6. Other relevant matters

a. Currency restrictions

From 19 June 2005, Russian residents are permitted to open bank accounts outside Russia without the need to obtain prior authorisation from the Russian Central Bank (although a reporting requirement remains in effect).

b. Anti-money laundering

As a member of the Financial Action Task Force (FATF), Russia has developed and enacted anti-money laundering legislation: Federal Law No. 115-FZ ‘On Combating Legalisation (Laundering) of Criminally Gained Income and Financing of Terrorism’, dated 7 August 2000.

Russian banks are required to: (i) establish and maintain internal systems ensuring compliance with Russian anti-money laundering legislation; (ii) monitor and record certain specified transactions; and (iii) report to the relevant authorities certain specified transactions. In certain cases Russian banks must suspend transactions for up to two business days and apply to the relevant controlling authority for approval.

Failure by Russian banks and their officers to comply with these requirements may result in sanctions, including the revocation of a banking licence (with a subsequent liquidation of the bank), limits on certain banking activities and criminal or administrative penalties for individuals.