Russia proposes new asset freeze reporting and suspension duties

17 September 2026

A draft federal law amending Russia's anti-money laundering law has been published for public consultation. The Bill would add new duties for entities that freeze assets pursuant to UN sanctions on the financing of weapons of mass destruction, & Russia's terrorism and extremism sanctions list.

Rosfinmonitoring, Russia's Federal Financial Monitoring Service, is the agency responsible for supervising and enforcing these obligations. Federal Law No. 115-FZ of 2001 governs anti-money laundering and counter-terrorist financing in Russia. It requires banks, insurers, securities firms and other entities to freeze the assets of people and entities on 2 lists. The first covers those linked to extremism or terrorism. The second, under Article 7.5, covers those subject to measures against the financing of weapons of mass destruction. Entities must tell Rosfinmonitoring when they freeze assets. They do not have to report later attempts to use frozen assets. See our Russia pages for information about these regimes & reporting duties.

The draft amends Articles 7, 7.1, 7.5, 7.10, 8 and 10.2 of Law No. 115-FZ. It would:

• require entities to record and report any instruction from a client whose assets are frozen, within 3 working days (new Article 7(1)(8) and Article 7.5(4.1))

• require entities to suspend a client's transactions immediately for 5 working days where the client's details partially match those of a listed person (new Article 7(10.3) and Article 7.5(5.1))

• require entities to tell Rosfinmonitoring of a suspension within 1 working day

• allow Rosfinmonitoring to set the criteria for a partial match and extend a suspension under Article 8, with transactions going ahead if it does not

• extend the suspension duty to the digital rouble platform (new Article 7.10(1)(5))

• add corrections to list entries to the information Rosfinmonitoring communicates (amended Article 10.2)

The law would enter into force 270 days after official publication. Public consultation closes on 24 September 2026.