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The Insider

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Bullion bypass: How Russia circumvents sanctions to export billions of dollars worth of gold through Armenia

Armenian companies are helping Russia bypass the Western embargo on the gold trade, The Insider and Hetq have discovered. Backed by prominent Armenian politicians and business figures, these companies have facilitated the import of billions of dollars' worth of gold into Armenia since 2022. But the precious metal doesn’t stay there, as gold exports to the UAE have reached record levels. At the same time, cash and securities are reportedly flowing in the other direction — from the UAE to Armenia. Russian businesses are capitalizing on trading gold via Armenia, as the country does not apply export duties. Meanwhile, conducting transactions through private entities facilitates the evasion of sanctions.

Contents

A joint investigation by The Insider and Hetq.

Gold flows from West to East

Gold was one of the first Russian export commodities to fall under an embargo following Moscow’s full-scale invasion of Ukraine in February 2022. In June 2022, the U.S. banned the purchase of the precious metal from Russia, calling it the “country’s biggest non-energy export.”

Officially, this embargo only applies to imports into the United States. However, if a third country purchases gold linked to Russia, it becomes ineligible for sale in the U.S., effectively barring banks from using it for investment or trading. This means that, unlike restrictions on most other imports, the American embargo on “bank gold” effectively has global implications.

After the start of the full-scale war, the flow of Russian gold shifted eastwards — from the U.K to the UAE, Hong Kong, and Turkey. However, by April 2023, even these flows had ceased completely. Since then, no Russian gold has been exported outside the Eurasian Economic Union (EAEU). Around the same time, Armenia emerged as a major gold exporter, according to reports by Hetq. A joint investigation by The Insider and Hetq has found that nearly all of this gold was sourced from Russia.

No Russian gold has been exported outside the Eurasian Economic Union since April 2023.

A stream of gold rivaling Armenia’s GDP

According to Russian customs data obtained by The Insider and Hetq, between 2022 and 2024 Armenia purchased 89 tons of gold from Russia valued at approximately $5.2 billion. Armenian Customs Service data reviewed by Hetq, however, indicates that 111 tons of Russian gold worth $6.2 billion were imported into Armenia from 2023 through the first half of 2024.

For context, Armenia's total imports in 2022 — of all products, not just one precious metal — amounted to $11 billion, while its GDP was $19.5 billion.

The discrepancies between Russian and Armenian customs data may be due to timing differences in the reporting of transactions between the two countries.

Who imports Russian gold: Armenian politicians and Russia-linked businessmen

Investigations by The Insider and Hetq reveal that some of the largest importers of Russian gold to Armenia in 2024 — those handling over $50 million worth of the metal — are connected to influential Armenian politicians, oligarchs, and businesses with ties to Russia. Notably, the Yerevan Jewelry Factory, the third-largest importer of Russian gold into Armenia, has links to the family of Khachatur Sukiasyan, a member of parliament from the ruling Civil Contract Party.

Khachatur Sukiasyan

Photo: Hetq

The Yerevan Jewelry Factory was officially opened in 2022 in a new building at the “Yerevan” market. It is linked to the Sukiasyan and Avagyan families, with the latter having been involved in the jewelry business in Russia. Hetq discovered that the company was re-exporting large batches of jewelry of Russian origin and labeling them as Armenian. It appears that the factory served as a channel for “laundering” Russian jewelry products, sourcing gold from about 30 Russian companies.

In 2022 and 2023, following the imposition of sanctions, recipients of Russian gold included not only jewelry factories and LLCs suspected of being shell companies, but also banks such as Araratbank and Converse Bank. By 2024, however, Armenian bankers had begun avoiding these risky transactions.

Following the release of this article, Converse Bank reached out to the editorial teams at The Insider and Hetq, providing the following comment:

“Converse Bank has consistently adhered to the sanctions policies of the UN, U.S., EU, and UK since their implementation.

Since 2017, the bank has regularly imported only gold bullion bars (weighing from 5g to 1,000g) into Armenia — not bank-grade gold, which typically weighs 11 to 13.3kg. These gold bars were imported solely for sale within the Armenian market, which is standard banking practice.

Since 2022, the volume of gold bullion transactions has significantly decreased. Converse Bank has never been engaged, directly or indirectly, in the export or re-export of precious metals.

It is important to note that primary sanctions only apply to entities importing Russian gold into the U.S., UK, or EU. Secondary sanctions were introduced later — in the U.S. in December 2023 and in the EU in 2024. Therefore, Converse Bank has not conducted any transactions since the introduction of these sanctions.”

Russian customs data confirms that Converse Bank imported Russian gold in 2022 and 2023. In 2022, the bank brought 356,474 grams of gold into Armenia, valued at 662.2 million rubles. The following year, imports totaled 121,996 grams, with a reported value of 795.5 million rubles. As of 2024, no gold imports by the bank are recorded in the customs database.

