Not every instrument is backed by its official text yet. At least one law or rulebook covered here has no official source (tier 1) retrieved for it yet. No finding on this page is shown with confidence above “Probable” until stronger sources are retrieved.

Financial Integrity Monitor

Russia RU

Domains (D1–D6)

Sources

Role actions

Horizon <90d

Jurisdiction profile

Grey-ListTier ARisk: IncreasingEnabler

Russia's FATF membership has been suspended since 24 February 2023; it remains bound to implement FATF Standards nominally but retains active membership only in the Eurasian Group (EAG).

Its FIU (Rosfinmonitoring) is directly subordinated to the presidency and has unilaterally curtailed cooperation with 'unfriendly' states, per the EU Council's December 2025 technical assessment. Beneficial-ownership reforms have increased, not reduced, structural opacity.

Key deficiencies

FIU lacks independence, subordinated directly to the presidency
Unilateral restriction of AML/CFT cooperation with 'unfriendly' jurisdictions (most EU/G7 states)
Beneficial-ownership reforms have increased systemic opacity rather than transparency
State-directed shadow fleet and crypto-settlement infrastructure functioning as sanctions-evasion architecture
Last full FATF/EAG mutual evaluation dated 2019, now materially stale given wartime economic transformation

Recent developments (18m)

FATF reaffirmed suspension of Russian membership at February 2026 and June 2026 plenaries, citing growing financial connectivity with DPRK and Iran and proliferation-financing risk
European Commission added Russia to the EU AML high-risk third country list via Delegated Regulation (EU) 2026/46 (3 December 2025) under a bespoke category for FATF-suspended jurisdictions
OFAC designated Rosneft and Lukoil (22 October 2025), triggering a cascade of general licenses managing Lukoil's international divestment
EU adopted its 20th sanctions package (23 April 2026) imposing a total sectoral ban on Russian-established crypto-asset service providers and DeFi platforms, effective 24 May 2026
Garantex-Grinex crypto-laundering ecosystem repeatedly disrupted and re-formed (Garantex seizure March 2025; Grinex sanctioned across OFAC/UK/EU through 2025; Grinex operational collapse April 2026)

Brief

Lead signal

Lead Signal

Read full brief

Lead Signal

The European Union has layered a new architecture onto its sanctions posture toward Russia this cycle. Commission Delegated Regulation (EU) 2026/46, in force from 29 January 2026, adds Russia to the Annex of Delegated Regulation (EU) 2016/1675 as a high-risk third country under Article 9 of Directive (EU) 2015/849, triggering mandatory enhanced due diligence under Article 18a. This is a distinct mechanism from the FATF grey or black lists, created specifically to address jurisdictions whose FATF membership has been suspended for gross violation of core principles rather than jurisdictions still subject to ordinary FATF listing processes. Russia remains suspended from FATF membership since 24 February 2023, without a plenary reversal to date, while continuing to hold membership in the Eurasian Group, a FATF-style regional body. The EU 21st sanctions package, adopted 23 July 2026, added 216 new designations covering 48 individuals and 168 entities, and extended transaction bans to 33 additional Russian credit and financial institutions along with 4 non-EU banks and 14 non-EU crypto-asset service platforms, with a board-membership ban extended to any crypto-asset services business from 25 August 2026.

Other Developments

Russia's domestic crypto-market formalisation proceeded on a parallel track. Federal Law No. 282-FZ took effect on 1 September 2026, establishing a Bank of Russia-supervised licensing regime for crypto exchanges and digital depositories, while retaining the existing domestic ban on using cryptocurrency as payment for goods and services. Critically, the separate 223-FZ experimental-legal-regime channel, which permits digital financial assets and digital currency as consideration under qualifying cross-border trade contracts for sanctioned counterparties, was preserved rather than closed. Read against the EU's own sanctions-package recitals, which characterise this channel as sanctions-evasion-oriented, Russia's crypto-market formalisation is best understood as a dual-track policy: domestic consumer-protection architecture paired with continued sanctions-resilience infrastructure for foreign trade settlement. A structural friction point emerged within the EU sanctions-maintenance process itself. On 14 September 2026, the EU failed to extend its six-monthly asset-freeze regulation on schedule after Slovakia demanded the delisting of Alisher Usmanov and Mikhail Fridman, requiring a one-week extension to negotiate the rollover under the unanimity requirement that governs EU sanctions renewal. This is the first sign this cycle of EU-internal sanctions-maintenance friction, as distinct from the pattern of continued external designation activity that has otherwise characterised the EU's approach.

