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Anti-Money Laundering: Specific Character of Russia & CIS countries

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Anti-Money Laundering: Specific Character of Russia & CIS countries
private intelligence & risk management company
Version as of Apr. 25, 2011
Anti-Money Laundering
Specific Character of Russia and CIS countries
CEO & Founder
Private intelligence company “R-Techno”
Roman V. Romachev
47, Volgogradskiy pr., Moscow, 109316
Tel./fax: +7 (495) 723-01-19
e-mail: r-techno@it2b.ru, www.r-techno.com
private intelligence & risk management company
Specific Character of Russia and CIS countries
Between 1991 and 2009 in Russia, “money laundering” schemes were far less popular than the so-called “conversion into cash”. Some
banking experts connect to the fact that the origin of capitals obtained illegally during that period of time captured interest neither of the
government nor of the citizens, and correspondingly no one required legitimization (laundering) of the capitals. This is what former
banker Aleksey Frenkel said about it:
Let’s start with terms. 5 years have just passed since the approval of the Federal Law No. 115-FZ On Counteraction of
Legitimization (Laundering) of the Proceeds of Crime and Financing of Terrorism. The banking sphere calls this statutory act
shortly – “Law 115”. And so will we. Let’s ponder over the meaning of the following phrase – “legitimization (laundering) of the
proceeds of crime”. A drug kingpin got an amount of money obviously from illicit sources, i.e. by selling drugs. He wants to buy
something useful for this money, such as a house, a yacht, a car or jewellery. In the West, to make his dream come true he will
have to legitimize the proceeds of crime, to turn it from “the black money” into “the white money”. Otherwise, there will be no
purchase. In order to prevent that, all the Western countries passed laws similar to our Law 115 and formed an international
organization – FATF, which should coordinate efforts and exchange information between the countries, fighting against the
money laundering. Seriously, if a drug kingpin can’t use his money to buy material benefits, why on Earth did he earn it?
Wouldn’t it be better to do some farming and switch over from cultivation of opium poppy to breeding calves?
Now let’s look at what is going on in Russia. Unlike the West, one may buy absolutely anything in Russia for “the black money”,
such as a house, a yacht, a car and jewellery. No one is actually surprised about it in our country. Consequently, in Russia
people, who earned money illegally, have no incentives to legitimize (or launder) money unlike in the West. No one wants to
launder money, i.e. to turn it from “the black (dirty) money” into “the white (clean) money” in Russia. Based on the viewpoint,
which is so much common in our country, that the fortunes earned on privatization were made illegally, we will additionally have
to say that one may buy even plants, newspapers, steam vessels and even entire sectors of the national economy for the
proceeds of crime.
— Letter of Aleksey Frenkel Article, Kommersant
47, Volgogradskiy pr., Moscow, 109316
Tel./fax: +7 (495) 723-01-19
e-mail: r-techno@it2b.ru, www.r-techno.com
private intelligence & risk management company
Specific Character of Russia and CIS countries
Thus, the AML system in Russia and CIS should include counteraction of the illegal conversion of
money into cash (“cash-out”).
AML-risks
One of the most serious bank risks related
to the lack of proper attention to
the anti-money laundering procedure is
Illegal conversion of money into cash also leads to
LICENSE
REVOCATION
47, Volgogradskiy pr., Moscow, 109316
Tel./fax: +7 (495) 723-01-19
e-mail: r-techno@it2b.ru, www.r-techno.com
private intelligence & risk management company
Know Your Customer
This is a general principle for all the banks that any efficient anti-money laundering is based on
the know your customer (KYC) concept.
AML outsourcing from R-Techno
General set of measures to study the customer:
•Check of the reliability of the information provided on the company;
•Confirmation of the company’s location;
•Check in the international and Russian ban-, stop lists and black lists;
•Check of the founders and executives for mass participation in other companies;
•Check for the implication of the company and top managers in financing of the terrorist organizations and
organized crime;
•Check for the implication of the company and top managers in laundering of the proceeds of crime and any
illegal activities;
•Check of the customer’s court history;
•Open-Source Intelligence (OSINT) – Internet, mass media, etc.
R-Techno performs checks across more than 27,000 documents of departmental structures both Russian
and international! This is a unique archive of R-Techno, which is expanded on a daily basis, ensuring the
customer gets the up-to-date information!
47, Volgogradskiy pr., Moscow, 109316
Tel./fax: +7 (495) 723-01-19
e-mail: r-techno@it2b.ru, www.r-techno.com
private intelligence & risk management company
47, Volgogradskiy pr., Moscow, 109316
Tel./fax: +7 (495) 723-01-19
e-mail: r-techno@it2b.ru, www.r-techno.com
Model report
private intelligence & risk management company
Counteragent AML-check costs
One-time check – 40 euros
Subscriber check (subscription – 1 000 euros per month) – 30 checks per month)
Subscriber check (subscription – as from 2 000 euros per month) – 65 checks per month)
47, Volgogradskiy pr., Moscow, 109316
Tel./fax: +7 (495) 723-01-19
e-mail: r-techno@it2b.ru, www.r-techno.com
private intelligence & risk management company
Contacts
Roman V. Romachev
www.r-techno.com
+7 495 723.01.19
47, Volgogradskiy pr., Moscow, 109316
Tel./fax: +7 (495) 723-01-19
e-mail: r-techno@it2b.ru, www.r-techno.com
Автор
Roman Romachev
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