Almost four years after the start of the war of aggression against Ukraine, the European Union (EU) has added Russia to its list of high-risk third countries. Delegated Regulation (EU) 2026/46 amending Delegated Regulation (EU) 2016/1675 by including Russia in the list of high-risk third countries was published on 9 January 2026. The EU high-risk list includes countries that have strategic deficiencies in their anti-money laundering and counter-terrorist financing (AML/CFT) systems. This classification has a direct impact on business relationships and transactions between the EU and Russia.
1. Background
There has been a long-standing debate in the EU as to whether Russia should be included in the list of high-risk countries in view of organised crime, widespread allegations of corruption and the risks arising from the war in Ukraine. In the National Risk Assessment 2018/2019 (Annex 4), Russia was already classified as a country with a high risk of money laundering and terrorist financing. With Delegated Regulation (EU) 2025/1393 of 8 July 2025, the Commission has set the goal of reviewing third countries that are not included in the FATF lists or whose FATF-membership has been suspended due to violations by the end of 2025. The purpose of the review was to determine whether these countries could pose a threat to the integrity of the EU financial system and whether the EU list of high-risk countries needed to be adjusted. Russia’s membership of the FATF had been suspended due to serious violations of the FATF’s basic principles.
2. Deficiencies identified by the European Commission
In cooperation with the European External Action Service and the authorities of the Member States, the European Commission had carried out a prima facie assessment of the country in terms of combating money laundering and terrorist financing. In particular, the following strategic deficiencies were identified, which then led to Russia being classified as a high-risk third country:
- the independence of the national central reporting office,
- the transparency of beneficial owners,
- the availability and accuracy of relevant information,
- the implementation of anti-money laundering requirements for crypto-asset transactions.
In the Commission’s assessment, these deficiencies pose significant risks to the stability and integrity of the EU financial system.
3. Impact on obligated entities
With the regulation coming into force on 29 January 2026, obligated entities must now apply enhanced due diligence requirements in addition to the general due diligence requirements pursuant to Section 15 (1), (3) No. 2 GwG when conducting business relationships and transactions with Russia.
This results in the following mandatory measures for obligated parties (Section 15 (5) GwG):
- Comprehensive identification and verification of the persons involved and beneficial owners, including Russian partners.
- Extended risk analysis taking into account the specific risks associated with Russia.
- Obtaining additional information on the purpose and intended nature of the business relationship.
- Intensified monitoring of the business relationship, ongoing review and updating of relevant information.
- Mandatory reporting of suspicious circumstances to the FIU (Financial Intelligence Unit) in cases of suspected money laundering or terrorist financing.
4. Practical tip for obligated parties
- Update risk identification and assessment
- The internal risk analysis should be expanded to include Russia-specific scenarios and reviewed regularly.
- Check whether existing business relationships or transactions have any connection to Russia.
- Adapt internal processes and systems
- Provide timely training for all relevant employees on the new requirements and highlight practical case scenarios.
- Adapt IT systems and parameters to automatically classify Russian counterparties as high-risk customers.
- Intensify documentation requirements
- Ensure complete documentation of all due diligence and control measures taken.
- Reformulate internal work instructions or adapt existing ones as necessary.
- Compliance with international embargo and sanctions regulations
- Review money laundering regulations as well as potential sanctions and embargoes relating to Russia in order to rule out regulatory risks.
