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.