ICT Views

Russia - a new frontier for us and for AML

by: (Director ICT Academic Faculty) on

I have just returned from my second trip to Moscow to deliver the ICA Diploma in AML in house to a large Russian Bank.

Having dodged the notorious Moscow traffic by taking the Aero Express train I arrive at my hotel. It is just down from Red Square and right across from the Bolshoi Ballet, right at the heart of icons of history. It’s cold though around -8 c but still great to be here (although I manage to fall over on the ice several times. Note to self: bring more practical shoes next time).

red squareWe have agreed an in-house delivery of the ICA Diploma in Anti Money Laundering with a large Russian bank. We are holding 4 workshops with their AML and Compliance people to help deepen their knowledge and share emerging best practice on CDD, KYC, AML and Sanctions. This is the first time we have delivered AML training in the Russian Federation (although compliance courses have run for several years through our training partner in the region ICS) and I am interested to see the delegates' reactions.

The first few workshops are translated into Russian through headsets which makes engaging with the delegates a lot harder (particularly if a joke gets translated followed by silence!) But the translators are fantastic and it soon warms up. The delegates are very friendly and I am impressed by the level of AML knowledge displayed. It quickly becomes apparent that the bank has all the CDD and AML procedures and policies that I would come across in a UK or US bank and the delegates talk with expertise about enhanced CDD, PEP onboarding and the screening against sanction lists. The delegates are interested in how to apply the risk based approach and the latest views from international regulators and other firms on using adverse media, getting information on source of wealth and dealing with PEPs.

Knowing that the Russian Federation has recently updated its AML laws and that FATF has acknowledged the improvements, the fact that there are clearly robust AML frameworks in the bank was heartening. However it's clear that there are still issues. Some of the ownership structures of Russian firms are deliberately opaque and it’s still unclear what the level of meaningful regulatory enforcement is on the ground.

The delegates also raise many of the challenges that are faced by AML practitioners worldwide -  pushback from the business when trying to obtain CDD and general pressures of workload etc. That’s a common theme I see everywhere I go. Local laws and regulation differ but the same challenges exist: how do you educate and engage your firm to grow, but in the right way and by taking on the right sort of business?

cafe pushkinBack to the hotel and I try some great Russian food. On my last day before flying out I sample some Borsch for lunch (beetroot and beef soup with sour cream) and on my second visit Kate and the lovely ladies from ICS  take me to breakfast at Pushkin’s Café (an atmospheric period restaurant.) I sample a few Russian delicacies of baked curd and fruit, sweet pancakes - fantastic! One of the best things about this job is trying the local food.

I have always been fascinated with Russian history and literature (I even finally read War and Peace last year!) so next on the list for my return in May is a tour of the Kremlin. I do get the chance to see Red Square and Lenin’s tomb on this trip though. As you walk downstairs and see him lying in state, it's very oppressive with black and red marble but an interesting experience.

Lenins tomb

I have to say everyone I meet is very friendly but Russian officials are not particularly keen on smiling or indeed facial expressions! Some rather gruff police point me on my way when I take a wrong turn. Interesting to see all of the busts of ex-soviet leaders that dot the walls of the Kremlin behind Lenin’s tomb. The only one covered with flowers is that of Stalin. Still a complicated figure in Russia today.

Back to the hotel to pack and catch up on emails – it’s not getting any warmer but it's not windy either – think I am acclimatising! I get taken to have a look the Moscow Metro station which is very impressive and I particularly like the chandeliers!


Sochi is gearing up for the Winter Olympics as I fly out and it’s good to see Russian firms opening up and looking to international organisations like ICT and ICA to benchmark and share the latest good practice. I am hopeful we will be back for many more sessions with Russian firms in the months and years to come.

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