New Challenges with International Banks’ Transactions with Russia as EU Lists Russia Among High-Risk Jurisdictions

The European Commission has independently added Russia to its blacklist of countries with a high risk of money laundering and terrorist financing, bypassing the Financial Action Task Force (FATF).

This was stated in a press release published on the EC website on December 3, 2025.

Despite FATF suspending Russia’s membership in 2023, key BRICS countries like China and India blocked its blacklisting, leaving a gap that the EU has now decisively filled. Previously, the EU’s blacklist usually mirrored FATF decisions, but now, with the EU’s own Anti-Money Laundering Authority (AMLA) becoming active, the EU is taking a more independent stance, including plans for AMLA to help manage the blacklist from July 2027.

The official EU registry has not yet been updated, but this move will require financial institutions within the EU to enhance scrutiny of all transactions involving Russia and impose additional risk mitigation measures on banks.

The delegated regulation will enter into force after scrutiny and non-objection of the European Parliament and the Council within a period of one month. This can be prolonged for another month.

This change leads to a significant complication of banking transactions for companies doing business with companies from Russia, including subsidiaries of European businesses in Russia.