Date: 2026-01-09Category: Not ApplicableState: Union GovernmentCountry: Europe
Commission Delegated Regulation (EU) 2026/46 of 3 December 2025 amending Delegated Regulation (EU) 2016/1675 to add Russia to the list of high-risk third countries with strategic deficiencies
**Executive Summary**
Commission Delegated Regulation (EU) 2026/46, dated 3 December 2025, amends Delegated Regulation (EU) 2016/1675 to include Russia in the list of high-risk third countries due to strategic deficiencies in its anti-money laundering and counter-terrorism financing (AML/CFT) regime. The regulation enters into force on the twentieth day following its publication in the Official Journal of the European Union. The Commission concluded its review of third countries by 31 December 2025.
**Key Points / Main Content**
* **Amendment:**
* Delegated Regulation (EU) 2016/1675 is amended to include Russia in the list of high-risk third countries.
* **Reasoning:**
* Russia's membership in the Financial Action Task Force (FATF) has been suspended due to gross violations of FATF's core principles.
* Strategic deficiencies have been identified in Russia's AML/CFT regime, specifically:
* Independence and international cooperation of the Financial Intelligence Unit.
* Beneficial ownership transparency and information availability/accuracy.
* Application of AML/CFT regulations to crypto-assets.
* These deficiencies pose a threat to the Union's financial system.
* **New Category:**
* A new category is added to the Annex of Delegated Regulation (EU) 2016/1675 for high-risk third countries not subject to FATF calls for action or increased monitoring but whose FATF membership is suspended.
* **Entry into Force:**
* The Regulation enters into force on the twentieth day following its publication in the Official Journal of the European Union.
**Impact Analysis**
**Member States**
*Impact:*
* The regulation is binding in its entirety and directly applicable in the Member States.
*Action Required:*
* Member States must implement the necessary measures to mitigate the risks associated with financial flows to and from Russia.
**EU Financial Institutions**
*Impact:*
* Subject to increased due diligence requirements when dealing with Russian entities or transactions involving Russia.
*Action Required:*
* Update their AML/CFT procedures and systems to reflect Russia's designation as a high-risk third country.
**European Commission, European External Action Service, and Member States' authorities**
*Impact:*
* Have jointly completed a prima facie assessment of Russia's AML/CFT regime.
*Action Required:*
* Cooperate in the monitoring and enforcement of the regulations.
**FATF (Financial Action Task Force)**
*Impact:*
* The FATF membership of the Russian Federation ('Russia') was suspended on account of its gross violation of the FATF's core principles.
*Action Required:*
* Continue monitoring and assessing Russia's progress in addressing the identified deficiencies.
Key Entities Referenced
Delegated Regulation (EU) 2016/1675: The regulation that identifies high-risk third countries with strategic deficiencies in their AML/CFT regimes.
Russia: Designated as a high-risk third country due to strategic deficiencies in its AML/CFT regime after FATF membership suspension.
Financial Action Task Force (FATF): An international standard-setter on AML/CFT whose principles were violated by Russia, leading to suspension and subsequent review.
Directive (EU) 2015/849: The directive providing the framework for the EU to identify third countries with strategic deficiencies in their AML/CFT regimes.
European Union: The union threatened by deficiencies in Russia's AML/CFT regime.
Official Journal EN
of the European Union L series
2026/46 9.1.2026
COMMISSION DELEGATED REGULATION(EU) 2026/46
of 3 December 2025
amending Delegated Regulation (EU) 2016/1675 to add Russia to the list of high-risk third countries
with strategic deficiencies
(Text with EEA relevance)
THE EUROPEAN COMMISSION,
Having regard to the Treaty on the Functioning of the European Union,
Having regard to Directive (EU) 2015/849 of the European Parliament and of the Council of 20 May 2015 on the
prevention of the use of the financial system for the purposes of money laundering or terrorist financing, amending
Regulation (EU) No 648/2012 of the European Parliament and of the Council, and repealing Directive 2005/60/EC of the
European Parliament and of the Council and Commission Directive 2006/70/EC(1), and in particular Article 9(2) thereof,
Whereas:
(1) The Union must effectively protect the integrity and proper functioning of its financial system and the internal
market against money laundering and terrorist financing. Directive (EU) 2015/849 therefore provides that the
Commission is to identify third country jurisdictions that have strategic deficiencies in their anti-money laundering
and countering the financing of terrorism (AML/CFT) regimes that pose significant threats to the Union’s financial
system (‘high-risk third countries’).
(2) Commission Delegated Regulation (EU) 2016/1675(2)identifies such high-risk third countries.
(3) Considering the high level of integration of the international financial system, the close connection of market
operators, the high volume of cross-border transactions to and from the Union, and the degree of market openness,
any AML/CFT threat posed to the international financial system is also a threat to the Union’s financial system.
