Brussels, December 5, 2025 – The European Commission has officially listed Russia as a high-risk third country for money laundering and terrorist financing, diverging from the global Financial Action Task Force (FATF) stance and mandating stricter due diligence across EU financial institutions. This move, detailed in a delegated regulation amending EU rules, stems from strategic deficiencies in Russia’s anti-money laundering and counter-terrorist financing (AML/CFT) frameworks, as assessed through public sources, member state inputs, and European External Action Service data. The decision takes effect after a one-to-two-month review by the European Parliament and Council, absent objections.
Background on FATF Suspension and EU Review Process
Russia’s path to this blacklist began with its 2022 full-scale invasion of Ukraine, prompting FATF to suspend its membership rather than expel it outright, due to opposition from BRICS nations including Brazil, India, China, and South Africa. FATF has maintained this suspension into 2025, explicitly avoiding a blacklist placement despite evidence of vulnerabilities, as explained by its president earlier this year.
EU lawmakers repeatedly urged action, leading the Commission in July 2025 to commit to reviewing non-FATF-listed countries with suspended status by year-end, under Delegated Regulation (EU) 2025/1393. This independent assessment concluded Russia meets high-risk criteria, hampered by Moscow’s lack of information-sharing cooperation. Unlike FATF’s “blacklist” of jurisdictions requiring countermeasures, the EU’s list—traditionally aligned but now autonomous via the upcoming Anti-Money Laundering Authority (AMLA)—focuses on enhanced due diligence.
Key Implications for EU Financial Institutions
Financial entities across the 27-nation bloc must now apply rigorous customer due diligence, ongoing transaction monitoring, and risk mitigation to all Russia-linked activities, compelling laggard banks to act decisively. This overlays existing sanctions that bar most Russian firms from EU financial services, further isolating Moscow amid debates over using frozen asset revenues—over €200 billion—for Ukraine aid, stalled by Belgium’s reservations.
The listing amplifies vulnerabilities in Russia’s AML/CFT regime, cited as systemic threats to EU financial integrity, including potential sanctions evasion via oligarch networks and illicit finance channels highlighted by the REPO Task Force. Compliance costs will rise, with firms required to document risk assessments and report suspicious activities more stringently, echoing prior EU blacklists like those for Iran or North Korea.
Russian Response and Geopolitical Context
Moscow dismissed the decision as “exclusively politicized,” akin to its FATF suspension, signaling no intent to address cited deficiencies. This aligns with prior EU steps, such as adding Russia to tax non-cooperative lists in 2023 and considering gray-listing in June 2025.
The blacklist emerges amid escalating EU-Russia tensions, including MEP resolutions in October 2025 calling for tighter sanctions integration with AML measures. European Commissioner Maria Luisa Albuquerque emphasized preserving financial system integrity, positioning this as a proactive safeguard against laundering risks tied to geopolitical conflicts.
Broader EU AML Evolution and Future Outlook
This marks the EU’s shift toward self-reliant blacklisting, empowered by AMLA’s July 2027 role in list drafting, reducing FATF dependency. Parallel reviews delist compliant jurisdictions like the UAE and Gibraltar, balancing enforcement.
For global finance, the move pressures aligned regulators to scrutinize Russia exposure, potentially influencing BRICS dynamics and FATF deliberations. EU institutions face implementation challenges, but the regulation underscores a zero-tolerance pivot on high-risk laundering hubs.
Experts anticipate minimal immediate market disruption given pre-existing sanctions, yet long-term effects could squeeze residual channels, bolstering Ukraine support indirectly. As AML enforcement intensifies, stakeholders monitor Parliament-Council scrutiny through early 2026.