## _cr16305

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### EXECUTIVE SUMMARY — Introduction and Scope
- Technical Note (TN) provides a targeted review of the Russian Federation’s AML/CFT system in the context of the Financial Sector Assessment Program (FSAP).
- TN focuses on: availability of beneficial ownership information; transparency of companies; preventive measures relating to PEPs; suspicious transaction reporting; and risk-based AML/CFT supervision in the banking sector.
- Staff analysis draws on the 2008 MER, documentation submitted by the RF to FATF and MONEYVAL, authorities’ written responses, and discussions during the mission from February 1–5, 2016 with CBR, Rosfinmonitoring, Ministry of Internal Affairs, Prosecutor General’s Office, Federal Taxation Service, Federal Security Service, and representatives of two banks.
- A full assessment against the current FATF standard will be conducted by the FATF, Eurasia Group and MONEYVAL and will be available in 2019.

### EXECUTIVE SUMMARY — Progress since 2008 MER (Findings)
- 2008 MER identified key deficiencies: lack of adequate transparency of beneficial ownership and insufficient guidance to banks on foreign PEPs.
- Measures taken since 2008:
  - Aligned the definition of “beneficial owner” with the FATF standard.
  - Introduced prohibition against individuals with criminal convictions acquiring or controlling a significant amount of shares in certain credit institutions (Federal Law No. 134-FZ (June 28, 2013) and Federal Law No. 146-FZ (July 2, 2013)).
  - CBR issued guidelines for enhanced CDD for foreign PEPs and extended requirements to domestic PEPs.
- RF exited FATF’s follow-up process in 2013.
- FATF standard and methodology revised in 2012 and 2013; greater emphasis on risk-based approach and assessing effectiveness.
- RF scheduled for comprehensive assessment under prevailing standard in late 2018, with plenary consideration of the draft MER scheduled for June 2019.

### ASSESSING AND UNDERSTANDING RISK — Context and Risk (Findings)
- 2008 MER: main ML/TF risks related to abuse of shell companies (“one-day” firms).
- Rosfinmonitoring assesses ML/TF threats based on STRs, CTRs, and other information; a Center of Risk Assessment of ML/TF (CRA) established and reports annually to the President.
- CRA and Rosfinmonitoring coordinate with many state bodies (e.g., Federal Tax Service, Ministry of Internal Affairs, Ministry of Finance, Rosfinnadzor, Federal Treasury, Prosecutor’s General Office, Investigation Committee, Federal Drug Control Service, Federal Customs Service, Federal Security Service, the CBR, Rosstat, Russian Assay Office).
- Main ML threats identified:
  - Fraud (e.g., account fraud, fraudulent loans, and identity fraud) is the most common predicate crime detected.
  - Corruption is a key concern; corruption in defense industry and construction highlighted by CRA.
  - Russia’s Transparency International Corruption Perception Index improved to 119 (out of 168 countries) in 2015 from 136 (out of 174 countries) in 2014.
  - Presidential Decree No. 147 (April 1, 2016) established an anti-corruption plan focusing on improving beneficial ownership information, exposing corruption, and enhancing international cooperation.
- TF threats identified:
  - Activities of armed gangs in the North Caucasus, operations of cells of international terrorist organizations in Russia, and Russian citizens travelling to conflict areas (e.g., Islamic State of Iraq and Levant).
- Vulnerabilities:
  - One-day firms: authorities reported more than two trillion roubles of financial transactions (volume) were reportedly carried out by these shell companies in 2015.
  - Technologies (wire transfers, crowdfunding, e-payment systems, mobile banking) identified as TF vulnerabilities due to anonymity and ease of small-value transfers.

### ASSESSING AND UNDERSTANDING RISK — Conclusions and Recommendations
- Understanding of ML/TF risks improved among some authorities but may be limited because analysis relies mostly on Rosfinmonitoring and CBR reports and on data provided predominantly by the banking sector.
- Limited scope could understate criminal proceeds in other sectors (e.g., real estate, lawyers, and precious metals and stones).
- Authorities initiated the NRA process, which will involve broad stakeholders and should lead to a national strategy enabling risk-based approaches across agencies.
- Main FSAP recommendations for AML/CFT:
  - Assessing and Understanding ML/TF Risks
    - i. To complete and share the results of national assessment of ML/TF risks — Priority: Near
    - ii. To prepare a national AML/CFT strategy that would prioritize AML/CFT policies and activities and allow the use of risk based approach by concerned authorities — Priority: Intermediate

### NATIONAL RISK ASSESSMENT (NRA) AND POLICY FRAMEWORK (Findings & Actions)
- RF authorities initiated an NRA expected to be completed early 2017.
- Presidential Decree No. 103, dated March 8, 2016, authorizes Rosfinmonitoring to organize an NRA with involvement of the CBR, relevant federal executive bodies, other state bodies and organizations, and representatives of the financial sector.
- Authorities will rely on FATF guidelines on data and statistics and inputs from MONEYVAL and the OSCE.
- Under proposed amendment, a public sanitized version of NRA results will be published on Rosfinmonitoring’s website.
- Authorities do not currently have a national AML/CFT strategy; some policies and activities address main ML/TF risks, others under consideration.
- Recent legislative measures:
  - Federal Law No. 110-FZ (May 5, 2014): enhanced customer identification for new technologies.
  - Federal Law No. 424-FZ (December 30, 2015): obliges FIs to conduct customer identification of foreign entities without legal personality and strengthens information exchange between CBR and Rosfinmonitoring.
- A draft law requiring legal entities to identify and document their beneficial owners and providing penalties has been submitted to parliament.
- Interdepartmental commission on combatting TF created; work underway to strengthen criminal penalties for involvement in terrorist activities.
- Authorities engaged private sector to raise awareness on some ML/TF risks.
- Authorities have not adopted a comprehensive strategy(ies) or policy(ies) to address risks and enhance framework effectiveness through better use of resources; they may do so after completing the NRA.
- Recommended actions:
  - Proceed with planned assessment of national ML/TF risks prior to the scheduled FATF/EAG/MONEYVAL assessment in 2018.
  - Use an inclusive, multi-faceted approach relying on qualitative and quantitative information beyond STRs and CTRs from all concerned agencies, reporting entities including DNFBPs, and academics.
  - Share a sanitized version of main NRA results with all concerned agencies and the private sector.
  - Based on NRA results, adopt and communicate a national AML/CFT strategy and propose prioritized action items.
  - Use the strategy for efficient allocation of resources and implementation of risk-based measures.

