Publicly, the FATF has said it views Russia’s aggression as unacceptable and as running counter to its “core principles”, but in practice, lowering Russia’s ranking requires consensus from its multilateral membership.

The intergovernmental body currently brings together around 40 countries, including China, India, Brazil, South Africa and Saudi Arabia, three times a year to evaluate which countries should be moved on or off gray and blacklists.

Ukraine first asked for Russia to be nominated among the high-risk jurisdictions in April 2022, according to the document, and has consistently — albeit unsuccessfully — submitted new evidence to get Moscow downgraded since then.

To succeed in the latest round of meetings, Ukraine will have to persuade an internal FATF body tasked with reviewing nominations and supporting evidence, and which meets on Oct. 22, to recommend the proposal for formal consideration.

If Ukraine’s latest pitch is successful, Russia will join Iran, North Korea, and Myanmar on FATF’s highest-risk list.

The dossier submitted to members for consideration highlights the close financial and military cooperation between Russia and high-risk countries such as North Korea and Iran. It also emphasizes Russia’s funding of private militia such as the Wagner Group and their associated illegal activities.

There are also references to the role that channels on the Telegram messaging app and cryptocurrencies play in Russian facilitation of terrorist financing and to the laundering of “money obtained from goods stolen during its invasion of Ukraine” — from grains to minerals.





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