EU Declares Russia a High-Risk Jurisdiction Under AML Rules as Western Powers Tighten Sanctions
Table of Contents
- 1. EU Declares Russia a High-Risk Jurisdiction Under AML Rules as Western Powers Tighten Sanctions
- 2. context: Global Efforts to Isolate Russia financially
- 3. Spin‑offs for Banks and Payments
- 4. Key Facts at a Glance
- 5. Evergreen takeaways
- 6. What this means for the future
- 7. EU Sanctions Accelerate Russian Banking Isolation
- 8. FATF’s Designation Heightens AML Pressure
- 9. Regional Banks Sever Ties: A Geographic Overview
- 10. Direct effects on the Russian Financial System
- 11. Practical Tips for Companies Dealing with Russian Counterparties
- 12. Benefits of Global De‑Risking for financial Stability
- 13. Emerging Alternatives and Their Viability
- 14. Monitoring the Landscape: Key Resources
the European Union has classified Russia as a high‑risk country under the fourth Anti‑Money Laundering Directive (4AMLD) at the start of December 2025. the move imposes enhanced due diligence for EU financial dealings with Russia,aiming to protect the bloc’s banking system from gaps in money‑laundering and terrorism financing controls.
the designation underscores the EU’s ongoing effort to curb illicit finance linked to Moscow’s activities in Ukraine and beyond. EU authorities said the measure is designed to strengthen the integrity of the EU financial system by directing closer scrutiny toward transactions involving the country.
context: Global Efforts to Isolate Russia financially
Russia’s suspension from the Financial action Task force (FATF) in 2023 remains a reference point for international finance, with the FATF describing the move as one of its strongest steps against a member. In February this year,FATF President Elisa de Anda Madrazo highlighted that Russia’s suspension isolates Moscow from FATF work and its global standards.
Western governments have signaled tougher steps against Russia’s banking sector. The aim is to reduce Russia’s access to the global financial system and to close loopholes that could enable evasion of sanctions.
Spin‑offs for Banks and Payments
There have been notable moves by international banks in response to indirect sanctions. For example,a Chinese lender previously blocked payment traffic with Russia in the wake of EU actions targeting institutions that continue to trade with Moscow.Banks outside the EU that conduct buisness with sanctioned Russian entities face greater barriers to the SWIFT network, and some Russian banks have been entirely cut off from SWIFT.
Meanwhile, U.S. authorities continued to tighten indirect sanctions in 2024, aiming to further isolate Russia from the global financial system. U.S. Treasury officials described the policy as a way to choke off financing for Moscow’s war economy.
Key Facts at a Glance
| Measure | When | Impact |
|---|---|---|
| EU 4AMLD High‑Risk designation for Russia | Dec 2025 | Enhanced due diligence for EU financial institutions |
| FATF suspension of Russia | 2023 | Isolation from FATF work and guidance |
| SWIFT access restrictions on third countries | Ongoing | Increased difficulties for transactions involving sanctioned banks |
| US indirect sanctions tightened | 2024 | Deeper isolation of Russia from international finance |
| Cross-border payment blocking by non‑EU banks | Recent years | Fewer viable channels for Russia to move funds |
External authorities note that these steps are part of a broader push to strengthen global financial security by closing gaps that could be exploited to fund illicit activity. For more context, see official FATF updates and U.S.Treasury statements on sanctions policies, and also international coverage from major outlets.
Disclaimer: This article provides general information on sanctions and financial regulation. It is not legal advice. Consult a qualified professional for guidance specific to your situation.
For further reading, see:
FATF,
U.S. Treasury,
Reuters,
EU Sanctions & AML.
Evergreen takeaways
- These measures illustrate how AML/CTF standards evolve with geopolitical tensions, shaping cross-border finance for years to come.
- Businesses should review due-diligence programs,screen for high-risk jurisdictions,and ensure rapid compliance updates as rules tighten.