### TRANSPARENCY AND BENEFICIAL OWNERSHIP — Background and Risk
- Types of legal entities in the RF: general partnerships, limited partnerships, limited liability companies, double liability companies, joint stock companies, production co-operatives, and unitary enterprises.
- Information on creation and types of legal persons is available online through the Federal Tax Service (FTS) website.
- As of end-2015, 4,820,432 legal entities were registered in Russia, most of which were limited liability companies.
  - The number includes:
    - 3,962,627 limited liability companies;
    - 126,074 joint stock companies;
    - 21,650 production co-operatives;
    - 23,262 unitary enterprises.
- All legal persons required to provide to the Unified State Register of Legal Entities (USRLE) basic information: legal form, information on founders, identity of persons entitled to act on behalf of the entity, taxpayer identification number, and information on bank accounts.
- At time of 2008 MER, commercial entities were not required to retain beneficial ownership information or register such information in the USRLE, and there was no explicit requirement for FIs or DNFBPs to identify beneficial owners.
- Shell or “one-day” companies pose a high risk and are often used as fronts to open bank accounts without revealing beneficial owners.

### BENEFICIAL OWNERSHIP — Availability and Legal Framework
- 2013 amendment to AML/CFT law (Federal Law No. 134-FZ, June 28, 2013) added a definition of beneficial owner consistent with the FATF standard and required FIs and DNFBPs to identify and verify beneficial owners.
  - Quoted definition: “Beneficial owner means for the purposes of this Federal Law a natural person who directly or indirectly (through third persons) owns (has a predominant stake of over 25 percent in the capital of) a client being a legal entity or has the possibility of controlling the actions of the customer.” (Federal Law No. 115-FZ, as amended).
- Amended framework broadly in line with revised FATF standard:
  - Where no natural person identified as BO, FIs should identify and take reasonable measures to verify identity of relevant natural persons who hold position of senior managing official (FATF, Interpretative Note to Recommendation 10.5).
  - FIs are not explicitly prohibited from establishing or continuing business relations where BO cannot be identified or verified, but are prohibited from opening an account when customer refuses to provide BO information, may refuse to carry out transactions, and may terminate the contract (Federal Law No. 115-FZ, as amended, Article 7).
  - RF law allows that in cases of failure to identify the BO, the FI may recognize the sole executive body (position of senior managing official) as the BO (Federal Law No. 115-FZ, Article 7).
- In practice banks might often designate the senior manager as BO; the law and regulations should clarify such measure should be a last resort.
- “De-offshorization” law (Federal Law No. 376-FZ (November 24, 2014)) defines controlled foreign company (CFC) thresholds:
  - A Russian tax resident is deemed to be a controlling person of a CFC if his/her participation or interest in the CFC is at least 50 percent during 2015 and 25 percent thereafter.
- Russia has international tax cooperation instruments:
  - RF currently has 81 bilateral agreements (text also notes 80 in another sentence).
  - Russia signed 11 intergovernmental agreements on cooperation and mutual assistance on tax compliance with CIS states.
  - In 2015, the OECD Multilateral Convention on Mutual Administrative Assistance in tax matters came into effect for Russia, ensuring exchange of information with 80 jurisdictions.

### BENEFICIAL OWNERSHIP — Limitations, Access, and Recommendations
- None of current systems in RF achieves adequate transparency regarding beneficial ownership of legal persons.
- Authorities indicated FIs provide a virtual national beneficial ownership registry since every legal person required to have an account in an FI and FIs are required to identify the beneficial owner (FATF, Russian Federation: 6th Follow-Up Report (October 2013)).
- Doubts remain whether identification and verification of BO information by FIs are effective and adequately robust; BO information collected by FIs via CDD is not always available, up-to-date, or accurate when requested by concerned agencies.
- Bill No. 96535-6 submitted to parliament would require all legal entities to keep and periodically update BO information within their principal office and provide such information at the request of Rosfinmonitoring or other authorized federal executive bodies; the bill would allow imposition of administrative liabilities and fines for non-compliance.
- Authorities did not provide information on sanctions imposed on FIs for failing to identify beneficial ownership.
- Access to BO information by concerned agencies:
  - Rosfinmonitoring, FTS, and Law Enforcement Agencies (LEAs) have timely access to basic information of legal persons and bank accounts held by natural and legal persons.
  - Through taxpayer identification number, FTS has timely access to accounts held by natural and legal persons; LEAs and Rosfinmonitoring can access such information via the FTS.
  - LEAs’ actions to access BO information are limited:
    - STRs and CTRs collected by Rosfinmonitoring can indicate BO information, but banks’ BO identification often not thorough.
    - LEAs make little use of special investigative techniques to locate ultimate beneficial owners; investigations often start with publicly available USRLE information.
    - Mutual legal assistance sometimes required to trace BO information across borders; authorities indicated it can be challenging, slow, and not used very often.
- Recommended actions on BO:
  - Conduct a comprehensive assessment (through the NRA, if possible) to obtain more granular understanding of risks of legal persons being misused for ML and TF.
  - Ensure banks properly identify customers’ beneficial owners and verify their identity.
  - CBR and Rosfinmonitoring should provide further guidance and education to banks on steps to identify ultimate beneficial owners and clarify that reliance on the customer’s self-declaration is not sufficient—FIs should verify information independently.
  - Enhance effective implementation of strengthened BO requirements, including imposition of penalties for non-compliance.
  - Ensure effective implementation of draft bill establishing requirements for legal entities to provide and disclose BO information.
  - Authorities could consider, as an alternative to the draft bill, creating a public registry for beneficial ownership information.

### PREVENTIVE MEASURES — PEPs (Findings)
- Banks required to take reasonable measures to identify foreign and domestic PEPs, and officials of public international organizations, including:
  - Securing management approval before establishing business relationships with PEPs;
  - Identification of the sources of funds or origins of their monetary assets or property;
  - Regularly updating information on such persons (Federal Law No. 115-FZ, as amended, Article 7.3);
  - Paying special attention to transactions made by PEPs and their family members (Federal Law No. 115-FZ, as amended, Article 7.3).
- Shortcomings in PEP framework:
  - AML/CFT law’s PEP definition appears limited to public officials appointed by the President, potentially excluding political party officials and senior politicians not appointed by the President.
  - References to parliamentarians are indirect: PEP definitions refer to members of committees and commissions of the Parliament, and according to the Regulation of State Duma, all parliamentarians must be members of committees and commissions.
  - FATF standard requires scope of PEPs based on prominent public functions rather than appointing power.
  - Restrictive definition can restrain banks’ application of enhanced due diligence and increase risk of failing to identify and report suspicious transactions of high-level public officials not appointed by the President.
  - AML/CFT law needs clarification to ensure enhanced measures apply to beneficial owners who are PEPs.
  - Banks required to pay special attention to transactions of PEPs and their family members, but not explicitly to close associates or PEPs who are beneficial owners as prescribed by the revised FATF standard.