(4) Commission Delegated Regulation (EU) 2025/1393(3) recognises that third countries which are not publicly
identified as subject to calls for action or increased monitoring by the Financial Action Task Force (FATF) might still
pose a threat to the integrity of the Union’s financial system, especially where membership of such countries in FATF
is suspended because of gross violations of the core principles upon which FATF is built. Pursuant to Article 1a of
Commission Delegated Regulation (EU) 2025/1184(4), the Commission is to conclude the review of such third
countries by 31 December 2025, to assess whether to amend the Annex to Delegated Regulation (EU) 2016/1675
accordingly.
(5) The FATF membership of the Russian Federation (‘Russia’) was suspended on account of its gross violation of the
FATF’s core principles. Thus, Russia falls within the criteria of the assessment pursuant to Article 1a of Delegated
Regulation (EU) 2025/1184. Considering that the weaknesses in the Russian AML/CFT regime might pose a serious
threat to the Union’s financial system, the Commission, in cooperation with the European External Action Service,
and Member States’ authorities, has completed a prima facie assessment of the country’s AML/CFT regime.
(1) OJ L 141, 5.6.2015, p. 73, ELI: http://data.europa.eu/eli/dir/2015/849/oj.
(2) Commission Delegated Regulation (EU) 2016/1675 of 14 July 2016 supplementing Directive (EU) 2015/849 of the European
Parliament and of the Council by identifying high-risk third countries with strategic deficiencies (OJ L 254, 20.9.2016, p. 1, ELI:
http://data.europa.eu/eli/reg_del/2016/1675/oj).
(3) Commission Delegated Regulation (EU) 2025/1393 of 8 July 2025 amending Delegated Regulation (EU) 2025/1184 to introduce a
review clause (OJ L, 2025/1393, 21.8.2025, ELI: http://data.europa.eu/eli/reg_del/2025/1393/oj).
(4) Commission Delegated Regulation (EU) 2025/1184 of 10 June 2025 amending Delegated Regulation (EU) 2016/1675 to add Algeria,
Angola, Côte d’Ivoire, Kenya, Laos, Lebanon, Monaco, Namibia, Nepal and Venezuela to the list of high-risk third countries which have
provided a written high-level political commitment to address the identified deficiencies and have developed an action plan with the
FATF, and to remove Barbados, Gibraltar, Jamaica, Panama, the Philippines, Senegal, Uganda and the United Arab Emirates from that
list (OJ L, 2025/1184, 16.7.2025, ELI: http://data.europa.eu/eli/reg_del/2025/1184/oj).
ELI: http://data.europa.eu/eli/reg_del/2026/46/oj 1/3EN
OJ L, 9.1.2026
(6) The assessment has identified a number of strategic deficiencies, notably relating to Russia’s laws and policies in the
area of the independence of the Financial Intelligence Unit and its ability to cooperate with counterparts in other
countries, Russia’s laws and policies in the area of beneficial ownership transparency and information availability
and accuracy, and Russia’s laws and policies in the area of applying AML/CFT regulation to crypto-assets. Such
deficiencies expose the Single Market to ML/TF risks which should be mitigated.
(7) The Commission therefore concludes that Russia is to be identified as a high-risk third country and should be added
to the Annex to Delegated Regulation (EU) 2016/1675. As Russia does not fit into any of the categories of high-risk
third countries set out in the Annex to Delegated Regulation (EU) 2016/1675, a new category should be added to that
Annex for high-risk third countries which are not identified as being subject to calls for action or increased
monitoring by the FATF, but whose membership in that international standard-setter is suspended.
(8) Delegated Regulation (EU) 2016/1675 should therefore be amended accordingly,
HAS ADOPTED THIS REGULATION:
Article 1
The Annex to Delegated Regulation (EU) 2016/1675 shall be amended in accordance with the Annex to this Regulation.
Article 2
This Regulation shall enter into force on the twentieth day following that of its publication in the Official Journal of the
European Union.
This Regulation shall be binding in its entirety and directly applicable in the Member States in
accordance with the Treaties.
Done at Brussels, 3 December 2025.
For the Commission
The President
Ursula VON DER LEYEN
2/3 ELI: http://data.europa.eu/eli/reg_del/2026/46/ojEN
OJ L, 9.1.2026
ANNEX
The following point IV is added to the Annex to Delegated Regulation (EU) 2016/1675:
‘IV. High-risk third countries which are not identified as being subject to calls for action or increased monitoring by the
FATF, but whose membership in that international standard-setter is suspended
No High-risk third country
1 Russian Federation’
ELI: http://data.europa.eu/eli/reg_del/2026/46/oj 3/3