Russia

Last updated: 28/04/2014


CENTRAL AUTHORITY FOR REPORTING

Federal Financial Monitoring Service (Rosfinmonitoring); fedsfm.ru


Rosfinmonitoring key functions:

  1. General regulation and coordination of anti-money laundering activity;
  2. Gathering and analysis of reports of suspicious transactions and other information;
  3. Prosecuting violations of anti-money laundering legislation;
  4. Transfer of collected data and analysis to the appropriate law enforcement authorities for further investigation and action;
  5. Direct anti-money laundering control for certain categories of organizations.

OTHER ANTI-MONEY LAUNDERING REGULATOR(S) [1]

The Government of the Russian Federation (RF Government); government.ru - responsible for anti-money laundering regulation.

The Central Bank of the Russian Federation (CBR); cbr.ru- responsible for anti-money laundering regulation and control over banks and other credit organizations, insurance companies, "professional participants in the securities market" (e.g. brokers, registrars, securities depositories and custodians, stock exchanges), investment funds and private pension fund management companies.

The Ministry of Finance (MinFin); minfin.ru - responsible for anti-money laundering regulation applicable to Regulated Persons (as defined below).

The Assay Chamber (under the supervision of MinFin); probpalata.ru - responsible for anti-money laundering control over entities engaged in trade in precious metals, gemstones and jewelry.

The Federal Supervision Service for Communications, Information Technologies and Mass Communications (Roscomnadzor); rkn.gov.ru - responsible for anti-money laundering control over postal service organizations.

The Federal Tax Service (FNS); nalog.ru- responsible for regulation of certain anti-money laundering issues. 


ARE LAWYERS COVERED BY ANTI-MONEY LAUNDERING LEGISLATION?

Yes. The Anti-Money Laundering Law (as defined below) includes advocates, notaries and legal services providers ("Lawyers") in the categories of professionals that are subject to the anti-money laundering special rules.


LIST THE LAWS REGARDING ANTI-MONEY LAUNDERING, INDICATING WHICH LAWS ARE APPLICABLE TO LAWYERS.

Anti-money laundering in Russia is governed by a number of laws and regulations; however, only some of these expressly apply to Lawyers.

Federal Law No. 115-FZ on Countering Legalization (Laundering) of Proceeds of Crime and Financing of Terrorism, dated 7 August 2001(the "AML Law") is the primary anti-money laundering law in Russia. Its provisions apply to organizations which carry out activities involving money or other assets, such as banks and credit organizations, professional participants in the securities market, insurance companies, leasing companies, and federal postal organizations ("Regulated Persons").

Lawyers are not expressly listed as Regulated Persons; however, Article 71 of the AML Law specifically applies to Lawyers.

The AML Law is complemented by multiple regulations issued by the RF Government, Rosfinmonitoring, MinFin and other governmental authorities.

Key regulations[2] include:


Regulations that apply to Lawyers and impose obligations or determine procedures

  • Resolution No. 82 of the RF Government on Approval of the Regulation for Submitting Information to the Federal Financial Monitoring Service by Advocates, Notaries and Legal or Accounting Services Providers, dated 16 February 2005 ("Resolution No. 82");
  • Order No. 245 of Rosfinmonitoring on Approval of the Instruction for Submitting Information to the Federal Financial Monitoring Service under Federal Law No. 115-FZ on Countering Legalization (Laundering) of Proceeds of Crime and Financing of Terrorism, dated 5 October 2009 ("Order No. 245");
  • Regulation on Client and Beneficiary Identification Requirements, with Consideration for a Level (Degree) of Risk of Client Involvement in Money Laundering or Terrorist Financing, approved by Order No. 59 of Rosfinmonitoring, dated 17 February 2011 ("Order No. 59");
  • Order No. 342 of Rosfinmonitoring, dated 28 November 2013 on Approval of Reference Codes to be Used by Organizations Effecting Cash or other Property Transactions, Individual Entrepreneurs, Advocates, Notaries and Persons Providing Legal or Accounting Services when Providing Information to the Federal Financial Monitoring Service.