### PREVENTIVE MEASURES — PEPs (Gaps, Data, and Recommendations)
- AML/CFT supervision of banks’ compliance with PEP requirements is limited and may not ensure banks are effectively monitoring ML risks from PEPs.
- Only a small percentage of customers have been identified by banks as PEPs.
- Low identification rate of PEPs may be due to:
  - Banks’ inadequate understanding or capacity to identify customers as PEPs, aside from the limited definition under the law;
  - Limited definition of PEPs under the law.
- No data provided by authorities on sanctions for violations by FIs of requirements regarding PEPs.
- CBR inspections do not focus sufficiently on the level of compliance and adequacy of banks in implementing the PEP requirements in line with the standard.
- PEPs — recommendations:
  - Bring definition of and measures for PEPs in line with the FATF standard.
  - Provide guidance from relevant supervisors on:
    - identifying PEPs, family members, and close associates;
    - identifying PEPs who are beneficial owners;
    - best practices in implementation of preventive measures to assist banks in strengthening their systems.

### SUSPICIOUS TRANSACTION REPORTS (STRs) — Legal Framework and Data
- Under revised FATF standard, if a FI has reasonable grounds to suspect funds are proceeds of criminal activity, or related to terrorist financing, it should be legally required to promptly report suspicions to the financial intelligence unit; all suspicious transactions, including attempted transactions, should be reported regardless of amount.
- FIs required to submit to Rosfinmonitoring information on transactions for which there is a suspicion they are carried out for ML/TF purposes and transactions subject to compulsory control (in excess of RUB 600,000).
- Attempted transactions of customers with an existing business relationship and of occasional customers are covered.
- In 2014, Rosfinmonitoring reported receiving over 11 million suspicious transaction reports (STRs) with an estimated value of RUB 160 trillion (most sent by credit institutions).
- Number of criminal cases initiated based on information provided by Rosfinmonitoring rose from 500 in 2013 to 1,500 in 2014.
- Of the 11 million STRs in 2014:
  - STRs filed on the sole basis of suspicions by reporting entities amounted to more than six million in 2014 and rose to eight million in 2015.
  - Total STRs filed with respect to PEPs (foreign, domestic and international organizations) was less than 100 in both years.

### STRs — Quality, Systems, and Recommendations
- Rosfinmonitoring considers FI suspicious transaction reporting system functioning well:
  - Single telecommunications network provided to FIs to submit STRs;
  - Automated system filters incoming STRs and rejects improperly generated STRs for return to sending FIs;
  - Rosfinmonitoring publishes newsletters and typology reports to guide reporting entities.
- Rosfinmonitoring sends some collected information to the CBR regarding potential violations of STR regulations by reporting FIs; CBR uses information in supervisory activities to discuss with FIs efforts to improve STR quality.
- Concerns:
  - CBR predetermined criteria may not be comprehensive enough to cover all potential ML/TF risks and may limit banks’ appreciation of suspicious transactions.
  - Transmission system relies on predetermined criteria provided and updated regularly by the CBR, offering little flexibility for FIs to assess suspicious transactions.
  - CBR inspections focus heavily on compliance with predetermined reporting criteria.
  - Several sanctions (including revocation of licenses) were imposed because banks failed to report suspicious transactions later determined to be suspicious by the CBR.
  - Such systems can lead to over-reporting or defensive-reporting.
  - STRs do not appear to correlate with RF’s ML/TF risks: STRs relating to PEPs are not commensurate with the ML risks; most reports concern unusual transactions rather than suspicions of laundering of proceeds of crimes.
- Rosfinmonitoring provides good quality general guidance on STRs but could improve case-by-case feedback to FIs.
- Recommendations on STRs:
  - Provide guidance on typologies and timely feedback to banks on quality of suspicious transaction reports to align reporting with ML/TF risks in Russia — Priority: Near
  - Rosfinmonitoring, in coordination with CBR, should provide additional guidance and timely, case-by-case feedback to FIs on reporting of suspicious transactions.
  - Share NRA results with FIs to improve alignment of STRs with ML/TF risks.

### AML/CFT SUPERVISION — Risk-Based Approach and Sanctions (Findings)
- Since 2008 assessment, CBR increased resources, including a merger enabling a three years’ inspection cycle; FATF concluded in the 2013 progress report that technical requirements for supervision and sanctions were largely in line with the previous standard and methodology.
- CBR applies a risk-based approach to AML/CFT supervision of FIs, relying on:
  - regular analysis of the 17 reporting forms from banks;
  - information from Rosfinmonitoring on the level of STRs;
  - LEAs’ investigations;
  - analysis of internal databases and direct contacts with FIs.
- CBR gives undue reliance on risk mitigation based on a checklist of predetermined criteria, rather than on robust analysis of indicators of inherent ML/TF risks of banks.
- Offsite activity centers on review of 17 categories of reporting, but information on ML/TF risks of the sector, risk profiles of individual institutions, and their level of AML/CFT compliance are insufficient.
- No well-defined, documented methodology that integrates findings for operational risk into a rating that accounts for inherent risk and risk mitigants to prioritize banks for supervisory oversight.
- Risk-based methodology does not seem to capture information relating to the level of compliance of AML/CFT measures in individual banks, including exposure to PEPs or weak implementation of beneficial ownership requirements.
- Supervisory inspections:
  - Supervisors regularly conduct scheduled and unscheduled on-site inspections.
  - From 2013 to 2015:
    - More than half of all total scheduled inspections included AML/CFT issues, with several inspections devoted exclusively to AML/CFT concerns.
    - Approximately 20% of all unscheduled inspections involved AML/CFT issues.
- CBR’s understanding of risks relating to banks and its supervisory tools could be enhanced to provide comprehensive, timely and consistent data on inherent ML/TF risk at the institutional level.

