According to Russia itself (NRA 2018) the main financial crime threats it faces are from embezzlement, corruption, abuse of power, financial fraud & drug trafficking, but third parties also highlight serious threats related to terrorism, WMD proliferation, financial crimes, tax offences, illegal wildlife (in particular logging and fishing), human trafficking, state enabled organised crime, tax offences & cybercrime. Other notable threats not rated though as high include overall organised crime, people smuggling and arms trafficking. With corruption endemic and state enabled organised crime at such high levels the 2019 FATF report that scored Russia as highly effective for its ability to carry out financial intelligence and terrorism investigations are not necessarily inconsistent. What is needed is a broader perspective and not just country and FATF information to inform assessors and to flow through to any overall assessment. In this Russian Country Financial Crime Dashboard a broader set of indicators suggest Russia is what most independent experts know – it’s a high threat and a low response country and not a medium threat and high response country – based on the best available criteria – and possibly presents the highest net financial crime related risks overall of all FATF member countries. 

As FATF member countries represent most of all the proceeds and flows of financial crime it could be argued that Russia is the country that most deserves to be blacklisted or at least greylisted – but this would need a new FATF full evaluation and that’s unlikely to be sanctioned or agreed to by Russia anytime soon. I can’t imagine any regulated for AML/CTF institution anyway doesn’t have Russia as anything another than its highest financial crime risk at present based on objective available criteria, and if it doesn’t it should reflect on this based on objective independently available information. This Dashboard may help.