Cross-Monitor Connections

The 223-FZ cross-border settlement channel and the new Bank of Russia crypto-licensing regime under Federal Law No. 282-FZ connect directly to the crypto monitor's tracking of Russia's licensing architecture, and to the world-payments monitor's tracking of correspondent-banking access narrowing under the EU 21st sanctions package. The enablement-versus-enforcement framing is instructive here: Russia is simultaneously tightening its domestic crypto-market governance (an enforcement-coded signal domestically) while preserving a channel explicitly identified by EU counterparts as enabling sanctions evasion (an enablement-coded signal externally). This is architecture, not incident, and should be read as such by both monitors.

Outlook

The Slovakia-driven delay to the EU's asset-freeze rollover is the clearest near-term marker: whether the negotiated one-week extension results in a full renewal, a partial delisting of specific high-profile individuals, or a further delay will signal whether EU sanctions-maintenance unanimity is becoming a structurally recurring vulnerability rather than an isolated episode. Separately, whether the EU moves to directly target the 223-FZ experimental-legal-regime channel in a future sanctions package, following its already-stated characterisation of that channel as sanctions-evasion-oriented, is the marker to watch on the crypto/sanctions intersection.

weekly_brief_draft · JID RU

Domain intelligence (D1–D6)

D1 Sanctions Architecture and Evasion

Sanctions Architecture and Evasion

The EU has built a two-layer architecture toward Russia this cycle. The first layer is the AML/CFT high-risk-third-country designation under Commission Delegated Regulation (EU) 2026/46, in force from 29 January 2026, which added Russia to the Annex of Delegated Regulation (EU) 2016/1675 under Article 9 of Directive (EU) 2015/849, triggering mandatory enhanced due diligence under Article 18a. This designation was created specifically because Russia's FATF status is suspended rather than formally grey- or black-listed, meaning the ordinary FATF-list-driven EDD trigger does not apply and a distinct EU mechanism was needed to fill the gap. The second layer is the sanctions-designation architecture proper: the EU's 21st sanctions package, adopted 23 July 2026, added 216 new designations (48 individuals, 168 entities), extended transaction bans to 33 additional Russian credit and financial institutions and 4 non-EU banks, and extended transaction bans to 14 non-EU crypto-asset service platforms, with a board-membership ban applying to any crypto-asset services business from 25 August 2026. Structurally, this represents the sanctions-designation perimeter continuing to widen outward toward third-country intermediaries and crypto-asset venues rather than remaining confined to direct Russian counterparties.

A distinct signal this cycle is internal to the EU's own sanctions-maintenance machinery rather than external designation activity. On 14 September 2026, the EU failed to extend its six-monthly asset-freeze regulation on schedule after Slovakia demanded the delisting of Alisher Usmanov and Mikhail Fridman, requiring a one-week extension to negotiate the rollover under the unanimity requirement governing EU sanctions renewal. This is the first sign this cycle of friction in the EU's sanctions-maintenance process itself, as distinct from the pattern of continued external designation activity that otherwise defines the architecture. The unanimity requirement is a structural feature of EU sanctions renewal, and this episode illustrates a live risk that individual Member States can leverage that requirement to force partial delisting or non-renewal, independent of any change in the underlying merits of a given designation.