### SANCTIONS — Findings and Recommendations
- Number of active banks decreased from 1,351 as of January 31, 2006 to 945 registered banks, owing to revocation of licenses, mergers and acquisitions, and unilateral decisions to close the business.
- Licenses revoked by the CBR due to AML/CFT violations sharply increased in 2014: 36 licenses revoked in 2014, 11 of which were based solely on AML/CFT violations; this surpassed the total number from 2011 to 2013.
- Trend continued with 34 revoked bank licenses in 2015 involving AML/CFT violations; revocations involved both small and larger banks.
- Among license revocations due to AML/CFT violations, most were due to failure of banks to report suspicious transactions.
- Recommendations:
  - CBR should pursue a more graduated approach to sanctions to ensure sanctions are proportionate to the severity and frequency of violations or the inspection score.
  - Apply the range of sanctioning powers in a manner proportionate to severity of identified breaches or the rating assigned resulting from the inspection.
- Supervision — recommendations:
  - i. To improve the CBR’s identification and understanding of ML/TF risks and controls, and develop further the risk-based approach tools for offsite and onsite supervision (with a focus on PEP and BO-related requirements) — Priority: Near
  - ii. To ensure effective implementation of a broad range of sanctions against financial institutions that are dissuasive and proportionate to the severity of the AML/CFT violations — Priority: Intermediate

### Annex I — Reporting Forms for Offsite AML/CFT Supervision of Banks (inventory)
- Numbered reporting forms (1–17) with stated periodicity:
  - 1 Turnover Sheet of the Credit Institution's Business Recording Accounts. — Monthly
  - 2 Information on the Standard of the Credit Institution's Assets (Banking Group). — Monthly
  - 3 Report on the Cash Turnover. — Monthly
  - 4 Information on Transactions with the Use of Payment Cards and on the Infrastructure, Intended for the Performance with or Without the Use of Payment Cards of Transactions for the Issue (Acceptance) of Ready Cash and of Payments for Commodities (Works, Services). — Quarterly
  - 5 Information on the accounts of clients and the payments carried out through the credit organization (its branch). — Quarterly
  - 6 Information on settlements between residents and non-residents for the performance of works, rendering of services, information transfer, results of intellectual activity, operations of a non-commercial character and for the goods that do not cross the border of the Russian Federation. — Monthly
  - 7 Information on Operations with Securities, Stakes, Partner Shares and Deposits in the Property Made Between Residents and Non-residents — Monthly
  - 8 Report on Operations with Foreign Money Cash and Cheques in Foreign Currency. — Monthly
  - 9 Information on the Opened Correspondent Accounts and on the Residuals of Funds on Them. — Monthly
  - 10 Report on currency transactions made on bank accounts and on the clients’ accounts at the authorized banks. — Monthly
  - 11 Report on Currency Transactions the Performance of Which Envisages the Formalization of the Passport of the Transaction. — Monthly
  - 12 Report on Transactions on the Currency and Money Markets. — Daily
  - 13 Report on Securities. — Monthly
  - 14 Bank Control Record on the Contract (also see appendix 6 to Instruction of the CBR No138-I). — Monthly
  - 15 Report on Observance of Foreign Exchange Control legislation by credit institutions and AML/CFT legislation by credit institutions and non-credit FI (submitted by CBR territorial units). — Irregular basis (when information is available)
  - 16 Information on types and volume of transactions conducted by non-credit financial institutions. — Monthly
  - 17 Report on off-exchange transactions. — Monthly

*Source: EXECUTIVE SUMMARY and selected sections from the Technical Note prepared for the FSAP on the Russian Federation (IMF staff report excerpts provided in the content unit).*

### EXECUTIVE SUMMARY __________________________________________________________________________ 4

### EXECUTIVE SUMMARY

### INTRODUCTION
- This Technical Note (TN) provides a targeted review of the Russian Federation’s AML/CFT system in the context of the Financial Sector Assessment Program (FSAP).
- The TN focuses on: availability of beneficial ownership information; transparency of companies; preventive measures relating to PEPs; suspicious transaction reporting; and risk-based AML/CFT supervision in the banking sector.
- A full assessment against the current FATF standard will be conducted by the FATF, Eurasia Group and MONEYVAL and will be available in 2019.
- Staff analysis draws on the 2008 MER, documentation submitted by the RF to FATF and MONEYVAL, authorities’ written responses, and discussions during the mission from February 1–5, 2016 with CBR, Rosfinmonitoring, Ministry of Internal Affairs, Prosecutor General’s Office, Federal Taxation Service, Federal Security Service, and representatives of two banks.

### PROGRESS SINCE THE LAST ASSESSMENT
Findings
- The 2008 MER identified key deficiencies, including lack of adequate transparency of beneficial ownership and insufficient guidance to banks on foreign PEPs.
- Since 2008, authorities have taken significant steps to strengthen the AML/CFT regime:
  - Aligned the definition of “beneficial owner” with the FATF standard.
  - Introduced a prohibition against individuals with criminal convictions acquiring or controlling a significant amount of shares in certain credit institutions (see Federal Law No. 134-FZ (June 28, 2013) and Federal Law No. 146-FZ (July 2, 2013)).
  - CBR issued guidelines for enhanced CDD for foreign PEPs and extended requirements to domestic PEPs.
- Owing to progress, the RF exited FATF’s follow-up process in 2013.
- The FATF standard and methodology were revised in 2012 and 2013. The revised standard places greater emphasis on a risk-based approach and on assessing effectiveness.
- The RF is scheduled to undergo a comprehensive assessment under the prevailing standard in late 2018, with plenary consideration of the draft MER scheduled for June 2019.

