The European Commission (EC) has adopted a delegated regulation adding the Russian Federation (Russia) to the EU’s list of “highrisk third countries” for anti-money laundering (AML) and counter-terrorist financing purposes (EC, IP/25/2910). This measure amends EC Delegated Regulation (EU) 2016/1675, which supplements Directive (EU) 2015/849 and contains the EU’s high-risk country list.
For banks and other “obliged entities”, EU law will now treat Russia not only as a heavily sanctioned state, but as a structural AML and “Combatting the Financing of Terrorism” (CFT) risk. That classification triggers mandatory enhanced due diligence on relationships with a Russian nexus and will increase supervisory pressure on any institution that still has direct, or even indirect, exposure to Russian counterparties.