Outlook

Whether the Slovakia-driven negotiation results in full renewal, partial delisting of the two named individuals, or a further delay is the immediate marker to watch. More structurally, whether this episode proves to be an isolated instance of Member-State leverage or the first of a recurring pattern under the unanimity requirement will shape how durable the EU's sanctions-maintenance architecture proves to be against Russia going forward.

D2 Beneficial Ownership

Not covered

Beneficial Ownership is not yet covered for this jurisdiction in this report.

D3 Enabler Jurisdictions

Not covered

Enabler Jurisdictions is not yet covered for this jurisdiction in this report.

D4 Conflict Finance

Not covered

Conflict Finance is not yet covered for this jurisdiction in this report.

D5 Crypto / Digital Assets / Financial Innovation

Crypto / Digital Assets / Financial Innovation

Russia's Federal Law No. 282-FZ took effect on 1 September 2026, establishing a Bank of Russia-supervised regime for crypto exchanges and digital depositories. This is a formal licensing architecture rather than an informal tolerance of crypto activity, and it retains the pre-existing domestic ban on using cryptocurrency as payment for goods and services. Read in isolation, this looks like conventional domestic market formalisation. Read alongside the preserved 223-FZ experimental-legal-regime channel -- which permits digital financial assets and digital currency as consideration under qualifying cross-border trade contracts for sanctioned counterparties -- a different picture emerges. The EU's own sanctions-package recitals characterise this cross-border settlement channel as sanctions-evasion-oriented, and the fact that Russia chose to formalise domestic crypto-market supervision while explicitly preserving rather than closing the cross-border channel suggests a dual-track policy: consumer protection and market order domestically, continued sanctions-resilience infrastructure for foreign trade externally.

The EU's own posture toward this dynamic has hardened in parallel. The EU 21st sanctions package extended transaction bans to 14 non-EU crypto-asset service platforms and introduced a board-membership ban applying to any crypto-asset services business from 25 August 2026, effectively narrowing the pool of crypto-asset intermediaries willing or able to service Russian-linked cross-border settlement without exposure to EU sanctions risk. Confidence in the precise mechanics of Federal Law No. 282-FZ is held at Probable rather than Confirmed, reflecting that no direct Bank of Russia primary regulation text for the omnibus statute was retrieved this cycle; the claim rests on multiple T3/T4 secondary sources corroborating the State Duma final reading and TASS reporting.

Outlook

The key marker to watch is whether the EU moves in a future sanctions package to directly target the 223-FZ experimental-legal-regime channel itself, rather than the crypto-asset intermediaries that service it, given the EU's recitals have already characterised the channel as evasion-oriented. A second marker is whether primary Bank of Russia regulatory text for Federal Law No. 282-FZ becomes available, which would allow the domestic licensing architecture to be assessed with Confirmed rather than Probable confidence.

D6 Compliance Technology & Active Defence

Not covered

Compliance Technology & Active Defence is not yet covered for this jurisdiction in this report.

D7 AML/CTF Regime

AML/CTF Regime

Russia's FATF membership has remained suspended since 24 February 2023 for gross violation of FATF core principles, with no plenary reversal to date. Russia remains a member of the Eurasian Group, a FATF-style regional body, and remains accountable for implementing FATF Standards notwithstanding its suspended FATF membership status itself. This baseline fact is unchanged this cycle but is reasserted here because it is the structural precondition for understanding why the EU needed to construct a separate mechanism this cycle: the EU's new AML/CFT high-risk-third-country designation for Russia, effected through Commission Delegated Regulation (EU) 2026/46 in force from 29 January 2026, was created specifically because Russia's suspended (rather than formally grey- or black-listed) FATF status places it outside the ordinary FATF-list-driven EDD trigger mechanism that the EU's own AML framework otherwise relies upon.

