Armen Tumanyan
The article provides a critical comparative, technical and legal analysis of the anti-corruption legislation of the Russian Federation and the Republic of Armenia. The author examines the evolution of international legal standards from early UN documents and the 1999 Council of Europe Convention to the 2003 UN Convention, revealing the dichotomy between mandatory and discretionary criminalization approaches. The primary focus is placed on a critical review of Annex 1 to the Criminal Code of the Republic of Armenia (2021). It is argued that in the absence of a legal basic definition of corruption, the incorporation of ordinary criminal property offenses (such as fraud and extortion) into this Annex constitutes a legislative defect aimed at the «simulation of anti-corruption productivity» and artificial workload generation for specialized courts. Architectural defects within the Criminal Code of Armenia are identified, specifically the complete absence of cross-reference norms to Annex 1. To resolve this doctrinal deadlock, the author substantiates the urgent need to adopt a comprehensive fundamental law of the Republic of Armenia «On Combating Corruption».