$5BRUSSIAN GOLD LAUNDERED THROUGH ARMENIA, 2023-2024
78.125%TROTSENKO'S RETAINED CONTROL OF ZCMC
$27.3MANIF PUBLIC MONEY WASTED OR STOLEN
ZeroDOMESTIC SANCTIONS-ENFORCEMENT CASES UNDER PASHINYAN

Sukiasyan, 'Pashinyan's Wallet,' and the Russian Gold Pipeline

Khachatur Sukiasyan -- known by his nickname "Grzo" -- is a sitting Civil Contract MP, elected in 2021, who controls the SIL Group business empire: Armeconombank (71 percent), Bjni mineral water, SIL Plaza Hotel, FlyOne Armenia (50 percent via brother Eduard), Ran-Oil / Mega Trade LLC, and a constellation of related vehicles. The Russian-language Armenian and Russian-opposition press consistently describes him as "Pashinyan's wallet" -- the principal private-sector financial counterparty of the ruling party.

Between 2023 and the first five months of 2024, Armenia's gold imports from Russia rose from $1 billion (17 tonnes) to $4 billion (68 tonnes). The gold was sourced from approximately 30 Russian companies, processed at the Yerevan Jewelry Factory (Sukiasyan-linked, per The Insider investigative reporting), and re-exported as "Armenian-origin" gold. None of it remained in Armenia. The structure is a textbook sanctions-laundering operation: Russian gold blocked from Western markets by post-2022 sanctions enters Armenia, receives an Armenian certificate of origin, and exits to global markets sanctions-clean.

The Russian FSB in 2025 accused Sukiasyan of benefiting separately from stolen Alrosa diamonds through ADM Diamonds. An $11 million Ministry of Defence fuel-supply contract went to a Sukiasyan-connected firm. He also imported Azerbaijani gasoline via Ran-Oil (22 railcars, 1,300 tonnes) -- politically explosive given Yerevan-Baku relations.

Trotsenko, ZCMC, and the OFAC Question

Roman Trotsenko was sanctioned by US OFAC in November 2023, by the UK FCDO in February 2025, and by the EU, Canada, Switzerland, Belgium, Ukraine and the UN. He is an adviser to Rosneft chief executive Igor Sechin, one of Vladimir Putin's closest political and business allies. He controls 78.125 percent of the Zangezur Copper-Molybdenum Combine -- ZCMC -- Armenia's largest mine, generating $724 million in revenue in 2024, through a Cyprus shell (Neo Metals Holding Ltd) feeding into cascading offshore LLCs. He also owns the Sotk gold mine.

In 2022, in a much-publicised gesture, Trotsenko cosmetically "donated" 15 percent of ZCMC to the Armenian government, with the shares received via the Armenia National Interests Fund (ANIF). The structural reality of the transaction: Trotsenko remained the controlling shareholder at 78 percent, ANIF received minority shares without operational control, and the Pashinyan government accepted those shares from an individual who would be US-OFAC-sanctioned within months. ZCMC's reported tax payments to the Armenian state subsequently dropped approximately 50 percent despite rising international copper prices.

There is no domestic Armenian enforcement action against Trotsenko. There is no nationalisation. There is no anti-Russia investigative prosecution.

ANIF Took Shares From an OFAC-Sanctioned Russian

The Armenia National Interests Fund was created by the Pashinyan government in 2019 as a sovereign-wealth vehicle. It was dissolved in August 2025. The dissolution audit, partially exposed in OWL's prior coverage of former Deputy Prime Minister and now Yerevan Mayor Tigran Avinyan, found at least $27.3 million in public money wasted or stolen: $6.9 million transferred to a "Moscow branch" with zero documentation, $3.8 million to CFW CJSC (Delaware-shell company, director identified as a business partner of Avinyan's wife), and a cascade of smaller transactions to companies created days before they received state funds.

ANIF's executive director, Davit Papazyan, is currently under an Armenian international arrest warrant; he is reported to be in London. Avinyan himself has never been charged. The Trotsenko ZCMC shares were the largest single asset ever placed under ANIF's nominal control. ANIF accepted them. The Pashinyan government accepted ANIF's acceptance. The chain of acceptances ends at the Office of the Prime Minister, which has not provided a public rationale for taking custody of OFAC-blocked assets.

Karapetyan: Why This Prosecution Is the Exception

Samvel Karapetyan made his fortune in Russia. The Tashir Group built its asset base around Gazprom-adjacent commercial real estate in Russian regional cities. He was named on the US Treasury 2018 "Kremlin List" of 210 individuals close to Vladimir Putin. His aircraft was OFAC-sanctioned in 2022. Ukraine's NSDC sanctioned him. France seized a EUR 120 million villa on the Riviera in February 2024 -- purchased in 2010 via a EUR 115 million Gazprombank loan, held inside a Maritime Villa Holding SNC shell.

He was also, until June 2025, the owner of Electric Networks of Armenia. The Pashinyan government nationalised ENA and arrested him. He is currently leading the Prime Minister in pre-election polling from house arrest -- 34 percent to Pashinyan's 33 percent.

The Karapetyan prosecution can be read in two ways. Read one: a real de-Russification campaign that started with the largest Russian-tied Armenian oligarch. Read two: the selective elimination of the only candidate polling within one point of the sitting Prime Minister, with the Russia framing as the available legal vehicle. The decisive evidence in favour of read two is the survival, undisturbed, of Sukiasyan, Trotsenko, and the ANIF channel. A real de-Russification campaign would not leave the $5 billion gold-laundering pipeline, the OFAC-sanctioned majority owner of the largest mine, and the sovereign-wealth fund that accepted his shares.

Pattern Comparison -- Ukraine, Moldova, Georgia, Armenia

Ukraine, after 2014: oligarch denationalisation law (Zelensky 2021), Kolomoyskyi prosecuted, Akhmetov restricted. Moldova: Plahotniuc fled and is wanted internationally, Shor convicted in absentia, Russian-tied parties (PCRM, Shor) banned from contesting. Georgia: the opposite drift -- Bidzina Ivanishvili, whose wealth originates entirely from Russian commodity trading in the 1990s, increasingly dominant.

Armenia under Pashinyan looks closer to Georgia than to Ukraine or Moldova. One headline prosecution. Zero structural enforcement. A Civil Contract MP running a multi-billion-dollar Russian sanctions-laundering pipeline through the country. The largest mine remaining under an OFAC-sanctioned Russian. The constitutional pivot away from Russia is happening in the speech layer of Armenian politics. In the capital-flows layer, the pivot has not happened.

Sources: OC Media (Karapetyan dossier) · Hetq, en/article/164455 (Karapetyan) · The Insider, Sukiasyan gold pipeline · Hetq, en/article/171035 (Sukiasyan/SIL Group) · OpenSanctions API (Trotsenko, Sukiasyan, Karapetyan) · US Treasury OFAC SDN list · Interfax (ZCMC, ENA nationalisation)