FATF Plenary: Germany’S Presidency Strategy and Global Network General Tasks
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FINANCIAL NO. 27 July 2020 SECURITY CONTENTS 5 Welcoming speech of Mr. Yury Chikhanchin, Director of Rosfinmonitoring Cover Story: COVID-19 and Measures to Combat Illicit Transactions 6 V. Putin: "I Know That the System Works" 11 COVID-19 Pandemic Related ML/TF Risks and Response Measures: Russian and International Experience 17 Risks Linked to the Embezzlement of Public Funds, Private and Corporate Property During the Coronavirus Pandemic Situation National AML/CFT System 26 Rosfinmonitoring Publishes Annual Report 2019 31 ITMCFM: 2019 Results 36 National Projects are the Main Strategic Areas of Monitoring and Control Over Budgetary Sphere International Block 39 32nd EAG Plenary Meeting - the First Meeting Held by the FATF Global Network as a Virtual Event 41 FATF Plenary: Germany’s Presidency Strategy and Global Network General Tasks 43 COVID-19 and Measures to Combat Illicit Financing 45 Participation of the Russian Federation in Moneyval Working Meetings 46 A Quarter of a Century in Pursuit of Dirty Money Compliance Council 50 Right to Refuse to Render Service to Customer as an Effective ML/TF Risk Mitigation Mechanism 53 AML/CFT Control Technologies, or What Enterpreneurs Should Be Ready for in 2020-2021 56 Mitigating the Risks of Using Enforced Debt Recovery Instruments in Money Laundering Schemes New Technologies 59 Digital Identity: the FATF View E-money 62 Measures to Mitigate ML/TF Risks in the Context of Cryptocurrency Transactions Provided by Legislative Acts of the European Union and Eu Member States AML/CFT Education and Science 71 International Summer Online School of Financial Intelligence took place 73 Innovative Approaches in the Educational Process and Improvement of the Personnel Training System in the AML/CFT Area 3 FINANCIAL SECURITY July 2020 NO. 27 EDITORIAL BOARD Chairman Deputy Chairman Editor of Editorial of Editorial in Chief Board Board Irina Ivanova Yury Chikhanchin Vladimir Ovchinnikov Members of Editorial Board Yury Korotkiy Galina Bobrysheva Vladimir Glotov Oleg Krylov Alexander Klimenchenok Evgeny Legostaev Sergey Teterukov Alexey Petrenko Evgeny Mozgov German Neglyad 4 FINANCIAL NO. 27 July 2020 SECURITY DEAR READERS, Greeting you from to everyday life: unfortunately, some of the pages of our our colleagues and loved ones have journal, I experience succumbed to the virus. mixed feelings. On We have decided to dedicate this issue the one hand, of "Financial Security" to the coronavirus amid the coronavirus problem, as viewed from the standpoint pandemic, the global of the AML/CFT/PF system's response AML/CFT framework to possible financial consequences faces completely new challenges and for the global economy and individual threats. On the other, our concerted countries. efforts have enabled us to quickly adapt to new circumstances and respond to In these challenging times, close emerging risks. cooperation with the private sector remains highly relevant. The search for new COVID-19 has made changes not modalities and approaches to supervision only to the international agenda (joint in the context of existing restrictive FATF/EAG Plenary meeting, scheduled measures is of particular importance. to be held in China, and CIS Council of Heads of FIUs meeting were both I wish you all good health and robust held via video conferencing), but also immune system! Yury Chikhanchin, Director of Rosfinmonitoring 5 FINANCIAL SECURITY July 2020 NO. 27 COVER STORY: COVID-19 AND MEASURES TO COMBAT ILLICIT TRANSACTIONS V. PUTIN: "I KNOW THAT THE SYSTEM WORKS" A meeting of the President of the Russian Federation Vladimir Putin with the Director of Rosfinmonitoring Yury Chikhanchin took place in the Kremlin on 18 June 2020 he focus of the meeting was on the public "We've developed a cooperation mechanism and funds monitoring results allocated for national put in place an oversight system, which includes projects. common approaches to risk assessment as well as T risk monitoring system and mitigation mechanisms, According to the Director of Rosfinmonitoring, the with all new proposals being forwarded to the supervision system has been put in place with the Russian Government." help of all stakeholders, with the Treasury of Russia, Federal Tax Service, General Prosecutor's Office Naturally, all these approaches proved to be useful and the Federal Security Service of Russia playing in overseeing the public funds expenditure allocated a major role. to fight the coronavirus. 