Regulations that might apply to Lawyers

  • Resolution No. 667 of the RF Government on Approval of Requirements for Internal Control Rules Developed by Organizations Performing Transactions with Monetary Funds and Other Assets and Termination of Certain Government Acts, dated 30 June 2012 ("Resolution No. 667");
  • Letter No. 07-02-05/40858 of MinFin on Applying Legislation of the Russian Federation on Countering Legalization (Laundering) of the Proceeds of Crime and Financing of Terrorism, dated 2 October 2013 ("MinFin Letter No. 07-02-05/40858");
  • Information Letter No. 2 of Rosfinmonitoring, dated 18 March 2009, on the Procedure of Application of Federal Law No. 115-FZ, dated 7 August 2001 ("Rosfinmonitoring Information Letter No. 2");
  • Recommendations for Developing Criteria for Detecting and Identifying Characteristics of Unusual Transactions approved by Order No. 103 of Rosfinmonitoring, dated 8 May 2009 ("Rosfinmonitoring Recommendations No. 103");
  • Order No. 213 of Rosfinmonitoring on Approval of the Guidance for Information to be Included in the Report of Personnel Regarding Transactions (Deals) Subject to Mandatory Control, or Unusual Transactions (Deals), dated 11 August 2010 "Order No. 213").


Other important legislation

  • Decree No. 808 of the President of the Russian Federation on Regulations of the Federal Financial Monitoring Service, dated 13 June 2012;
  • Regulations on the Procedure for Compiling a List of Organizations and Individuals for whom there is Evidence of Participation in Extremist Activities or Terrorism and on Communication of such List to Organizations Effecting Cash or other Property Transactions approved by Resolution No. 27 of the RF Government, dated 18 January 2003;
  • Resolution No. 715 of the RF Government on Qualifying Requirements for Officers Responsible for Compliance with Rules of Internal Control and Programs to Ensure its Performance, as well as Requirements for Training and Development of Personnel, and Identification of Clients and Beneficiaries for the Purposes of Countering Legalization of Proceeds of Crime and Financing of Terrorism, dated 5 December 2005 ("Resolution No. 715");
  • Resolution No. 58 of the RF Government on Approval of the Regulation on Compulsory Registration with the Federal Financial Monitoring Service of Organizations Performing Transactions with Monetary Funds and Other Assets, and Individual Entrepreneurs in Spheres not Controlled by Oversight Bodies, dated 27 January 2014;
  • Resolution No. 209 of the RF Government on Approval of the Regulation on the Provision of Information to the Federal Financial Monitoring Service by Organizations Effecting Cash or other Property Transactions and by Individual Entrepreneurs and on Enquiries sent by the Federal Financial Monitoring Service to Organizations Effecting Cash or other Property Transactions and to Individual Entrepreneurs, dated 19 March 2014;
  • Order No. 203 of Rosfinmonitoring on Requirements for Personnel Training and Development in Organizations Performing Transactions with Monetary Funds and Other Assets for the Purpose of Countering Legalization of Proceeds of Crime and Financing of Terrorism, dated 3 August 2010;
  • Order No. 44 of Rosfinmonitoring on Approval of the Administrative Rules on the Provision by the Federal Financial Monitoring Service of a Service for Recordkeeping on Organizations Effecting Cash or other Property Transactions and whose Sphere of Action is not Supervised by Regulatory Authorities, dated 14 February 2012;
  • Order No. 192 of Rosfinmonitoring on Approval of the Administrative Rules Regarding Monitoring by the Federal Financial Monitoring Service and its Regional Bodies of Legal Entities and Natural Persons to Ensure Compliance with the Requirements of the Legislation of the Russian Federation on Countering Legalization (Laundering) of Proceeds of Crime and Financing of Terrorism and Holding Liable Persons Violating Such Legislation, dated 06 June 2012.


Russia is also party to the following international treaties covering anti-money laundering issues:


The requirements imposed by international treaties are beyond the scope of the present guidance and are mentioned for information purposes only.


ARE VISITING LAWYERS SUBJECT TO LOCAL LAWS REGARDING ANTI-MONEY LAUNDERING, AND, IF SO, TO WHAT EXTENT?

Russian AML Law applies to legal service providers. Therefore, visiting Lawyers will be subject to AML Law to the extent they fall under this category.


LIST ANY ANTI-MONEY LAUNDERING GUIDANCE FOR LAWYERS (FOR EXAMPLE, LAW SOCIETY OR BAR ASSOCIATION GUIDELINES) CURRENTLY IN PLACE.

I.          Lawyers

There is no professional association which governs the conduct of lawyers who are not advocates or notaries.

Lawyers may use as guidance certain Rosfinmonitoring anti-money laundering guidelines. In particular:

  • Rosfinmonitoring Recommendations No. 103; and
  • Rosfinmonitoring Information Letter No. 2.