### ASSESSING AND UNDERSTANDING RISK — A. Context and Risk
Findings on threats and vulnerabilities
- 2008 MER: main ML/TF risks related to the abuse of shell companies (“one-day” firms).
- Rosfinmonitoring assesses ML/TF threats based on STRs, CTRs, and other information; a Center of Risk Assessment of ML/TF (CRA) was established and reports annually to the President.
- Rosfinmonitoring’s CRA and Rosfinmonitoring more broadly coordinate with many state bodies (e.g., Federal Tax Service, Ministry of Internal Affairs, Ministry of Finance, Rosfinnadzor, Federal Treasury, Prosecutor’s General Office, Investigation Committee, Federal Drug Control Service, Federal Customs Service, Federal Security Service, the CBR, Rosstat, Russian Assay Office).
- Main ML threats identified:
  - Fraud (e.g., account fraud, fraudulent loans, and identity fraud) is the most common predicate crime detected.
  - Corruption is a key concern given perceived size of proceeds; corruption in defense industry and construction highlighted by CRA.
  - Russia’s Transparency International Corruption Perception Index improved to 119 (out of 168 countries) in 2015 from 136 (out of 174 countries) in 2014.
  - Presidential Decree No. 147 (April 1, 2016) established an anti-corruption plan focusing on improving beneficial ownership information, exposing corruption, and enhancing international cooperation.
- TF threats identified:
  - Activities of armed gangs in the North Caucasus, operations of cells of international terrorist organizations in Russia, and Russian citizens travelling to conflict areas (e.g., Islamic State of Iraq and Levant).
- Vulnerabilities:
  - One-day firms present particular ML vulnerability; authorities reported more than two trillion roubles of financial transactions (volume) were reportedly carried out by these shell companies in 2015.
  - Technologies (e.g., wire transfers, crowdfunding, e-payment systems, mobile banking) identified as vulnerabilities for TF due to anonymity and ease of small-value transfers.

### ASSESSING AND UNDERSTANDING RISK — B. Conclusions and Recommendations
Findings and implications
- Some authorities have improved understanding of ML/TF risks, but understanding may be limited because analysis relies mostly on Rosfinmonitoring and CBR reports and on data provided predominantly by the banking sector.
- This limited scope could understate criminal proceeds in other sectors (e.g., real estate, lawyers, and precious metals and stones).
- Authorities have initiated the NRA process, which will involve broad stakeholders and should lead to a national strategy to prioritize AML/CFT policies and activities and enable risk-based approaches across agencies.

Recommendations (from Table 1: Main FSAP Recommendations for AML/CFT)
- Assessing and Understanding ML/TF Risks
  - i. To complete and share the results of national assessment of ML/TF risks — Priority: Near
  - ii. To prepare a national AML/CFT strategy that would prioritize AML/CFT policies and activities and allow the use of risk based approach by concerned authorities — Priority: Intermediate

### TRANSPARENCY AND BENEFICIAL OWNERSHIP OF LEGAL PERSONS IN RUSSIA
Findings
- Authorities took measures to prevent abuse of Russian companies for ML/TF purposes, including strengthened legal requirements on beneficial ownership and a law for identifying Russian tax residents who are beneficial owners of foreign companies (“de-offshorization”).
- BO information is accessed and shared when available and often in a timely manner, but availability and accuracy need improvement.
Recommendation
- Entity Transparency and availability of beneficial ownership information
  - i. To improve the availability and accuracy of BO information (through the customer due diligence of banks, the creation of a register for BO information or requiring companies to have relevant BO information at the premises level) and ensure robust implementation of sanctions against persons who do not comply with the information requirements — Priority: Near

### PREVENTIVE MEASURES — POLITICALLY EXPOSED PERSONS AND REPORTING OF SUSPICIOUS TRANSACTIONS
Findings
- Preventive measures updated and largely in line with FATF standards, but:
  - PEPs definition requires further amendments to fully align with FATF (to include all categories of prominent public officials, family members, associates, including when PEPs are beneficial owners).
  - Effectiveness of measures should be enhanced.
- Suspicious transaction reporting system generates a significant quantity of reports, but quality of reporting needs improvement to match ML/TF risk profile of Russia.

Recommendations
- Preventive Measures
  - i. To ensure that the definition of PEPs fully aligns with the FATF standards to include all categories of prominent public officials, family members, associates including when PEPs are beneficial owners — Priority: Near
  - ii. To provide guidance to banks in identifying and accepting, and managing business relations with customers who are PEPs, including for domestic PEPs, their family members and associates — Priority: Intermediate
  - iii. Provide guidance on typologies and timely feedback to banks on quality of suspicious transactions reports to align the reporting with the ML/TF risks in Russia — Priority: Near

### AML/CFT SUPERVISION — RISK BASED APPROACH AND SANCTIONS
Findings
- AML/CFT supervision of banks is comprehensive and sanctions are effective, but:
  - The existing risk-based supervisory methodology appears limited, relying on a checklist of predetermined criteria rather than robust analysis of indicators of ML/TF risks.
  - Comprehensive data on nature and potential exposure to ML/TF risks at institutional level could improve implementation of risk-based supervisory tools.
- Sanctions, particularly revocation of bank licenses for AML/CFT violations, have ramped up in recent years and are considered effective and dissuasive, leading to improved compliance of banks.

Recommendations
- Supervision
  - i. To improve the CBR’s identification and understanding of ML/TF risks and controls, and develop further the risk-based approach tools for offsite and onsite supervision (with a focus on PEP and BO-related requirements) — Priority: Near
  - ii. To ensure effective implementation of a broad range of sanctions against financial institutions that are dissuasive and proportionate to the severity of the AML/CFT violations — Priority: Intermediate

*Source: EXECUTIVE SUMMARY, Technical Note prepared for the FSAP on the Russian Federation.*

### 11.      The revised FATF standard now calls on countries to identify, assess, and understand

### _cr16305 - 11.      The revised FATF standard now calls on countries to identify, assess, and understand

### National Risk Assessment (NRA) and AML/CFT policy framework
- The RF authorities initiated an NRA expected to be completed early 2017.
- Presidential Decree No. 103, dated March 8, 2016, authorizes Rosfinmonitoring to organize an NRA and foresees the involvement of the CBR, relevant federal executive bodies, other state bodies and organizations, and representatives of the financial sector.
- The authorities will rely on FATF guidelines on data and statistics and inputs from MONEYVAL and the OSCE.
- Under the proposed amendment, a public sanitized version of the results of the NRA will be published on Rosfinmonitoring’s website.
- The authorities do not currently have a national AML/CFT strategy; some related national policies and activities address main ML/TF risks, while others are under consideration.
- Recent legislative measures include:
  - Federal Law No. 110-FZ (May 5, 2014): enhanced customer identification for new technologies (e.g., transfers between individuals and cross-border money transfers).
  - Federal Law No. 424-FZ (December 30, 2015): obliges FIs to conduct customer identification of foreign entities without legal personality (e.g., trusts, foundations, partnerships) and strengthens information exchange between the CBR and Rosfinmonitoring on customers of FIs involved in ML/TF.
- A draft law requiring legal entities to identify and document their beneficial owners and providing penalties has been submitted to parliament.
- An interdepartmental commission on combatting TF was created and work is underway to strengthen criminal penalties for involvement in terrorist activities, including aiding and abetting.
- Authorities have engaged the private sector to raise awareness on some identified ML/TF risks.
- Authorities have not adopted a comprehensive strategy(ies) or policy(ies) to address risks and enhance framework effectiveness through better use of resources; they may do so after completing the NRA.

