Russia Added to the EU List of High-Risk Third Countries for AML

Banking & Finance

By: Jan Prošek

On December 3, 2025, the European Commission included Russia on the list of high-risk third countries regarding the fight against money laundering and the financing of terrorism (AML/CFT). This was enacted through Commission Delegated Regulation (EU) 2026/46 of December 3, 2025. The regulation entered into force on the twentieth day following its publication—specifically on January 29, 2026. Since this date, the Russian Federation has been officially classified as a high-risk country under the EU AML regime.

The practical consequence of Russia's inclusion on this EU "blacklist" is that all obliged entities (entities subject to AML legislation, such as banks, credit providers, real estate agents, or insurance companies) in the Czech Republic and across the EU must now treat any business relationship or transaction linked to Russia as high-risk.

In accordance with legal regulations, this necessitates the mandatory application of Enhanced Due Diligence (EDD). Specifically, this includes:

  • Obtaining additional information on the customer and their ultimate beneficial owner (UBO);

  • Verifying the source of funds and source of wealth;

  • Determining the intended nature of the business relationship;

  • Verifying documents and information from various reliable and independent sources.

Czech obliged entities are therefore required to conduct stricter monitoring of clients and transactions with links to Russia and to consistently implement all additional measures for the prevention of money laundering and terrorist financing associated with this high-risk classification.

This text was translated by AI