MinFin Letter No. 07-02-05/40858 provides guidance for auditors and does not expressly include Lawyers as addressees. However, Lawyers are referred to in the document, and, collectively with auditors, defined as "service providers". The guidance given in certain sections of the letter then applies to service providers. Further, auditors and Lawyers are treated equally under the AML Law and Lawyers could therefore use MinFin Letter No. 07-02-05/40858 as guidance.
 

II.          Advocates

Lawyers who are registered as advocates must comply with the rules of the bar association of which they are a member, as well as the rules of the Federal Chamber of Advocates of the Russian Federation (the "Federal Chamber of Advocates").

The Federal Chamber of Advocates has issued a number of guidelines which apply to advocates, for example:

III.          Notaries

Notaries must comply with the rules of the regional notarial chambers of which they are a member, as well as the rules of the Federal Notarial Chamber. The Federal Notarial Chamber has issued guidelines on anti-money laundering applicable to notaries:

Some regional notarial chambers have also issued rules on anti-money laundering internal control which complement the guidelines issued by the Federal Notarial Chamber. However, such guidelines are generally not available publicly.


IS THE LAW SOCIETY/BAR ASSOCIATION INVOLVED IN SUPERVISING OR ENFORCING COMPLIANCE WITH ANTI-MONEY LAUNDERING REGULATIONS?

No. Members of the legal profession do not have a duty to supervise or enforce anti-money laundering regulations.


DESCRIBE CLIENT DUE DILIGENCE REQUIREMENTS, INCLUDING WHEN IT MUST BE UNDERTAKEN BY LAWYERS.

I.          Due Diligence

Lawyers must undertake due diligence measures when participating in or carrying out on behalf of a client, the following transactions:

  1. Transactions involving immovable property;
  2. Management of cash funds, securities or other assets of a client;
  3. Management of bank or securities accounts;
  4. Raising funds for the creation, operation or management of companies; and
  5. Creation, operation or management of legal entities, as well as the sale and purchase of legal entities.


Due diligence must be undertaken with regard to any legal entity regardless of the value of the transaction. Due diligence need not be performed on individuals if the value of the transaction is below RUB 15,000 (or equivalent), provided there is no suspicion that the transaction is done for the purposes of money-laundering or financing terrorism.

Under Articles 7 and 71 of the AML Law, Lawyers are required to identify a client by obtaining and verifying the following information:

a)  For individuals – surname, name, patronymic name (unless otherwise required by law or national custom), citizenship, date of birth, personal identification document details, migration card details and a document confirming the right of a foreign or stateless person to reside in Russia (if applicable), registered residential address, and taxpayer's identification number (if any);

b)  For legal entities – name, taxpayer's identification number (or tax code, if a foreign organization), state registration number, place of registration and address;

Client identification procedures and guidelines applicable to Lawyers are further detailed in Order No. 59. This states that the client identification process should include:

a)  Obtaining information required by Articles 7 and 71 of the AML Law;

b)  Checking for involvement in extremist activity;

c)  Identifying foreign public officials (applicable to clients who are individuals);

d)  Identifying the client’s location, registered address (place of residence) in the jurisdictions which do not follow the Recommendations enacted by the Financial Action Task Force (FATF) (The "FATF Recommendations") or using accounts with banks registered in such jurisdictions;

e)  Assigning a risk category; and

f)  Renewing information obtained as a result of the identification of the client or beneficiary.

The renewal of information must be completed at least annually for most clients, and at least every 6 months if the client falls into the “high risk” category.


Completing and maintaining a client questionnaire in the form approved by Order No. 59 is mandatory if:

a)  the surname, name and patronymic (if any), as well as other information available on the client fully coincides with information recorded in the list of organizations and individuals for whom there is evidence of participation in extremist activities,maintained by Rosfinmonitoring (the "Rosfinmonitoring List"); or

b)  there are grounds to suspect the client’s involvement in money laundering; or

c)  there exist grounds to record information; or

d)  the organization has assigned the client to a “high risk” category.


II.          Other Requirements

In addition to the due diligence requirements above, Lawyers are required to:

a)  Put into place internal controls, i.e. develop rules of internal control and programs to ensure their performance, appoint officers responsible for their compliance and take other internal organizational measures for these purposes, record the information obtained and preserve its confidential character; and

b)  Keep records and ensure safekeeping of documentation, i.e. documents containing client identification data must be kept for not less than five years from the date of termination of relations with the client.