### Understanding of ML/TF threats, vulnerabilities, and sectoral risks
- Authorities’ understanding of ML threats relies heavily on Rosfinmonitoring’s analysis of STRs and CTRs provided mostly by the banking sector and may understate magnitude and ignore contributing crimes such as tax evasion, corruption, and fraud in other sectors (e.g., real estate, nonbank FIs).
- In transnational ML activity, authorities showed some understanding of destinations used for laundering and common understanding of how proceeds move in and out of Russia through the banking sector; understanding of the volume and laundering through other channels was less developed.
- Conflicting assessments were presented about the main assets used for ML in Russia:
  - Some viewed Russian ML as mainly cash or “near cash” based.
  - Others understood activities also involved purchase of nonfinancial assets (such as real property or other high value goods).
- Overall, understanding of risks related to the financial sector was higher than for DNFBPs.

### Conclusions and recommendations on ML/TF risk assessment
- Authorities are making efforts to identify, assess, understand and mitigate the RF’s ML/TF risks, but further action is needed to finalize and communicate the results of the NRA.
- Recommended actions:
  - Proceed with the planned assessment of national ML/TF risks prior to the scheduled FATF/EAG/MONEYVAL assessment in 2018.
  - Use an inclusive and multi-faceted approach to assessing ML/TF risks, relying on qualitative and quantitative information beyond STRs and CTRs from all concerned agencies, reporting entities including DNFBPs, and academics.
  - Share a sanitized version of the main results of the NRA with all concerned agencies and the private sector.
  - Based on NRA results, adopt and communicate a national AML/CFT strategy and propose prioritized action items to address and mitigate identified ML/TF risks.
  - Use the strategy as the foundation for efficient allocation of resources across the AML/CFT regime and implementation of risk-based measures.

### Transparency and beneficial ownership of legal persons — background and risk
- Types of legal entities in the RF include: general partnerships, limited partnerships, limited liability companies, double liability companies, joint stock companies, production co-operatives, and unitary enterprises.
- Information on creation and types of legal persons is available online through the Federal Tax Service (FTS) website.
- As of end-2015, 4,820,432 legal entities were registered in Russia, most of which were limited liability companies.
  - The number includes:
    - 3,962,627 limited liability companies;
    - 126,074 joint stock companies;
    - 21,650 production co-operatives;
    - 23,262 unitary enterprises.
- All legal persons are required to provide to the Unified State Register of Legal Entities (USRLE) basic information: legal form, information on founders, identity of persons entitled to act on behalf of the entity, taxpayer identification number, and information on bank accounts.
- At the time of the 2008 MER, commercial entities were not required to retain beneficial ownership information or register such information in the USRLE, and there was no explicit requirement for FIs or DNFBPs to identify beneficial owners.
- Shell or “one-day” companies pose a high risk and are often used as fronts to open bank accounts without revealing beneficial owners; corporate vehicles are commonly used to veil beneficial owners and integrate illicit proceeds.

### Availability of beneficial ownership (BO) information
- A 2013 amendment to the AML/CFT law (Federal Law No. 134-FZ, June 28, 2013) added a definition of beneficial owner consistent with the FATF standard and required FIs and DNFBPs to identify and verify beneficial owners.
  - “Beneficial owner means for the purposes of this Federal Law a natural person who directly or indirectly (through third persons) owns (has a predominant stake of over 25 percent in the capital of) a client being a legal entity or has the possibility of controlling the actions of the customer.” (Federal Law No. 115-FZ, as amended).
- The amended framework is broadly in line with the revised FATF standard:
  - Where no natural person is identified as BO of a legal person, FIs should identify and take reasonable measures to verify the identity of the relevant natural persons who hold the position of senior managing official (FATF, Interpretative Note to Recommendation 10.5).
  - FIs are not explicitly prohibited from establishing or continuing business relations where BO cannot be identified or verified, but are prohibited from opening an account when the customer refuses to provide BO information, may refuse to carry out transactions, and may terminate the contract (Federal Law No. 115-FZ, as amended, Article 7).
  - The RF law allows that in cases of failure to identify the BO, the FI may recognize the sole executive body (position of senior managing official) as the BO (Federal Law No. 115-FZ, Article 7).
  - In implementation, banks might often designate the senior manager as BO; the law and regulations should clarify such measure should be a last resort.
- The “de-offshorization” law (Federal Law No. 376-FZ (November 24, 2014)) provides a framework for determining Russian tax residents who are beneficial owners of foreign companies and defines controlled foreign company (CFC) thresholds:
  - A Russian tax resident is deemed to be a controlling person of a CFC if his/her participation or interest in the CFC is at least 50 percent during 2015 and 25 percent thereafter.
- Russia has international tax cooperation instruments:
  - The RF currently has 81 bilateral agreements (text notes also state 80 in another sentence).
  - Russia signed 11 intergovernmental agreements on cooperation and mutual assistance on tax compliance with CIS states.
  - In 2015, the OECD Multilateral Convention on Mutual Administrative Assistance in tax matters came into effect for Russia, ensuring exchange of information with 80 jurisdictions.

### Limitations in BO transparency and recent initiatives
- None of the current systems in the RF achieves adequate transparency regarding beneficial ownership of legal persons.
- Authorities indicated FIs provide a virtual national beneficial ownership registry since every legal person is required to have an account in an FI and FIs are required to identify the beneficial owner (FATF, Russian Federation: 6th Follow-Up Report (October 2013)).
- Doubts remain whether identification and verification of BO information by FIs are effective and adequately robust; BO information collected by FIs via CDD is not always available, up-to-date, or accurate when requested by concerned agencies.
- A bill (Bill No. 96535-6) was submitted to parliament to require all legal entities to keep and periodically update BO information within their principal office and provide such information at the request of Rosfinmonitoring or other authorized federal executive bodies; the bill would allow imposition of administrative liabilities and fines for non-compliance.
- Authorities did not provide information on sanctions imposed on FIs for failing to identify beneficial ownership, limiting contextual assessment of FI implementation.

