EU Officials Describe Possible Russian AML Blacklisting as Largely Symbolic

Top financial officials within the European Union have downplayed the potential consequences of placing Russia on the EU’s anti-money laundering (AML) blacklist, describing the step as largely symbolic rather than transformative for financial oversight. The development comes as debates continue over how the bloc might intensify financial pressure on Russia amid its actions in Ukraine and the resulting security concerns.

John Berrigan, Director General for Financial Stability at the European Commission, addressed lawmakers in the European Parliament on the matter, emphasizing that existing sanctions already place substantial constraints on Russian entities. He noted that the EU has already imposed strict transaction bans on numerous high-profile Russian institutions and that this framework has effectively curtailed Russian access to European banking. “The listing of Russia on the AML list would be a symbolic gesture on our side because European banks are already subject to a transaction ban on a lot of the entities that we’re talking about,” Berrigan told members of parliament, suggesting that a blacklist move would not materially alter compliance practices.

The EU’s AML blacklist—often referred to as the “grey list”—is designed to identify countries deemed to have strategic deficiencies in their anti-money laundering and counter-terrorism financing frameworks. Once a jurisdiction is placed on the list, European financial institutions are required to apply enhanced scrutiny and due diligence on transactions connected to it. Such listings can damage a country’s reputation and further restrict access to international markets, even without additional sanctions.

Russia’s potential addition to the list has been under consideration for some time. The European Commission uses a methodology rooted in international standards set by the Financial Action Task Force (FATF), the global watchdog for anti-money laundering practices. Russia had once been blacklisted by FATF in 2000 but was removed in 2002 following improvements that led to its full membership in 2003. However, after its invasion of Ukraine, FATF took the rare step in 2023 of suspending Russia’s membership entirely—a punitive action that isolated Moscow from FATF’s policy-making and technical discussions but did not equate to the formal deficiencies associated with a grey or blacklist designation. FATF President Elisa de Anda explained that suspension cut Russia out of participation in global AML efforts but did not formally declare the country noncompliant with technical standards, leaving some ambiguity in how international institutions should frame the risks posed by Russia.

Within the EU, momentum has built among many lawmakers to push for Russia’s inclusion on the AML list as a way of signaling intensified scrutiny. Nonetheless, administrative hurdles and procedural requirements have delayed a final decision. As of mid-2025, Brussels had not taken the formal step, with officials pointing to the need for more robust evidence and further analysis of how effective such a measure might actually be. If enacted, the designation would require European banks to apply heightened due diligence to Russian-linked financial activity, adding compliance burdens but also potentially deepening Moscow’s financial isolation.

For now, EU officials suggest the main impact would be symbolic, reinforcing political resolve more than altering the practicalities of financial oversight. Berrigan’s remarks reflect a wider recognition that banks and financial institutions across Europe have already incorporated Russia-related restrictions into their compliance regimes since the earliest waves of sanctions, leaving little room for substantive tightening through an AML listing alone.

This nuanced stance underscores the challenge of balancing symbolic political gestures with effective regulatory tools. While some see value in formally blacklisting Russia to reinforce the EU’s posture, others argue the focus should remain on rigorously enforcing existing sanctions and strengthening broader AML frameworks.

At the same time, the European Commission has been pursuing its own enforcement agenda within the bloc, launching infringement proceedings against 11 member states, including Belgium, Denmark, and Germany, for failing to guarantee comprehensive access to beneficial ownership registers. These registers are a cornerstone of the EU’s anti-money laundering policy, providing transparency about the individuals who ultimately own and control companies. By improving oversight in this area, the Commission hopes to strengthen defenses against illicit financial flows that could be linked to high-risk jurisdictions such as Russia.

By fLEXI tEAM