The European Union intends to add the Russian Federation to its “blacklist” of countries with the highest level of risk in the field of money laundering and terrorist financing. Politico writes about this with reference to two European officials and a draft document that the publication has reviewed.
So far, the FATF, an international anti—money laundering group, has only suspended Russia’s membership after its armed aggression against Ukraine. Despite calls from a number of countries, Russia has not been included in either the FATF’s “grey” or “black” lists, mainly due to resistance from states affiliated with Moscow and members of the BRICS alliance.
The situation in the EU has changed after the creation of its own supervisory authority, the European Anti—Money Laundering Agency (AMLA). The new body has the authority to create an autonomous list of high-risk countries and can act independently of the FATF.
Earlier, the European Parliament has repeatedly demanded that the European Commission go beyond the FATF position. The Commission promised to conduct an assessment by the end of 2025, and now a draft decision on Russia’s inclusion in its “black” category has appeared in the appendix to the updated list of EU countries.
If the decision is approved, EU banks and financial institutions will be required to apply enhanced supervision to any transactions involving Russian clients.
What does it mean
In the event of a final decision to include Russia in the list of high-risk jurisdictions for EU citizens who simultaneously hold Russian citizenship, financial controls may be strengthened in accordance with the requirements of the AMLD5 and AMLD6 directives, as well as the guidelines of the European Banking Authority (EBA).
In this case, Russian citizenship will be considered by banks as an increased risk factor, although the status of a citizen of an EU member state remains decisive in terms of their rights in the country of residence.
In practice, this may mean more detailed inquiries about the origin of funds, enhanced due diligence for large or atypical transactions, and a more thorough analysis of cross-border transfers. This will especially apply to transactions related to the Russian Federation. In some cases, banks may revise the terms of service or restrict access to individual products if the overall risk to the customer is considered increased.
It is important to note that such measures do not cancel the legal status of EU citizens. They only determine how banks should conduct inspections and assess risks during operations.
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