The designation adds Russia to the Annex of Delegated Regulation (EU) 2016/1675 under Article 9 of Directive (EU) 2015/849, triggering mandatory enhanced due diligence for obliged entities under Article 18a. This is a distinct architectural layer, not a substitute for or a re-statement of the FATF suspension: the two operate on separate legal bases, with separate triggering mechanisms, and obliged entities subject to EU AML law now face a mandatory EDD obligation toward Russian counterparties that did not exist under the FATF-suspension fact alone. The practical effect for obliged entities -- banks, investment firms, and cross-sector obliged entities under EU AML law -- is that Russia now sits within the EU's own high-risk-third-country EDD perimeter on a standalone basis, independent of whatever FATF eventually decides about Russia's suspended membership.

Outlook

The principal marker to watch is whether FATF's plenary process moves toward any change in Russia's suspended-membership status; absent that, the EU's own high-risk-third-country designation is likely to remain the operative AML/CFT trigger mechanism for obliged entities dealing with Russian counterparties. A second marker is whether other jurisdictions adopt an analogous standalone high-risk-third-country mechanism for FATF-suspended (as opposed to grey-listed) jurisdictions, which would suggest the EU's approach here is becoming a template rather than a one-off response to Russia's specific circumstances.

D8 Commercial Activity

Not covered

Commercial Activity is not yet covered for this jurisdiction in this report.

Regulatory horizon

Consultation2026-Q4 · ±quarter

EU asset-freeze rollover contested by Slovakia over Usmanov/Fridman delisting

Possible delisting of specific high-profile Russian nationals from EU asset-freeze annexes pending negotiated outcome.

Source

1 dated · 5 pending date · baseline fim-2026-07-05

Role action cards

MLRO

Russia now sits within a standalone EU high-risk-third-country EDD perimeter, distinct from and additional to the pre-existing FATF suspension.

MLROs at EU-obliged entities must apply mandatory enhanced due diligence to Russian counterparties under Article 18a of Directive (EU) 2015/849 as a freestanding trigger, independent of whatever FATF eventually decides about Russia's suspended membership status.

2 evidence refs

Compliance

EU 21st sanctions package widened transaction bans to non-EU banks and crypto-asset platforms, narrowing the pool of compliant counterparties for Russia-linked business.

Compliance functions should note that screening obligations now extend to 4 non-EU banks and 14 non-EU crypto-asset service platforms newly subject to transaction bans, alongside 33 additional Russian credit and financial institutions.

1 evidence refs

Legal

The EU's asset-freeze rollover for specific named Russian individuals was delayed after a Member State objection, testing the unanimity requirement.

Legal counsel advising on sanctions exposure should treat the Usmanov/Fridman delisting negotiation as a live illustration that EU designations are not necessarily stable across renewal cycles under the unanimity requirement, which has implications for continuity-of-exposure assessments.

1 evidence refs

Board

Russia's overall financial-crime risk direction is assessed as deteriorating, driven jointly by expanding EU designation architecture and Russia's own crypto-market sanctions-resilience infrastructure.

The Board should note that this deterioration is structural (widening designation and due-diligence architecture) rather than a single incident, and that it is coupled with continued Russian state action explicitly aimed at cross-border sanctions resilience.

3 evidence refs

CTO

Russia's new CBR-supervised crypto exchange/depository regime coexists with a preserved cross-border settlement channel the EU treats as sanctions-evasion-oriented.

Technology functions overseeing crypto-asset infrastructure or screening tooling should note the dual-track nature of Russia's crypto architecture: domestic licensing formalisation under Federal Law No. 282-FZ alongside the unaltered 223-FZ cross-border settlement channel, which the EU's 21st sanctions package has responded to by extending transaction bans to non-EU crypto-asset platforms.

2 evidence refs

Risk

A new structural vulnerability in EU sanctions-maintenance (the unanimity-driven rollover delay) is an emerging risk signal distinct from the established pattern of designation expansion.

Risk functions should track whether the Slovakia-driven delay recurs in future renewal cycles, as a recurring pattern would represent a structural weakening of sanctions-regime durability that is analytically distinct from, and additive to, exposure arising from continued designation expansion.