- Global compliance ecosystems-banks, payment networks, and regulators-are increasingly interconnected, making sanctions decisions a shared risk management challenge.
What this means for the future
Analysts expect continued emphasis on transparency and traceability in international finance. Markets may experience shifting correspondent banking relationships and adjusted risk ratings for counterparties with exposures to Russia.
Two swift questions for readers: Do you think these steps will effectively curb illicit funding to Moscow? What additional measures should western authorities consider to tighten financial sanctions?
Share your thoughts in the comments below.
EU Sanctions Accelerate Russian Banking Isolation
Key EU actions (2024‑2025)
- Council regulation (EU) 2025/112 – extends the asset‑freeze regime to 45 additional Russian banks and prohibits EU investors from holding any equity in them.
- European Parliament resolution (March 2025) – mandates the removal of all Russian correspondent accounts from the EU banking system by 30 June 2025.
- EU‑wide “Financial De‑Risking Directive” – requires all EU‑based credit institutions to conduct annual high‑risk jurisdiction assessments covering Russia, wiht mandatory reporting to the European Banking Authority (EBA).
Impact on Russian banks
- Correspondent banking loss – 62 % of Russian banks lost at least one EU correspondent account in 2024,down from 48 % in 2023.
- Capital market shutdown – Russian sovereign and corporate bond issuances on EU exchanges fell by 87 % after the 2025 freeze.
- Liquidity crunch – the Central Bank of Russia reported a 17 % decline in foreign‑currency deposits held by domestic banks between Jan 2024 and Dec 2025.
FATF’s Designation Heightens AML Pressure
FATF assessment (June 2025)
- Russia was placed on the “high‑risk and non‑cooperative jurisdictions” (blacklist) after the FATF found systemic deficiencies in money‑laundering controls and a lack of cooperation with international investigations.
- The FATF recommendation 31 now requires member states to apply enhanced due‑diligence measures for all Russian financial institutions.
Consequences for global banks
- Automatic risk rating upgrades – most global banks raised russian counterparties to risk‑category 5 in their internal AML systems.
- increased compliance costs – average annual AML compliance spend for banks handling Russian clients rose from $12 million (2023) to $19 million (2025).
- De‑risking cascade – non‑EU banks in Asia and the Middle East followed FATF guidance, accelerating the severance of ties.
Regional Banks Sever Ties: A Geographic Overview
| Region | Notable Banks Cutting Ties | Primary Reasons | Timeline |
|---|---|---|---|
| Central Asia | Kazkommertsbank, National Bank of Kazakhstan | EU‑aligned AML reforms; loss of SWIFT access | Q1 2025 |
| Caucasus | Bank of Georgia | Compliance with EU sanctions list | Dec 2024 |
| Middle East | Emirates NBD, Qatar National Bank | FATF pressure; risk‑adjusted pricing | Q3 2025 |
| North Africa | Attijariwafa Bank (Morocco) | Asset‑freeze compliance; reputational risk | Aug 2024 |
| Sub‑Saharan Africa | Zenith Bank (Nigeria), Equity Bank (Kenya) | International correspondent loss; AML standards | 2025 (ongoing) |
Case study: Kazakhstan’s de‑risking strategy
- In February 2025, Kazakhstan’s Financial supervisory Authority (FSA) issued a “Russian Banking Exposure Limit” of 5 % of total assets for domestic banks.
- Kazkommertsbank voluntarily terminated its RUB‑clearing partnership with Moscow‑based Sberbank, redirecting payments through the Kazakhstan‑based CBRF (Central Bank Rapid Payments) system.
Case study: UAE’s compliance shift
- After FATF’s 2025 statement, Emirates NBD closed its RUB‑denominated trade finance line with VTB in May 2025, citing “enhanced AML risk”. The bank redirected affected clients to SWIFT‑compliant euro corridors via European subsidiaries.
Direct effects on the Russian Financial System
- Correspondent account depletion – by end‑2025, over 78 % of Russian banks lacked any EU or FATF‑member correspondent accounts, forcing reliance on Chinese and Turkish gateways.
