Évaluation mutuelle de la Russie

Russia has in a short time (since 2003) implemented and enhanced its AML/CFT system and has done so in less time than many other countries.

The FIU (Rosfinmonitoring) is to be commended for performing the traditional tasks of an FIU in full compliance with the FATF Standards, as well as many other tasks, including serving as the central responsible agency for AML/CFT matters. Authorities should ensure that policy reviews and risk assessments by Rosfinmonitoring are followed up and implemented without delay by other government bodies.

The implementation of Recommendation 33 and Special Recommendations III, VI, VIII and IX is lacking, especially given the most important money laundering and terrorist financing techniques that Russia currently faces.

The systems for record keeping and suspicious transaction reporting are generally sound and in line with the FATF Standards. Improvements in the customer due diligence area should be made. The money laundering and terrorist financing offences are almost fully in line with the FATF Standards, but Russian authorities should endeavour to increase the number of investigations/prosecutions for these offences.

Russia should review and update all its supervisory laws and practices.  None of the supervisory authorities in Russia currently possesses an adequate level of (sanctioning) powers, and criminal ownership of financial institutions is not specifically prohibited. Only the Bank of Russia is to be commended for performing its tasks at an acceptable level despite the lack of legal tools.  Progress by the Russian Federation in addressing these issues should be monitored.

International co-operation by the Russian Federation is generally sound, based on practical mechanisms and supported by numerous treaties.  Russia and Rosfinmonitoring in particular should also be commended for their support to the Eurasian Group and for taking a leadership role in the Eurasian region on AML/CFT matters.