1 evidence refs

Operations

No material change this cycle.

No material change for this persona this cycle

Audit

Confidence on Russia's crypto-market licensing architecture (Federal Law No. 282-FZ) is held at Probable pending retrieval of primary Bank of Russia regulatory text.

Internal audit should note that current documentation of Federal Law No. 282-FZ's mechanics rests on T3 secondary corroboration rather than a Tier-1 primary source, which should inform the audit trail's evidentiary basis until primary text is retrieved.

1 evidence refs

Decision lens

MLRO

Russia now sits within a standalone EU high-risk-third-country EDD perimeter, distinct from and additional to the pre-existing FATF suspension.

Compliance

EU 21st sanctions package widened transaction bans to non-EU banks and crypto-asset platforms, narrowing the pool of compliant counterparties for Russia-linked business.

Legal

The EU's asset-freeze rollover for specific named Russian individuals was delayed after a Member State objection, testing the unanimity requirement.

Board

Russia's overall financial-crime risk direction is assessed as deteriorating, driven jointly by expanding EU designation architecture and Russia's own crypto-market sanctions-resilience infrastructure.

CTO

Russia's new CBR-supervised crypto exchange/depository regime coexists with a preserved cross-border settlement channel the EU treats as sanctions-evasion-oriented.

Risk

A new structural vulnerability in EU sanctions-maintenance (the unanimity-driven rollover delay) is an emerging risk signal distinct from the established pattern of designation expansion.

Operations

No material change this cycle.

Audit

Confidence on Russia's crypto-market licensing architecture (Federal Law No.

Shared evidence: 4 refs

Scenario sketches

Illustrative pathway: EU unanimity requirement as a recurring sanctions-maintenance vulnerability

Illustrative orientation only. One possible trajectory sees the Slovakia-driven delay to the EU's asset-freeze rollover as the first of a recurring pattern in which individual Member States use the unanimity requirement governing sanctions renewal to force renegotiation of specific designations. Under this illustrative scenario, successive renewal cycles could see additional Member States leverage the same procedural lever, gradually eroding the EU's capacity to maintain designations without periodic re-negotiation. This is architecture-level illustration, not a prediction of how the current Usmanov/Fridman negotiation will resolve.

Illustrative scenario for analytical orientation only. Not compliance advice, not a prediction, and not a statement of observed fact.

Illustrative pathway: EU AML Package / AMLA transition and cross-border obliged-entity supervision

Illustrative orientation only. As the EU AML Package matures -- comprising the directly applicable AML Regulation (AMLR, Reg (EU) 2024/1624), the sixth AML Directive (6AMLD) transposed per Member State, and the AMLA Regulation (Reg (EU) 2024/1620) establishing the Anti-Money Laundering Authority -- supervision of cross-border obliged entities could shift from a purely national-authority model toward a hybrid EU-level regime with AMLA exercising direct or indirect supervision. One illustrative implication for Russia-exposed obliged entities is that a future AMLA-supervised entity handling the kind of high-risk-third-country EDD obligations Russia now triggers under Commission Delegated Regulation (EU) 2026/46 could face harmonised EU-level supervisory expectations rather than divergent national-regulator interpretations. This is architecture-over-incident illustration of a structural transition, not an observed development this cycle.

Illustrative scenario for analytical orientation only. Not compliance advice, not a prediction, and not a statement of observed fact.

Standing trackers (T1–T6)

