In Russia, entities falling within the categories of banks, money transfer businesses, leasing firms, investment and securities enterprises, as well as insurance companies, are regulated entities subject to Anti-Money Laundering (AML) obligations. In accordance with Russia’s AML regulations, these establishments are mandated to ascertain the identity of their clients and identify transactions that exhibit characteristics of potential financial crimes. Under the purview of these regulations, regulated entities are compelled to institute an AML program and internal control mechanisms as a means of ensuring their adherence to the stipulated guidelines. Furthermore, they are required to designate AML compliance officers and provide ongoing training to these personnel. The duty of these compliance officers includes the reporting of suspicious transactions to the Federal Service for Financial Monitoring.

Entities operating under the Anti-Money Laundering obligation are obligated to promptly report customer transactions involving a minimum of 600,000 Russian Rubles (approximately 8,000 Euros) in either cash or non-cash forms. Additionally, real estate asset transactions involving a minimum of 3 million Russian Rubles (about 40,000 Euros) must also be reported to the financial intelligence unit. Furthermore, these entities are tasked with identifying Politically Exposed Persons (PEPs) and notifying supervisory bodies of any irregular financial transactions associated with PEPs.

Within the framework of Russia’s AML regulations, the gravest consequences are reserved for individuals found guilty of committing financial crimes. Paradoxically, organizations mandated to undertake Anti-Money Laundering (AML) checks, if they fail to execute them, inadvertently facilitate the occurrence of financial crimes. Russia, in a bid to avert such outcomes, issues admonitions to companies falling short of their AML obligations, urging them to rectify their course and ensure full AML compliance. Entities failing to attain AML compliance expose themselves to a gamut of penalties, encompassing fines and administrative sanctions, which in turn jeopardize the validity of their licenses. Consequently, entities subject to AML obligations must adopt requisite measures to insulate themselves from the risks of financial penalties and the potential revocation of licenses.