After imposing 19 rounds of sanctions, the European Commission is preparing to include the Russian Federation in the list of countries with a high risk of money laundering and terrorist financing. This status will mean that all financial transactions related to Russia will be subject to enhanced monitoring procedures: banks will be required to verify beneficiaries, the origin of funds, and chains of intermediaries, and certain transactions may be subject to additional approval by the European Anti-Money Laundering Supervisory Authority. In fact, Russian capital in the EU automatically falls into the high-risk category, even if it is not on the sanctions list.
To ensure an effective financial monitoring mechanism in Europe, the EU Anti-Money Laundering Agency (AMLA) was established and began operating in Frankfurt on July 1, 2025. The AMLA was created as a specialized supervisory body with a mandate to coordinate national financial intelligence, directly supervise the largest high-risk institutions, and establish uniform standards for combating money laundering and terrorist financing throughout the Union. It is AMLA that will be involved in compiling the updated “blacklist” of countries outside the European Union from 2027.
To understand why the EU is moving toward a tougher regime on Russian funds, one must recall not only the war against Ukraine, but also the long-standing practice of Russian money laundering schemes in Europe.
One example is the story of a network of dozens of offshore companies linked to the investment bank Troika Dialog, which between 2006 and 2013 funneled more than $4.6 billion through Lithuania’s Ukio Bankas by entering into fictitious contracts. Among the beneficiaries mentioned were the Russian president’s business circle, including cellist Sergei Roldugin, who is described in EU documents and international investigations as “Putin’s wallet.” Roldugin’s offshore structures were used to purchase assets whose value clearly did not correspond to the musician’s official income, and some of the transactions were carried out through European banks, particularly in Switzerland and Luxembourg.
Another example is the so-called “Moldovan Laundromat” – a scheme whereby at least $20 billion was transferred from Russia to Europe between 2011 and 2014 through fictitious loans, shell companies, and court decisions in Moldova. In particular, Russian companies registered fake debts to offshore structures, which then “collected” them through Moldovan courts. The money was then transferred to accounts in Moldovan and Latvian banks, and then through correspondent accounts in large European banks to the UK and other jurisdictions. The OCCRP investigation showed that these flows were used both for the personal enrichment of Russian officials and businessmen and for the accumulation of shadow financial resources that the Kremlin operates abroad.
The financial flows coming to the West from Russia are not only corruption and tax evasion, they are also directly linked to the financing of terrorist and extremist structures that the Kremlin uses as a foreign policy tool.
A prime example of this is the Russian Imperial Movement (RIM), which the US State Department recognized as a terrorist organization in April 2020 and added RIM and its leaders to the list of Specially Designated Global Terrorists. The RIM is based in Russia, conducts paramilitary training, and provides training to foreign far-right and neo-Nazi groups, including those from Europe and North America. The RIM’s military wing, the Imperial Legion, is involved in combat operations in Ukraine.
Another example was the Kremlin’s financing of the Wagner Group, against which the EU, the US, and a number of other countries imposed sanctions for war crimes in Ukraine, Africa, and the Middle East. EU documents classify the Wagner Group as a terrorist organization that should be considered part of Russia’s military-political machine. Although Wagner was formally positioned as a “private military company,” it was financed through state contracts, agreements with Russian state corporations (particularly in the areas of resources and logistics), and informal channels linked to the military budget.
Funding for such structures does not always come from the official budget of the Russian Federation—often it is “donations” from “patriotic” businessmen, foundations, or anonymous transfers through fundraising platforms, which makes it difficult to identify the beneficiaries.
Russia has systematically used banks and semi-transparent financial channels to influence EU domestic politics. One of the most famous examples is the €9 million loan that the French far-right party National Front (now Marine Le Pen’s National Rally) received in 2014 from Russia’s First Czech Russian Bank. The bank later lost its license, and the right to claim the loan was transferred to another Russian company, which only reinforced suspicions about the political nature of this financial transaction.
In recent years, another channel has been added to the classic financing schemes involving banks and offshore companies: crypto assets. The newly created AMLA already considers the cryptocurrency sector to be one of the main risks in the fight against money laundering and terrorist financing, emphasizing its anonymity, speed, and cross-border nature.
Europe has grounds for adding Russia to the list of countries with a high risk of money laundering and terrorist financing. Brussels no longer considers it a “large but ordinary” economy with certain regulatory shortcomings; we are talking about a systemic threat, where the state, large state-owned companies, oligarchs, special services, and criminal networks work together. The EU must gradually consolidate Russia’s status as a state whose financial model is incompatible with the rules of open economies. This is a logical continuation of the sanctions policy, but with a different emphasis: not only to punish aggression, but also to make the Russian Federation’s long-term shadow financial operations so expensive and risky as to narrow the resource base for war, repression, and support for terrorist and extremist networks in Europe.
In this sense, the inclusion of Russia in the list of high-risk countries is only an intermediate stage. The next question will be how decisively the EU and its partners will be able to apply instruments of influence to the whole spectrum of Russian schemes – from classic “laundromats” and political loans to the financing of terrorist groups and extremist networks operating under the cover of “private” structures.