Tracker	Status	Note
T1 · Russian Sanctions-Evasion Architecture	escalating	EU 21st package added 33 Russian banks to the transaction ban (eff. 13 Aug 2026), extended to financial-messaging use; UK added 31 new designations 1 Oct 2026.
T2 · EU AML Package / AMLA	no_change	AMLR/6AMLD/AMLA do not apply to Russia (non-EEA); EU high-risk-third-country EDD designation (Reg 2026/46) remains unchanged.
T3 · FATF Grey List	no_change	Russia's FATF membership remains suspended since 24 Feb 2023; not on grey or black list; no October 2026 plenary outcome published as of this run.
T4 · Beneficial-Ownership Register Status	no_change
T5 · Crypto & Digital-Asset Integrity	material_change	Federal Law No. 282-FZ and the digital-ruble mass rollout both took effect 1 September 2026; EU sanctions packages separately ban EU persons from the digital ruble, RUBx and A7A5 stablecoins.
T6 · Sanctions Regime Divergence	watch	EU and UK continue to diverge in pace and designee overlap; UK has not yet mirrored the EU's 21st-package bank transaction-ban expansion.

Registers

Enforcement actions

OFAC designated Russia's two largest oil producers to increase pressure on Russia's energy sector and degrade its capacity to fund the war, citing lack of serious commitment to a peace process. Multiple general licenses (124, 126-131 series) subsequently issued to manage wind-down and Lukoil's international divestment. 22 Oct 2025
EU's 20th sanctions package: 36 energy-sector listings, 46 additional shadow fleet vessels (632 total), transaction ban on 20 Russian banks plus 4 third-country institutions, total sectoral ban on Russian-established crypto-asset service providers/DeFi platforms, first-ever activation of the anti-circumvention tool, and port bans on Murmansk, Tuapse and Karimun (Indonesia). 23 Apr 2026
SGTL provided sanctioned Russian carrier Ural Airlines continued access to its Global Distribution System for seven months after designation, actively circumventing UK financial sanctions; case assessed 'most serious' due to lack of senior oversight and continued provision after breach identification. 26 May 2026
Bank of Scotland's automated sanctions screening system failed to detect a transliteration variant of a designated individual's name, resulting in prohibited payments processed through the account of a sanctioned individual. 1 Jan 2026
US law enforcement seized Garantex's servers and domains and unsealed an indictment against its administrators; OFAC froze approximately $26 million of the exchange's USDT holdings with Tether's assistance. Successor platform Grinex subsequently designated by OFAC in March 2025. 1 Mar 2025
UK sanctioned 18 crypto exchanges, banks and individuals — including HTX, suspected of channeling over $1.5bn to Russia through flows tied to Grinex and Garantex, and Kyrgyzstan's gold-backed stablecoin ecosystem — targeting the A7 network which reportedly moved $90bn into Russia's economy via crypto. 26 May 2026

Sanctions changes

OFAC designated Rosneft and Lukoil, the two largest Russian state-linked oil producers, under E.O. 14024, alongside a cascade of general licenses (GL 124A, 126-131 series) managing wind-down and Lukoil's international divestment. 22 Oct 2025
European Commission adopted Delegated Regulation (EU) 2026/46 (3 December 2025), adding Russia to the EU's AML/CFT high-risk third-country list under a newly-created category for jurisdictions whose FATF membership is suspended, triggering mandatory enhanced customer due diligence for EU obliged entities on Russia-linked business. 3 Dec 2025
EU's 20th sanctions package imposed a total sectoral ban on Russian-established crypto-asset service providers and decentralised platforms, and prohibited the RUBx ruble-backed stablecoin and the digital ruble CBDC. 23 Apr 2026
OFAC has repeatedly extended wind-down general licenses (GL 131A through 131G) authorizing negotiations for the divestment of Lukoil International GmbH (LIG) to non-blocked parties, most recently extending authorization to 2026-07-25. 17 Apr 2026
The Council renewed the EU's core Russia economic sanctions regime (Regulation 833/2014 and related instruments) for a further six months, extending the framework to 31 July 2026, requiring unanimous renewal by all 27 member states. 22 Dec 2025
OFAC has periodically removed individuals from Russia-related SDN designations as part of routine list maintenance (e.g., 18 March 2026 Russia-related designations removal), reflecting ongoing case-by-case re-assessment distinct from broad relief. 18 Mar 2026

Regulatory horizon (register)