### Access to BO information by concerned agencies
- Rosfinmonitoring, FTS, and Law Enforcement Agencies (LEAs) have timely access to basic information of legal persons and bank accounts held by natural and legal persons.
- Through the taxpayer identification number, the FTS has timely access to accounts held by natural and legal persons; LEAs and Rosfinmonitoring can access such information via the FTS.
- LEAs’ actions to access BO information are limited:
  - STRs and CTRs collected by Rosfinmonitoring can indicate BO information, but banks’ BO identification is often not thorough, limiting value of BO information in STRs.
  - LEAs make little use of special investigative techniques to locate ultimate beneficial owners; investigations often start with publicly available USRLE information.
  - Mutual legal assistance is sometimes required to trace BO information across borders; authorities indicated it can be challenging, slow, and not used very often.

### Conclusions and recommendations on beneficial ownership
- Authorities should continue taking concrete steps to improve availability of BO information of legal persons in the RF.
- Recommended actions:
  - Conduct a comprehensive assessment (through the NRA, if possible) to obtain more granular understanding of risks of legal persons being misused for ML and TF.
  - Ensure banks properly identify customers’ beneficial owners and verify their identity.
  - CBR and Rosfinmonitoring should provide further guidance and education to banks on steps to identify ultimate beneficial owners and clarify that reliance on the customer’s self-declaration is not sufficient—FIs should verify information independently.
  - Enhance effective implementation of strengthened BO requirements, including imposition of penalties for non-compliance.
  - Ensure effective implementation of the draft bill establishing requirements for legal entities to provide and disclose BO information.
  - Authorities could consider, as an alternative to the draft bill, creating a public registry for beneficial ownership information.

### Preventive measures — Politically Exposed Persons (PEPs) and suspicious transaction reporting
- Banks in the RF are required to take reasonable measures to identify foreign and domestic PEPs, and officials of public international organizations, including:
  - Securing management approval before establishing business relationships with PEPs;
  - Identification of the sources of funds or origins of their monetary assets or property;
  - Regularly updating information on such persons (Federal Law No. 115-FZ, as amended, Article 7.3);
  - Paying special attention to transactions made by PEPs and their family members (Federal Law No. 115-FZ, as amended, Article 7.3).
- Shortcomings in the PEP framework:
  - The AML/CFT law’s PEP definition appears limited to public officials appointed by the President, potentially excluding important political party officials and senior politicians not appointed by the President.
  - References to parliamentarians are indirect: PEP definitions refer to members of committees and commissions of the Parliament, and according to the Regulation of State Duma, all parliamentarians must be members of committees and commissions.
  - The FATF standard requires scope of PEPs based on prominent public functions rather than appointing power.
  - The restrictive definition can restrain banks’ application of enhanced due diligence and increase risk of failing to identify and report suspicious transactions of high-level public officials not appointed by the President.
  - The AML/CFT law needs clarification to ensure enhanced measures apply to beneficial owners who are PEPs.
  - Banks are required to pay special attention to transactions of PEPs and their family members, but not explicitly to close associates or PEPs who are beneficial owners as prescribed by the revised FATF standard.

*Source: IMF staff report text as provided in the content unit.*

### 29.      The gaps in the preventive measures against PEPs consequently affect the banks’

### _cr16305 - 29.      The gaps in the preventive measures against PEPs consequently affect the banks’

### Gaps in preventive measures for PEPs — findings
- AML/CFT supervision of banks’ compliance with PEP requirements is limited and may not ensure banks are effectively monitoring ML risks from PEPs.
- Only a small percentage of customers have been identified by banks as PEPs.
- Low identification rate of PEPs may be due to:
  - banks’ inadequate understanding or capacity to identify customers as PEPs, aside from the limited definition under the law;
  - a limited definition of PEPs under the law.
- No data was provided by authorities on sanctions for violations by FIs of requirements regarding PEPs.
- CBR inspections do not focus sufficiently on the level of compliance and adequacy of banks in implementing the PEP requirements in line with the standard.

### PEPs — recommendations
- Bring the definition of and measures for PEPs in line with the FATF standard.
- Provide guidance from relevant supervisors on:
  - identifying PEPs, family members, and close associates;
  - identifying PEPs who are beneficial owners;
  - best practices in implementation of preventive measures to assist banks in strengthening their systems.

### Suspicious Transaction Reports (STRs) — legal framework and scope
- Under the revised FATF standard, if a FI has reasonable grounds to suspect that funds are proceeds of a criminal activity, or are related to terrorist financing, it should be legally required to promptly report its suspicions to the financial intelligence unit.
- All suspicious transactions, including attempted transactions, should be reported regardless of the amount of the transaction.
- FIs are required to submit to Rosfinmonitoring information on transactions for which there is a suspicion that they are carried out for ML/TF purposes and transactions subject to compulsory control (in excess of RUB 600,000).
- Attempted transactions of customers with an existing business relationship and of occasional customers are covered.

### STRs — data and quality findings
- In 2014, Rosfinmonitoring reported receiving over 11 million suspicious transaction reports (STRs) with an estimated value of RUB 160 trillion (most of which were sent by credit institutions).
- The number of criminal cases initiated based on information provided by Rosfinmonitoring reportedly rose from 500 in 2013 to 1,500 in 2014.
- Of the 11 million STRs in 2014:
  - those filed on the sole basis of suspicions by reporting entities amounted to more than six million in 2014 and rose to eight million in 2015.
  - total STRs filed with respect to PEPs (foreign, domestic and international organizations) was less than 100 in both years.
- Rosfinmonitoring considers the FI suspicious transaction reporting system to be functioning well:
  - a single telecommunications network is provided to FIs to submit STRs;
  - the automated system filters incoming STRs and rejects improperly generated STRs for return to the sending FIs;
  - Rosfinmonitoring publishes newsletters and typology reports to guide reporting entities.
- Rosfinmonitoring sends some collected information to the CBR regarding potential violations of STR regulations by reporting FIs; the CBR uses the information in supervisory activities to discuss with FIs efforts to improve STR quality.

### Concerns about CBR predetermined criteria and reporting behavior
- CBR predetermined criteria may not be comprehensive enough to cover all potential ML/TF risks and may limit banks’ appreciation of suspicious transactions.
- The transmission system relies on predetermined criteria provided and updated regularly by the CBR, offering little flexibility for FIs to assess suspicious transactions.
- CBR inspections focus heavily on compliance with predetermined reporting criteria.
- Several sanctions (including revocation of licenses) were imposed because banks failed to report suspicious transactions later determined to be suspicious by the CBR.
- Such systems can lead to over-reporting or defensive-reporting.
- Criteria provided by the CBR demonstrate some shortcomings in scope and do not necessarily cover all possible scenarios of suspicious transactions.