6 FINANCIAL NO. 27 July 2020 SECURITY Rosfinmonitoring monitors about 7,000 COVID-19- situation, including compliance of the contractors related public contracts totalling RUR 11 billion involved in the COVID-19 response efforts. If you look awarded to 4500 different companies and individual at the graphs, you'll see declining trends across the entrepreneurs. To mitigate the risk of non-execution board, including suspicious transactions and the use of these contracts, Rosfinmonitoring has assessed all of shell companies...A similar situation exists in the contractors involved to identify those at higher risk, procurement of medical equipment and artificial lung passing on some of its findings to law enforcement. ventilation devices" explained Yury Chikhanchin. "To date, some of these contracts have been The pandemic has also threatened systemic terminated and criminal investigations have been enterprises, which also found themselves in need of launched. This has allowed us to improve the government support. Background Special conditions to apply for tax payment delay or to use instalment plans for tax payments Systemic enterprises are companies that, due due in 2020 – except for MET, excise taxes and to their status as some of the largest employers petroleum profits tax – for companies whose and taxpayers in their respective industries, play revenues have declined by 10 percent or more. a major role in the country's economy. Systemic enterprises facing higher risks may also The Russian government has launched a apply for subsidies to cover the cost of manufacturing, number of initiatives in support of systemic execution of works and provision of services, as well enterprises: as state guarantees needed to restructure existing debt and secure new loans, including bond loans. Subsidized loans to replenish working capital and maintain employment. The number of eligible enterprises currently stands at 1335. A 6-month bankruptcy moratorium. Agencies involved in public procurement oversight Law enforcement Supervisors FSB Ministry of Internal Rosfinmonitoring FTS Affairs Investigative General FAS Federal Treasury Committee Prosecutor's Office 7 FINANCIAL SECURITY July 2020 NO. 27 According to the Director of Rosfinmonitoring, V. Putin: "Although they may not necessarily be among them there are companies previously shell companies, they weren't set up for legitimate identified by Rosfinmonitoring to be in «risk zone» business either." for the falsification of financial statements and transfer of funds to entities registered abroad, Yu. Chikhanchin: That's right. Despite their recent including jurisdictions with preferential tax regimes. incorporation, they're already targeting contracts In addition, some of them are believed to have worth billions. And we, in collaboration with other participated in transferring money to shadow agencies, are monitoring their activities...If we look turnover zone using «technical» companies, at the districts where national projects are being placement of funds in deposit accounts and implemented, the Southern Federal District and appointment of foreign nationals to management the Far Eastern Federal District are of the biggest positions in the company. All generated intelligence concern. We're working closely with the offices of has been passed on to the Russian government for plenipotentiary representatives in these districts to elaboration of new approaches. keep them updated in advance on the risks we see and developing ways to mitigate them. As for the While reporting to the President of the Russian constituent entities, some of them do face risks, i.e. Federation on the overall situation with national the Stavropol Territory, the Penza Region and the projects, Chikhanchin pointed out that about one- Khabarovsk Territory." third of contractors are currently believed to be at risk, with some, according to intelligence provided In addition, the Director of Rosfinmonitoring reported by financial institutions, being linked to a significant to the President of the Russian Federation on the number of suspicious transactions or displaying agency's cooperation with governors, particularly signs of fictitiousness. in implementing pilot projects in the Novgorod and Awarded contracts in the framework of countering COVID-19 pandemic 8 FINANCIAL NO. 27 July 2020 SECURITY Tula Regions. Rosfinmonitoring engages closely Yu. Chikhanchin: "We'll do our best." with the governments of these regions to take preventive actions against the identified risks. The Director of Rosfinmonitoring proposed the To this end, the competent authorities, working following approaches to improving public procurement in collaboration with the contracting authorities, oversight: used Rosfinmonitoring's intelligence to monitor the execution of public contracts awarded to certain to develop a mechanism for colour-coding contractors and to assess the level of risk each public funds to enable their traceability all of them face. Following a review of the outcomes the way from contract authorities to individual of this engagement, the Russian government