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"BLACK OUT" for citizens of the Russian Federation in the field of financial monitoring

21 December, 2022

Work in the field of financial monitoring is becoming inaccessible to citizens of the Russian Federation.

Starting from November 19, 2022, employees of the subject of primary financial monitoring who are involved in conducting primary financial monitoring should no longer have citizenship (nationality) of the state carrying out armed aggression against Ukraine. Such requirements, first of all, are imposed on the head, deputy head, chairman and members of the supervisory board, the responsible officer and the person temporarily acting as the responsible officer. The list of persons involved in primary financial monitoring may include managers, lawyers, accountants, etc. of various levels. In this case, attention should be paid to the organization of the financial monitoring structure of the institution. 
 
These changes are regulated in the Law of Ukraine "On Amendments to Certain Laws of Ukraine on the Protection of the Financial System from the Actions of a State Carrying out Armed Aggression against Ukraine, and the Adaptation of Ukrainian Legislation to Certain Standards of the Financial Action Task Force on Money Laundering (FATF) and Requirements EU Directive 2018/843" dated 04.11.2022 No. 2736-IX.