DOES YOUR COUNTRY FOLLOW A RISK-BASED APPROACH TO CLIENT DUE DILIGENCE BY LAWYERS?

Yes. Russia follows a risk-based approach to client due diligence by Lawyers.

Lawyers are required to carry out certain due diligence to identify their clients. The identification requirements may vary depending on the level of risk of anti-money laundering operations carried out by a client (item 2 of Article 7 of the AML Law).

The AML Law requires Lawyers to develop rules of internal control and programs to ensure their performance, and recommends that risk assessment programs form part of these programs. Under item 14 of Resolution No. 667, a risk assessment program must estimate a client’s risk category based on the client’s operations and the types of activity it conducts which have a high risk of the client acting with the aim of money laundering or terrorist financing, taking into account the Recommendations enacted by the Financial Action Task Force (FATF) (The "FATF Recommendations").

Under item 2.14 of Order No. 59, the level of risk should be assessed at the stages of establishing a business relationship with a client, rendering services to a client, and in any other cases provided by the organization’s internal control rules.


ARE THERE ENHANCED DUE DILIGENCE MEASURES FOR CERTAIN TYPES OF CLIENTS, FOR EXAMPLE, POLITICALLY EXPOSED PERSONS?

Due diligence (identification) requirements may vary depending on the level of risk of anti-money laundering operations carried out by a client (item 2 of Article 7 of the AML Law).

Regulated Persons are required to take enhanced due diligence measures for certain types of clients. Because these measures are not expressly stated to apply to clients of Lawyers, it is unclear whether Lawyers are also subject to these enhanced measures.

Regulated Persons are required to take reasonable and practicable measures to identify amongst current and potential clients foreign public officials, officials of international organizations, state servants of the Russian Federation and certain other categories of individuals per Article 73 of the AML Law (e.g., officers of the state federal services appointed by the President or the RF Government, employees of the CBR, etc). Regulated Persons are required to take additional due diligence steps when rendering services to such clients.

Under Article 73, foreign public officials and officials of international organizations are defined under the FATF Recommendations.

As a general rule, Regulated Persons can accept foreign public officials and officials of international organizations as clients on the basis of a written decision of the director of the Regulated Person, who is also responsible for regularly updating the identification information obtained about foreign public officials.

Regulated Persons involved in providing services to foreign public officials and officials of international organizations are obliged to identify the origin of their assets. Regulated Persons are also required to pay close attention to transactions made by or on behalf of their spouses or relatives of foreign public officials.

Similar scrutiny applies to "high risk" financial operations of state servants of the Russian Federation and certain other categories of individuals per Article 73.


ARE THERE SIMPLIFIED DUE DILIGENCE MEASURES FOR CERTAIN TYPES OF CLIENTS, FOR EXAMPLE, LISTED COMPANIES?

No. Russian anti-money laundering legislation does not provide for simplified due diligence requirements with regard to any types of clients. 


ARE LAWYERS PERMITTED TO RELY ON THIRD PARTY DUE DILIGENCE? IF YES, PLEASE DESCRIBE.

No. Lawyers are not permitted to rely on third party due diligence, and are required to collect the required data directly from their clients.


WHEN IS A LAWYER UNDER AN OBLIGATION TO REPORT SUSPICIOUS TRANSACTIONS?

Lawyers are required to report their clients' transactions to Rosfinmonitoring if they suspect a transaction is performed or may be performed with the purpose of legalizing proceeds of crime or for financing terrorism ("suspicious transaction").

Such reports should be made no later than one business day following the day of identifying of the suspicious transaction.

Procedures for making the reports are determined by Resolution No. 82 and Order No. 245.

An advocate and a notary may submit such information both independently and through corresponding advocates' and notaries' chambers if such chambers have concluded an agreement on cooperation with Rosfinmonitoring. Currently, the following agreements are in place:

  • Cooperation Agreement No. 01-1-13/11 between the Rosfinmonitoringof the Russian Federation and the Federal Chamber of Advocateson Countering Legalization of Proceeds of Crime and Financing of Terrorism, dated 12 July 2007.; and
  • Cooperation Agreement No. 01-1-13/10 between the Rosfinmonitoringand the Federal Notarial Chamberon Countering Legalization of Proceeds of Crime and Financing of Terrorism, dated 12 July 2007.