### Rosfinmonitoring’s view on STRs and feedback
- Rosfinmonitoring views that significant improvement has been made in the quality of STRs received from the banking sector in recent years.
- STRs do not appear to correlate with the RF’s ML/TF risks:
  - STRs relating to PEPs are not commensurate with the ML risks;
  - most reports concern unusual transactions rather than suspicions of laundering of proceeds of crimes.
- Rosfinmonitoring, in consultation with CBR, provides good quality general guidance on STRs but could improve case-by-case feedback to FIs.
- More case-by-case feedback about STRs and their outcomes (e.g., closed, disseminated) would assist FIs in improving quality of STRs.
- When completed, the results of the NRA should be shared with FIs to improve their understanding and quality of suspicious reports to align them with ML/TF risks in Russia.

### Conclusions and recommendations (PEPs and STRs)
- Ensure the definition of PEPs is fully in line with the FATF standard.
- Provide guidance to FIs to assist in identifying and dealing with PEPs (including beneficial owners, family members, or close associates).
- Rosfinmonitoring, in coordination with CBR, should provide additional guidance and timely, case-by-case feedback to FIs on the reporting of suspicious transactions.
- Share NRA results with FIs to improve alignment of STRs with ML/TF risks in Russia.

### AML/CFT supervision — risk-based approach (findings)
- Since the 2008 comprehensive assessment, the CBR has increased resources, including a merger enabling a three years’ inspection cycle; FATF concluded in the 2013 progress report that technical requirements for supervision and sanctions were largely in line with the previous standard and methodology.
- The CBR applies a risk-based approach to AML/CFT supervision of FIs, relying on:
  - regular analysis of the 17 reporting forms from banks;
  - information from Rosfinmonitoring on the level of STRs;
  - LEAs’ investigations;
  - analysis of internal databases and direct contacts with FIs.
- The CBR gives undue reliance on risk mitigation based on a checklist of predetermined criteria, rather than on robust analysis of indicators of inherent ML/TF risks of banks.
- CBR offsite activity centers on review of 17 categories of reporting, but information on ML/TF risks of the sector, risk profiles of individual institutions, and their level of AML/CFT compliance are insufficient.
- There is no well-defined, documented methodology that integrates findings for operational risk into a rating that accounts for inherent risk and risk mitigants to prioritize banks for supervisory oversight.
- The risk-based methodology does not seem to capture information relating to the level of compliance of AML/CFT measures in individual banks, including exposure to PEPs or weak implementation of beneficial ownership requirements.

### CBR inspections — activity and limitations
- Supervisors regularly conduct scheduled and unscheduled on-site inspections.
- From 2013 to 2015:
  - more than half of all total scheduled inspections included AML/CFT issues, with several inspections devoted exclusively to AML/CFT concerns.
  - approximately 20% of all unscheduled inspections involved AML/CFT issues.
- CBR’s understanding of risks relating to banks and its supervisory tools could be enhanced to provide comprehensive, timely and consistent data on inherent ML/TF risk at the institutional level.

### Sanctions — findings and recommendations
- The number of active banks decreased from 1,351 as of January 31, 2006 to 945 registered banks, owing to revocation of licenses, mergers and acquisitions, and unilateral decisions to close the business.
- Licenses revoked by the CBR due to AML/CFT violations sharply increased in 2014 (36 licenses, 11 of which were based solely on AML/CFT violations), surpassing the total number from 2011 to 2013.
- The trend continued with 34 revoked bank licenses in 2015 involving AML/CFT violations; revocations involved both small and larger banks.
- Among license revocations due to AML/CFT violations, most were due to failure of banks to report suspicious transactions.
- Recommendation: CBR should pursue a more graduated approach to sanctions to ensure sanctions are proportionate to the severity and frequency of violations or the inspection score.
- Recommendation: Apply the range of sanctioning powers in a manner proportionate to severity of identified breaches or the rating assigned resulting from the inspection.

### Annex I — Reporting Forms for Offsite AML/CFT Supervision of Banks (inventory)
- Numbered reporting forms (1–17) with stated periodicity:
  - 1 Turnover Sheet of the Credit Institution's Business Recording Accounts. — Monthly
  - 2 Information on the Standard of the Credit Institution's Assets (Banking Group). — Monthly
  - 3 Report on the Cash Turnover. — Monthly
  - 4 Information on Transactions with the Use of Payment Cards and on the Infrastructure, Intended for the Performance with or Without the Use of Payment Cards of Transactions for the Issue (Acceptance) of Ready Cash and of Payments for Commodities (Works, Services). — Quarterly
  - 5 Information on the accounts of clients and the payments carried out through the credit organization (its branch). — Quarterly
  - 6 Information on settlements between residents and non-residents for the performance of works, rendering of services, information transfer, results of intellectual activity, operations of a non-commercial character and for the goods that do not cross the border of the Russian Federation. — Monthly
  - 7 Information on Operations with Securities, Stakes, Partner Shares and Deposits in the Property Made Between Residents and Non-residents — Monthly
  - 8 Report on Operations with Foreign Money Cash and Cheques in Foreign Currency. — Monthly
  - 9 Information on the Opened Correspondent Accounts and on the Residuals of Funds on Them. — Monthly
  - 10 Report on currency transactions made on bank accounts and on the clients’ accounts at the authorized banks. — Monthly
  - 11 Report on Currency Transactions the Performance of Which Envisages the Formalization of the Passport of the Transaction. — Monthly
  - 12 Report on Transactions on the Currency and Money Markets. — Daily
  - 13 Report on Securities. — Monthly
  - 14 Bank Control Record on the Contract (also see appendix 6 to Instruction of the CBR No138-I). — Monthly
  - 15 Report on Observance of Foreign Exchange Control legislation by credit institutions and AML/CFT legislation by credit institutions and non-credit FI (submitted by CBR territorial units). — Irregular basis (when information is available)
  - 16 Information on types and volume of transactions conducted by non-credit financial institutions. — Monthly
  - 17 Report on off-exchange transactions. — Monthly

*Source: _cr16305 - 29.      The gaps in the preventive measures against PEPs consequently affect the banks’*

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_Source: https://www.imf.org/-/media/websites/imf/imported-full-text-pdf/external/pubs/ft/scr/2016/_cr16305.pdf_