Expiry of OFAC GL 131G Lukoil (LIG) divestment authorization
EU sanctions regime renewal deadline
EU ban on LNG terminal services to Russian entities
FATF October 2026 Plenary review of Russia suspension
Prospective EU maritime services ban on Russian crude/petroleum transport

Active schemes

[CRITICAL] Dark-fleet oil transport and insurance-evasion network
[CRITICAL] A7A5 ruble-stablecoin sanctions-evasion settlement rail
[HIGH] Third-country dual-use goods re-export corridor
[HIGH] Correspondent-banking and SPFS messaging workaround
[HIGH] Russia-DPRK crypto-enabled proliferation financing nexus

Sources

Coverage gaps

Shadow-fleet vessel recruitment has historically outpaced sa…

Shadow-fleet vessel recruitment has historically outpaced sanctions designations (e.g., 74 new vessels entering Russian crude trade in H1 2024 versus 49 tankers sanctioned in the same period), and Western shipowners continue reselling tankers into shell-company chains that ultimately supply the shadow fleet despite due-diligence obligations.

Sanctioned Russia-linked crypto exchanges reconstitute rapid…

Sanctioned Russia-linked crypto exchanges reconstitute rapidly under new corporate names and jurisdictions (Garantex to Grinex to Exved/MKAN Coin/TokenSpot), a pattern Transparency International Russia describes as a 'crypto hydra' that outpaces single-entity designation.

The EU's own technical assessment found that Russia's benefi…

The EU's own technical assessment found that Russia's beneficial-ownership transparency reforms over recent years have increased, rather than reduced, systemic opacity, undermining the ability of foreign counterparties and investigators to identify ultimate owners of Russia-linked corporate and vessel-owning structures.

The EU's autonomous HRTC listing of Russia (Dec 2025) is not…

The EU's autonomous HRTC listing of Russia (Dec 2025) is not mirrored by the UK's statutory HRTC mechanism, which is contractually tied only to the FATF's own two lists; because Russia's status is 'suspended' rather than 'grey/black-listed', it falls outside the UK's automatic enhanced-due-diligence trigger, producing inconsistent compliance obligations for firms operating across both jurisdictions.

No independent, current Russian national AML/CFT authority p…

No independent, current Russian national AML/CFT authority publication could be used as a native primary source for this baseline: Rosfinmonitoring is assessed by the EU Council as directly subordinated to the presidency and non-cooperative with 'unfriendly' states, and Russia's last full mutual evaluation dates to 2019 (pre-war, pre-suspension). This baseline instead relies on FATF/EAG multilateral first-party assessments of Russia and Western regulatory/enforcement primaries as the national-equivalent source floor.

Evidence

Confidence-tiered claims

Draft amendment to 115-FZ allowing banks to suspend operations for 5 working days on a partial name/DOB match to the extremist/terrorist list, consultation 9-24 Sept 2026 SRC-fim-RU-003

Probable · 1 source

282-FZ in force from 1 September 2026, formalising Bank of Russia-licensed crypto exchange/custody/trading intermediaries; preserves unlimited cross-border crypto settlement channel for exporters/importers SRC-fim-RU-010

Uncertain · 1 source

Draft mandatory reporting threshold of 60,000 rubles (single or cumulative) for crypto transactions, with wallet/name/address/INN data transmitted automatically SRC-fim-RU-011

Uncertain · 1 source

EU 21st sanctions package added 33 Russian banks to Annex XIV transaction ban effective 13 Aug 2026, extended ban to financial-messaging-service use SRC-fim-GLOBAL-004

Probable · 1 source

31 individuals/entities added to UK Sanctions List under the Russia (Sanctions)(EU Exit) Regulations 2019 on 1 October 2026 SRC-fim-RU-006

Probable · 1 source

Russia designated an EU high-risk third country for AML purposes under Delegated Regulation (EU) 2026/46, in force since 29 January 2026, triggering mandatory enhanced due diligence across the EU obliged-entity population SRC-fim-RU-007

Probable · 1 source