The report can be made either by submitting a hard copy document signed by the respective Lawyer (or representative of the law firm) and affixed with a seal (if any), or by email signed with an electronic digital signature submitted via encrypted software provided by Rosfinmonitoring.

The report should include information necessary to identify the client, the type of transaction and grounds for its settlement, the date and amount of the transaction, as well as the circumstances which give reason to believe that the transaction is carried out for the purpose of laundering of the proceeds of crime or financing of terrorism.

Templates for reports of suspicious transactions are provided in Order No. 245.

The abovementioned provisions do not apply to information covered by attorney-client privilege under Federal Law No. 63-FZ on Advocacy and the Activities of Advocates in the Russian Federation, dated 31 May 2002(the "Advocacy Law").


DOES ATTORNEY/CLIENT PRIVILEGE AND/OR DUTIES OF CONFIDENTIALITY PROVIDE A DEFENCE OR PARTIAL/TOTAL EXCEPTION TO THE REQUIREMENT TO REPORT SUSPICIOUS TRANSACTIONS?

Yes, but to a limited extent only.

The Advocacy Law respects attorney-client privilege. Advocates are therefore not required to report information covered by attorney-client privilege, which includes any and all information relating to an advocate's legal advice to a client (Advocacy Law Article 8; AML Law Article 71). All other categories of Lawyers are not covered by this exception.


DOES LOCAL LAW PROVIDE ANY CRIMINAL AND/OR CIVIL INDEMNITY TO A LAWYER WHO HAS REPORTED A SUSPICIOUS TRANSACTION?

The AML Law provides only a civil indemnity for Regulated Persons. Lawyers are not expressly covered by this indemnity.

The reporting of required information does not constitute a violation of professional or commercial secrets (item 8 of Article 7 of the AML Law).

Suspension of operations and refusal to execute a client's instructions if carried out in accordance with applicable laws will not give rise to civil liability for violation of the relevant agreements (item 12 of Article 7 of the AML Law).


ONCE A SUSPICIOUS TRANSACTION REPORT HAS BEEN FILED, IS A LAWYER ALLOWED TO PROCEED WITH THE LEGAL ADVICE/TRANSACTION, AND, IF SO, MUST CONSENT FROM AUTHORITIES BE OBTAINED FIRST?

There is no direct or clear guidance concerning how a Lawyer must proceed after filing a suspicious transaction report. The rules exist for Regulated Persons (item 10 of Article 7 of the AML Law).

Under these rules, Regulated Persons must suspend their service to clients for five business days from the date on which the clients' instruction should have been executed, and immediately inform Rosfinmonitoring if either party to a transaction is:

  • a legal entity is directly or indirectly owned by persons recorded in the Rosfinmonitoring List, or is an individual or a legal entity acting on their behalf or at their instruction; or
  • an individual recorded in the Rosfinmonitoring List on the basis of grounds provided for in sub-items 2, 4 and 5 of item 2.1 of Article 6 of the AML Law.


If the transaction is not suspended by Rosfinmonitoring within the specified period, the Regulated Person may proceed with carrying out its client's instructions, unless another restricting decision is made.

This requirement does not expressly apply to Lawyers.


IS THERE A TIPPING-OFF PROHIBITION? IF YES, PLEASE DESCRIBE.

Yes. Lawyers are prohibited from informing their clients of the suspicious transactions reports (Article 7 of the AML Law).


DESCRIBE ANY RESTRICTIONS ON ACCEPTING A NEW CLIENT.

Generally there are no direct restrictions on accepting a new client. However, advocates are prohibited from accepting a new client or matter if the services sought are for an obviously illegal nature (Article 6 of the Advocacy Law).


ARE THERE ONGOING MONITORING REQUIREMENTS FOR EXISTING CLIENTS? IF YES, PLEASE DESCRIBE.

Yes, there are ongoing monitoring requirements for existing clients applicable to Lawyers.

Under Items 2.10 and 2.17 of Order No. 59, Lawyers are obliged to regularly update information on their clients not less than every six months in the case of high risk anti-money laundering activities of their clients, and not less than annually in other cases. Updates are also required in case of suspects that clients operations may be connected with money laundering or financing of terrorism.


DESCRIBE ANY OTHER WAYS IN WHICH LAWYERS ARE AFFECTED BY ANTI-MONEY LAUNDERING LEGISLATION.

Under Article 13 of the AML Law, infringements of this law result in administrative, civil and criminal liability.
 

