russia placed on the “black list”: EU decision to include the russian federation in the list of high-risk third countries for money laundering and terrorist financing (AML/CFT) enters into force

The Delegated Regulation of the European Commission (EU) of 3 December 2025, which includes the russian federation in the list of high-risk third countries with strategic deficiencies in their anti-money laundering and counter-terrorist financing (AML/CFT) regimes, entered into force on 29 January 2026 in accordance with European Union legal procedures.

As no objections were raised by EU Member States or the European Parliament within the established timeframe, the Delegated Regulation entered into force automatically, without additional approval stages.

“The inclusion of the russian federation in the list of high-risk countries for money laundering and terrorist financing is a principled and important step to strengthen the financial security of the EU and the global financial system. It significantly limits russia’s ability to circumvent sanctions, launder illicit funds and finance its aggression. Ukraine is grateful to the European Commission, EU Member States and the European Parliament for their coordinated position and will continue the systematic work with partners, launched back in 2022, to strengthen global financial security,” emphasized Minister of Finance of Ukraine Sergii Marchenko.

Since 2022, the Ministry of Finance of Ukraine has taken consistent and systematic steps to facilitate the adoption of this decision, including:

– conducting intensive consultations and communications with the European Commission, including within the framework of implementing Commission Delegated Regulation (EU) 2025/1393;
– organizing and holding a series of meetings and exchanges with competent authorities of EU Member States and other international partners;
– ensuring targeted diplomatic engagement together with the Ministry of Foreign Affairs of Ukraine and Ukrainian diplomatic missions in EU Member States, including the provision of comprehensive analytical materials and evidence of systemic AML/CFT deficiencies of the russian federation.

Practical implications of the decision

In practical terms, the inclusion of the russian federation in the EU list of high-risk third countries requires the mandatory application of enhanced due diligence measures to all financial transactions linked to russia within the European Union. In particular, this includes:

– enhanced identification of customers and beneficial owners;
– verification of the source of funds and sources of wealth;
– strengthened monitoring of financial transactions.

These measures significantly restrict the access of russian legal entities and individuals to the EU financial system and further reinforce the financial isolation of the aggressor state.

Context and next steps

The European Commission updates the list of high-risk third countries on a regular basis (on average once or twice a year), as well as at any time should new information or changes in risk assessments emerge.

In making such decisions, the European Commission takes into account, inter alia:

– FATF findings;
– the results of its own technical assessments;
– overall risks to the integrity of the EU financial system.

In this context, maintaining coordinated support from EU Member States and the European Parliament remains critical to ensuring the continued presence of the russian federation on this list during future updates.

The Ministry of Finance of Ukraine will continue its systematic engagement with European and international partners to strengthen global financial security and prevent the use of the international financial system to support the russian federation’s armed aggression.