The Federal Financial Monitoring Service (“the FFMS”) is the main AML/CTF Supervisory authority in Russia. Their role is to conduct financial intelligence investigations, collect data, and monitor transactions of controlled entities in accordance with the AML law.
As one of the key participants in the Russian AML/CTF system, the CBR regulates the activities of credit institutions and non-credit financial institutions. One of the most important tasks of the CBR is the reduction of the level of money laundering and financing terrorism risk in the financial sector.
The AML law in Russia contains a limited list of legal entities in transactions with money and other assets falling under the regulation of the AML law. This list includes financial institutions such as banks and non-banking credit institutions, professional participants of the securities market, insurance and leasing companies, postal and other non-credit institutions that deal with money transmission.
According to Russia’s AML regulations, if you are a reporting entity you must identify your customer and have mechanisms in place to detect suspicious transactions that may be financial crimes.
In addition to the obligation to identify the client as a reporting entity you are also obliged to monitor your clients’ transactions for suspicious activities, take steps to freeze suspicious assets (when required) and develop and implement internal regulations and procedures.
The AML regulations also require you to develop and implement your own internal risk assessment programs, based on FFMS recommendations for development of criteria for identification and determination of unusual transactions. There is a requirement for you to implement the AML and internal control programs to ensure that your organisation is compliant. The employment of AML Compliance Officers is also required together with the training of employees regularly.
Several CBR regulations establish requirements for internal control and client identification procedures for credit institutions.
AML Compliance Officers must report suspicious transactions to the Federal Service for Financial Monitoring. The financial institutions that are subject to AML obligations are required to report at least 600,000 RUB (8,000 EUR) cash or non-cash customer transactions to the financial intelligence unit. In addition, organisations must detect politically exposed person’s (“PEPs”) and report unusual financial transactions of PEPs to supervisory units.
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* This page is intended as general information only and should not be relied on as the sole source of information for your AML obligations and AML program. Please visit your local regulatory authority sites for the latest relevant and full information.