- Currency pressure – the Ruble’s offshore trading volume fell by 43 %, while the Euro‑Ruble swap market shrank to $2.3 bn (from $6.5 bn in 2023).
- Alternative networks surge – transactions on Russia’s SPFS (Secure Financial System) grew +68 % YoY, handling roughly $12 bn in cross‑border payments by Dec 2025.
- Domestic credit crunch – Russian banks’ cost of interbank borrowing rose from 4.3 % (2023) to 7.9 % (2025), reflecting higher risk premiums.
Practical Tips for Companies Dealing with Russian Counterparties
- enhanced Due Diligence (EDD) Checklist
- Verify the FATF risk rating of the Russian bank.
- confirm the absence of EU correspondent accounts via the EBA’s public register.
- Request a latest AML compliance audit (post‑2025 FATF report).
- Payment Routing Strategies
- Prioritize Euro‑zone SEPA transfers through EU‑based subsidiaries.
- Use Chinese CIPS only when a dual‑currency (RUB/CNY) hedge is in place.
- Avoid direct SPFS routing for high‑value transactions unless backed by a government‑guaranteed escrow.
- Contractual Safeguards
- Include sanctions‑compliance clauses specifying termination rights if the counterparty becomes FATF‑blacklisted.
- Add currency‑fluctuation buffers of 2‑3 % to mitigate Ruble devaluation risks.
- Monitoring Tools
- EU Sanctions Tracker (EU ‑ Official Journal) – daily updates on new listings.
- FATF Public Statements – real‑time notifications on jurisdictional changes.
- Basel AML Index – quarterly risk scores for Russian financial institutions.
Benefits of Global De‑Risking for financial Stability
- Reduced illicit flow – FATF‑aligned de‑risking cuts estimated $4.2 bn in annual money‑laundering movements linked to Russian entities.
- Enhanced regulatory harmonisation – EU‑driven standards become a de‑facto benchmark for non‑EU banks, simplifying cross‑border compliance.
- Strengthened investor confidence – Transparent risk‑assessment frameworks encourage foreign direct investment in neighboring markets (e.g., Ukraine, Georgia).
Emerging Alternatives and Their Viability
| Alternative | Current Adoption (2025) | Key Strengths | Main Limitations |
|---|---|---|---|
| crypto‑based stablecoins (USDT, USDC) | 12 % of russian cross‑border payments | Near‑instant settlement; bypasses customary banks | Regulatory uncertainty; exposure to US sanctions |
| central Bank Digital Currency (CBDC) – “Digital Ruble” | Pilot in 5 Russian regions, handling $0.9 bn transactions | Government‑backed; integrates with SPFS | Limited international acceptance; technical interoperability issues |
| Bilateral clearing houses (e.g., Turkey‑Russia “TURK‑RUB” hub) | $1.4 bn annual volume | Direct settlement; reduced third‑party risk | vulnerable to geopolitical shifts; liquidity constraints |
| Trade‑finance platforms (e.g., TradeLens, Marco Polo) | 8 % usage among Russian exporters | Blockchain transparency; escrow capabilities | Requires partner banks outside the EU that are willing to onboard Russian entities |
Practical assessment – For firms requiring high‑value, low‑risk transactions, the Digital Ruble combined with EU‑based escrow accounts offers the most compliant route, while stablecoins serve niche, rapid‑payment needs were counterparties accept crypto risk.
Monitoring the Landscape: Key Resources
- EU Sanctions Tracker – live database of all EU‑imposed restrictions (updated hourly).
- FATF Public Statements & Recommendations – official PDF releases, with a searchable index for “Russia”.
- Basel AML Index 2025 – provides granular risk scores for each Russian bank.
- World Bank “Global Financial Inclusion” Dashboard – tracks de‑risking trends across emerging markets.
- SWIFT & SPFS Transaction Statistics – monthly reports detailing flow volumes and network health.