I.          Administrative Liability

Under Article 15.27 of the Code of Administrative Offences of the Russian Federation, violation of the anti-money laundering legislation will result in the following liability:

a)  Officers: a fine in the range of RUB 10,000 – RUB 50,000, or disqualification for a term between 1 to 3 years; and

b)  Legal entities: a fine in the range of RUB 50,000 – RUB 1,000,000, or administrative suspension of the activity for a term from 60 days up to 90 days.


II.          Criminal Liability

The Criminal Code of the Russian Federation prosecutes both (i) legalization (laundering) of monetary funds and other assets acquired by a person as a result of a crime (Article 174), and (ii) participation in legalization (laundering) of monetary funds and other assets acquired by other persons as a result of a crime (Article 1741). Sanctions are imposed on individuals and include:

a)  fines up to RUB 1,000,000, or in the amount of individual’s income for a period of up to 5 years;

b)  disqualification for up to 5 years;

c)  imprisonment for up to 7 years; and

d)  other sanctions, including restraint and compulsory labor.

A combination of the above sanctions may be imposed on a convicted person.


III.         Disciplinary Liability (applicable to advocates only)

Violation of anti-money laundering requirements by advocates may also lead to disciplinary measures, including termination of the advocate's status (Article 17 of the Advocacy Law; Articles 10.1 and 18 of the Advocate's Code of Ethics).


HAVE LAWYERS IN YOUR JURISDICTION BEEN IMPLICATED IN MONEY LAUNDERING, INCLUDING ANY TYPE OF COMPLAINT, ARREST OR PROSECUTION?

There is limited information on the prosecution of Lawyers involved in anti-money laundering activities available publicly.

According to the information available, there have been several court cases on the violation of anti-money laundering legislation by notaries. In these cases the notaries were accused of a failure to develop and adopt internal control rules, appoint compliance officers, and keep records required under the AML Law. Courts applied administrative fines as sanctions.


HAS THE FINANCIAL ACTION TASK FORCE (FATF) OR A FATF-STYLE REGIONAL BODY CONDUCTED A MUTUAL EVALUATION OF THIS COUNTRY, AND, IF SO, WHAT WERE THE FINDINGS CONCERNING LAWYERS’ COMPLIANCE WITH THE FATF 40+9 RECOMMENDATIONS?

Russia was placed in the FATF mutual evaluation report of June 2008 as requiring monitoring under a regular follow-up process. The report stated that the anti-money laundering requirements for Lawyers in Russia were generally incomplete or not effectively implemented. The report also expressed concern about the low numbers of suspicious transaction reports filed by lawyers.

In October 2013, the FATF recognized that Russia had made significant progress in addressing the deficiencies identified and could be removed from the regular follow-up process.



Information provided by:

Philip Korotin
Associate
pkorotin@morganlewis.com

Vasilisa Strizh
Partner
vstrizh@morganlewis.com

Morgan Lewis
Tsvetnoy Bulvar, 2 | Moscow 127051 | Russian Federation
Telephone: +7 495 212 2500 | Fax: +7 495 212 2400
www.morganlewis.com

 

Notes

  1. The present guidance covers governmental authorities only, and does not extend to non-commercial or non-governmental organizations.
     
  2. Some of the listed regulations are available on the official website of Rosfinmonitoring(fedsfm.ru), and more can be found on the Government’s website for legal information- pravo.gov.ru.
     
  3. The following constitutes grounds to record information (item 2 of Article 7 of the AML Law):
  • the transaction has a complex or unusual nature which does not have any obvious economic sense or legal purpose;
  • the transaction does not conform with the aims of the client’s activities as established by its foundation documents;
  • repeated transactions the nature of which gives reason to believe that they are carried out for the purpose of evading anti-money laundering control;
  • effecting a transaction for a client with respect to whom a competent authority has raised a query with the organization;
  • the client’s abandonment of a one-off transaction which employees of the organization suspect is being effected for the purposes of legalization/laundering
  • other circumstances which give reason to believe that a transaction is carried out for the purpose of laundering of the proceeds of crime or financing of terrorism.

 


Disclaimer

This article is provided as a general informational service. It should not be construed as, and does not constitute, legal advice on any specific matter, nor does this message create an attorney-client relationship. These materials may be considered Attorney Advertising in some jurisdictions. Please note that the prior results discussed in the material do not guarantee similar outcomes. Links provided from outside sources are subject to expiration or change. © 2014 Morgan, Lewis & Bockius LLP. All Rights Reserved.


 

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