairs, is that the e-visa is now open to citizens of every country, including Bangladesh, Nigeria and Ethiopia, for tourist, business and work visits, and that the Ministry no longer processes stand-alone invitation letters. The e-visa has a statutory maximum processing time of 3 working days; in practice it can take a few weeks, so apply well before you book flights. See our վիզայի ծառայություններ for the application itself.

This position may be temporary. The repeal was adopted as a facilitation measure for the COP17 conference held in Yerevan from 18 to 30 October 2026, and in April 2026 the Ministry of Internal Affairs proposed re-adopting rules of the same content after the conference. Decision 643-N has no sunset clause, so reinstating the list would require a new government decision. The published texts have not fully caught up with the repeal: the e-visa decree (Government Decision 1268-N) still refers to invitation-only nationalities without naming any. Check the position again before any trip planned after 30 October 2026. Our հրավերի նամակի ուղեցույց sets out the old procedure in case it returns.

Ethiopian citizens have a second route. Under Government Decision 610-N, as amended by Decision 932-N, nationals of the listed countries who hold residence status valid for at least six months in the specified jurisdictions (including the United States, the EU and Schengen states and the Gulf states named in the decision) may enter visa-free until 1 July 2027, for up to 180 days a year. Ethiopia is on that list. Bangladesh and Nigeria are not.

You may not need to travel at all

An Armenian LLC can be registered through a representative acting under a power of attorney, so the entry question only matters for steps that need you in person, usually the bank. Our guide to registering an Armenian LLC without visiting covers the power of attorney and its legalisation.

Gate 2: registering the LLC

The Law on Limited Liability Companies allows any natural or legal person to be a founder or participant, and provides that this right may be restricted only by law. No law restricts it by nationality for an ordinary trading or services company. The same law expressly allows a foreign citizen’s identity-document number in the company’s founding particulars, so foreign ownership is built into the system. A sole foreign founder is permitted; no Armenian co-owner or local director is required.

The State Register may refuse registration only on the grounds listed in the Law on State Registration of Legal Entities. None of them concerns the founder’s nationality or sanctions exposure, a refusal must state its reasons, and the Register may not refuse on the ground that a registration seems inexpedient. Registration takes no more than 1 working day after the documents are filed (2 working days if a founder is itself a company), and the standard route carries no state fee.

Documents and the public services number

A foreign founder files a passport copy with a notarised Armenian translation. The Register’s published FAQ also lists a public services number for non-Armenian founders. Any foreigner lawfully present in Armenia can obtain one from the Migration and Citizenship Service within 1 working day. Published guidance does not settle whether a founder filing remotely through a representative always needs one, and the government’s online services page lists only the translated passports.

Իրական սեփականատիրոջ հայտարարագիր

Anyone holding 20% or more is a beneficial owner. The company must declare its beneficial owners at bo.e-register.am within 40 days of registration and again every year by 20 February. Failing to do so carries an administrative fine of AMD 30,000 to AMD 100,000 (about USD 83 to USD 277 at the house rate of AMD 361.36 per USD, CBA rate of 19 October 2026). Banks read this declaration, so an incomplete or late one becomes a bank problem as well as a Register problem.

Where the general rule stops

Banks, credit organisations, payment and settlement organisations, investment companies, fund managers and insurers are governed by their own sectoral laws, which carry separate ownership approvals. Residence is also separate. For applications under the new system from 1 November 2026, an LLC-based residence permit requires a charter capital contribution or shareholding of at least AMD 2,000,000 (about USD 5,535 at the same house rate), and new applications can be filed only after that date. Our բիզնեսի գրանցման ծառայություն covers the filing itself.

Gate 3: the bank

Central Bank of Armenia Decision 21-N, adopted on 30 January 2026 and in force since 12 August 2026, added a chapter on the risk of circumventing international sanctions to the minimum internal-control rules every Armenian bank must follow. It is binding on banks and governs how they assess you as a customer.

Who is screened, and when

• Persons screened: holders of significant direct or indirect participation, beneficial owners, directors, authorised persons and guarantors. For individuals the bank considers citizenship, residence and main country of tax residence; for companies, their location and place of activity.
• At onboarding: screening is part of opening the account, so screening the company name alone is not enough.
• Continuously: within one working day after a sanctions list changes or after the customer’s own data changes.
• Transactions: before each transaction is executed.

Decision 21-N contains no nationality ban, no fixed onboarding deadline and no universal ownership percentage. Each bank chooses which foreign sanctions regimes it follows according to its business, size and risk profile, and it must be able to suspend or reject transactions that carry circumvention risk. The absence of a ban does not entitle anyone to an account.

Iranian owners: enhanced due diligence

The Financial Action Task Force has called for countermeasures against Iran since February 2020 and repeated that call in its statement of 19 June 2026. Armenia’s anti-money-laundering law requires enhanced due diligence for high-risk customers, and Central Bank Decision 11-N, in force since 30 January 2026, treats persons located in, resident in or originating from such non-compliant countries as high risk. We found no Iran-specific Central Bank instruction issued after the June 2026 statement.

Bank policy follows the same line. Evocabank’s Financial Crime Compliance Policy, approved by its board on 24 January 2025, lists Iran as a higher-risk country, applies enhanced due diligence and runs sanctions screening. Expect heavier scrutiny and slower onboarding. The published policy contains no outright refusal of Iranian-linked customers.

Bangladeshi, Nigerian and Ethiopian owners

The same screening applies, and we found no Armenian banking rule that restricts these nationalities as such. In our experience the causes of refusal are the same for every founder: an ownership chain the bank cannot verify, unclear source of funds, no visible connection between the business and Armenia, and counterparties in sanctioned or high-risk countries. Opening an account without visiting the bank also triggers enhanced due diligence.

What to prepare before approaching a bank

1. An ownership chart down to every individual holding 20% or more, with passports and proof of address for each, matching the beneficial ownership declaration exactly.
2. Evidence of the source of the funds going into the company and of each owner’s wealth: bank statements, sale contracts, salary records, tax returns.
3. A short description of the business in Armenia: what it sells, to whom, where staff and premises are, and why the company is Armenian.
4. A list of expected counterparties and payment countries for the first year. Payments to or from sanctioned jurisdictions should be disclosed at the start; a bank that discovers them later can freeze transactions.
5. Identity documents for the director and anyone who will hold signing authority.
6. A plan for an in-person visit if the bank asks for one, which affects the entry question in Gate 1.

Banks’ account requirements differ and change often; our guides to corporate bank accounts in Armenia և accounts for non-residents cover the standard procedure, and our banking service handles the introduction. If an owner is Iranian or the funds come from a higher-risk jurisdiction, have the bank file reviewed before you register the company, because the company is easy to form and hard to use without an account.

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