The infographic below highlights the largest importers of Russian gold into Armenia in 2024. Each of them brought in more than $50 million worth of the precious metal.

The largest Armenian companies importing Russian gold in 2024

Hetq contacted several companies involved in the Armenian gold trade. Conversations with their representatives revealed a general reluctance to discuss issues such as the gold trade, sanctions risks, and cooperation with Russia and the West.

For example, a person who identified himself as the director of TB Arm, the largest gold importer and exporter in Armenia, said on behalf of co-owner Armen Tadevosyan that the company would not comment on its operations.

Anahit Chitchyan, owner of Diamond Standard, the country's second-largest gold importer, insisted that her company had operated strictly within the law from 2022 to 2024, complying with its licenses and being fully transparent in its reporting. However, she declined to provide further details, noting only that Diamond Standard has been inactive for the past six months.

Win-Gold director Zohrab Toroyan also pointed to inactivity, telling Hetq that the company has not operated for close to three months. He added that Win-Gold and GG-Group, owned by Gor Sharyan and registered in the town of Abovyan in Armenia’s Kotayk Province, have been exporting unprocessed gold.

Imported gold doesn't stay in Armenia

It can be assumed that the sizable Russian gold imports could be used to make jewelry — but this seems unlikely given the numbers. In 2020, Armenia's jewelry exports amounted to $26 million. In 2021, they grew to $75 million, and the upward trend continued — to $109 million in 2022 and $499 million in 2023. Obviously, Armenia's jewelry industry experienced remarkable growth in the early 2020s, increasing 1.5 to 2-fold annually. However, it seems highly implausible to suggest that it would then grow nearly 100-fold between 2022 and 2024 (assuming that gold imports in 2024 were intended exclusively for the jewelry sector).

Imported gold does not stay in Armenia — neither in the form of jewelry nor in the country’s banks. It is exported. According to State Revenue Committee (SRC) data obtained by Hetq, gold was shipped mainly to the United Arab Emirates in 2023. Moreover, Armenian customs data shows a record volume of gold exports in the first half of 2024 — close to 59 tons, valued at $4.1 billion. Apart from the UAE, smaller quantities were exported to Hong Kong and China.

Imported gold does not stay in Armenia — neither in the form of jewelry nor in the country’s banks.

The SRC identified Diamond Standard, Golden Line, Win-Gold, Bagario Gold, and TB Arm as the main companies exporting gold in 2023-2024. This means that some exporters are also importing gold.

Hetq has previously reported that Golden Heritage was one of the largest gold exporters in Armenia — an investigation by the outlet published in May 2020 revealed that Golden Heritage was exporting significant amounts of gold from the country. In a subsequent interview with Hetq, the company's owner revealed that the firm imported gold from Switzerland and shipped it to Russia. By 2022, the company had shifted to importing Russian gold and exporting it to Turkey.

Bypassing duties and trading for cash

Payments worth billions of dollars, required if gold were sold in banks for foreign currency, would have likely triggered suspicions. Additionally, due to international sanctions, Russia — being the ultimate recipient of such payments — would face the obvious problem of using these currencies to purchase other goods.

Meanwhile, data from the Observatory of Economic Complexity (OEC) highlights a comparable inflow of receipts to Armenia for a category that includes “cash” and “bonds.” In 2022, such imports totaled $1.45 billion — all originating from the UAE. This could potentially indicate the transfer of cash from the United Arab Emirates to Armenia.

Economist Aghasi Tavadyan notes that Russian businesses have utilized Armenia as a transit point for gold exports in order to avoid Russia's customs duty on gold. This duty does not apply to exports within the Eurasian Economic Union, which Armenia joined in 2015.

“Russian businessmen would first transport gold to Armenia and then re-export it to the Emirates. They benefited from the arrangement, as Armenia doesn’t impose export duties on gold,” Tavadyan explains.

Response from Armenia's Ministry of Economy

In response to an inquiry by Hetq, the Armenian Ministry of Economy acknowledged that the export of Russian gold under the embargo could render Armenia vulnerable to secondary sanctions. However, the Ministry's Secretary General Haykaz Nasibyan stressed that no such cases have been recorded so far.

The export of embargoed Russian gold could expose Armenia to secondary sanctions.

“The development of the situation is constantly monitored by the Ministry of Economy of Armenia in order to react flexibly to changes,” Nasibyan said, adding that the ministry is convinced of the effectiveness of the monitoring tools introduced by the government.

Data from Armenia’s Statistical Service indicate a sharp drop in gold imports and exports from May 2024, following a peak earlier in the year. In April, Armenia exported 14.3 tons of gold, but the figure dropped sharply — to 3.7 tons in May.