Russia AML

The Russia file usually fails on the date, not the list. Most country-risk sections I review name Russia and stop there, without saying which of the four lists they checked — FATF's call-for-action and increased-monitoring lists, the EU high-risk third-country list, the EU Annex I of non-cooperative tax jurisdictions — or when. That matters because the lists change several times a year, and a client, beneficial owner or payment corridor touching Russia needs the position recorded on each, not a single line. Write the position on each list into the file, with the date you checked, before the auditor asks.

https://firm.cy/aml-country/russia

Not legal advice. Verify against the primary source before acting.

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