International Narcotics Control Strategy Report - 2003
Released by the Bureau for International Narcotics and Law Enforcement Affairs, March 2004
Part I: Drug and Chemical Control
I. Summary
In 2003, the Government of Russia (GOR) placed renewed emphasis on combating its drug trafficking problems by creating a new counternarcotics agency aimed at coordinating all drug investigations within the country. Heroin trafficking and abuse continues to be a major problem facing Russian law enforcement agencies and public health agencies. Since the events in Afghanistan in 2001, opium cultivation and heroin production in Afghanistan has risen dramatically. Given Russia's large and porous borders with Central Asia, Afghan opium/heroin transiting Russia to Europe has become a major problem for the GOR. This rise in heroin trafficking is reflected in the increase of drug related crimes and the number of HIV/AIDS cases. Illegal diversion of legally manufactured drugs into the Russian underground market and the trafficking of precursor chemicals are also widespread in Russia. Acetic anhydride, a precursor chemical used in the production of heroin, both transits Russia from Ukraine and originates in Russia and is subsequently transported to Turkey. The GOR has recognized the extent of the drug trafficking and health problems within the country and is taking steps to address both the law enforcement and public health issues. Russia is party to the 1988 UN Drug Convention, the 1961 Single Convention of Psychotropic Substances and its 1972 Protocol, and the 1971 UN Convention on Psychotropic Substances.
II. Status of Country
Russia is a transit country for heroin and opium, most of which comes from Afghanistan, and the majority of which is destined for Europe. Given the porous nature of the Russian border with Central Asia and the limited technical and financial support for law enforcement, it is clear that Russia is ill-equipped to handle the inundation of Afghan heroin into the country. Russia is also a consumer of heroin due to the high availability and low prices. The average price of a gram of heroin in Russia is between $30.00 and $36.00, down from a reported average of $39.00 in 2002. Despite the low cost of heroin, addicts still resort to criminal activity to support their addiction. Production of amphetamines and synthetics for domestic consumption is minor but on the rise. Designer �club� drugs are increasing in popularity with Russia's youth. Typically, MDMA Ecstasy is produced in the Netherlands and Poland. However, in 2003, there were several reports by both the Russian Ministry of Internal Affairs (MVD) and Federal Security Service (FSB) that MDMA labs now exist in Russia. Although the MDMA tablets produced in Russia are of low quality, the low prices (sometimes as low as $5.00 U.S.) are attractive to Russian youth in comparison to the $20.00 U.S. typically charged for MDMA tablets from the Netherlands.
Russia remains a significant producer/diverter of precursor chemicals for export for the production of Afghan and Turkish heroin. Acetic Anhydride (AA) is transshipped from Ukraine through Russia to Turkey or shipped directly from Russia to Turkey. In April 2003, approximately 3 tons of AA was seized by Russian law enforcement agencies. This seizure was a result of increased cooperation between Russian and Turkish law enforcement agencies. Cocaine trafficking is not widespread in Russia, as the prices remain very high. Although there have been numerous reports of cocaine being transported to the Russian port of St. Petersburg, no significant seizures of cocaine occurred in Russia in 2003.
Drug abuse within Russia is a matter of concern for national health officials. In the beginning of 2003, there were 340,000 registered drug addicts in Russia. This figure only reflects those addicts who are known to health officials. The number of drug users in Russia is estimated to be between 3 and 4 million people. The majority of drug users are under 30 and approximately 30 percent are heroin addicts. According to the Ministry of Health, as of October 2003, there were 251,000 officially registered HIV/AIDS cases in Russia, but the actual number is estimated to be between 700,000 and 1.5 million. Currently 70-80 percent of all transmissions are through intravenous drug use.
Domestic distribution of drugs is handled by traditional Russian criminal organizations that have long conducted other criminal operations in various regions of Russia. Trafficking into the country is often handled by members of various ethnic groups who tend to specialize in certain categories of drugs in specific areas. Afghans, Tajiks and other Central Asians mainly import heroin across the southern border with Kazakhstan into European Russia and western Siberia.
III. Country Actions Against Drugs in 2003
Policy Initiatives. In July 2003, Russian President Vladimir Putin created a new drug agency called the Russian State Committee for the Control of Narcotic and Psychotropic Substances (GKPN). This 40,000 member agency is tasked with coordinating all drug investigations and enforcing narcotics laws within Russia. The head of the GKPN, Viktor Cherkesov, reports directly to President Putin, reflecting the importance of the new agency.
Russia has an enormous chemical production industry. Unfortunately this industry is almost completely devoid of effective management and regulation by either regulatory or law enforcement bodies. This lack of control results in huge illegal shipments of the precursor chemicals needed in the manufacturing of heroin. The new Russian State Narcotics Control Committee has devoted a significant portion of its resources to the control of the Russian precursor chemical industry and the diversion of legally manufactured pharmaceuticals to the illicit market. Among the chemicals used in the production of heroin hydrochloride, acetic anhydride (AA) and the solvents acetone, ethyl ether, methyl ethyl ketone, and hydrochloric acid are considered the most critical. Each has widespread legitimate commercial and industrial use, and each is regulated by the United Nations International Narcotics Control Board (INCB), as well as the Organization of American States, and the U.S. Drug Enforcement Agency (DEA) DEA will work closely with the U.S. State Department, and the new Russian State Narcotics Control Committee to develop the GKPN's ability to regulate and control the chemical industry.
Accomplishments. Russia now has a legislative and financial monitoring scheme that facilitates the tracking and seizure of all criminal proceeds. Since 1997, Russia has passed a number of laws criminalizing money laundering and terrorist financing, which also provide for the forfeiture of criminal proceeds. Russian legislation provides for techniques such as search, seizure and compelling the production of documents, as well as the identification, freezing, seizing and confiscation of funds/assets. Where sufficient evidence indicates that property was obtained as the result of a crime, investigators and prosecutors can apply to the court to have the property seized or frozen. Law enforcement agencies have the power to identify and trace property that is, or may become, subject to confiscation or is suspected of being the proceeds of crime or terrorist financing.
Law Enforcement Efforts. In November 2003, the GOR passed legislation reducing the sentence for possession of drugs for personal use from a maximum of 3 years in jail to a fine. Additionally, the GOR passed legislation increasing the maximum jail terms for drug dealers from 15 to 20 years.
Corruption. President Putin has stated that controlling corruption is a priority for his administration. However implementing this policy presents a constant challenge. Inadequate budgets, low salaries and lack of technical resources and support for law enforcement hamper performance, sap morale and encourage corruption. In 2003, there were several reports of corruption among low to mid level law enforcement officers. In October 2003, five GKPN agents were arrested on charges of extortion. The agents allegedly were taking bribes to not launch a criminal case against a drug trafficker. The agents were former Ministry of Internal Affairs (MVD) officers.
In October 2003, reports of corruption among newly assigned GKPN officers in Russia's Far East indicated that corrupt officers could earn up to 7,000 rubles ($230.00) a month for protecting one drug sales point. On October 28, 2003, a former policeman of the Krasnoyarsk Oktyabraskiy district was sentenced to seven and a half years in prison for drug trafficking. There were no reported cases of high level narcotics related corruption.
Agreements and Treaties. Russia is party to the 1988 UN Drug Convention, the 1961 Single Convention on Psychotropic Substances and its 1972 Protocol, and the 1971 UN Convention on Psychotropic Substances. Under the U.S./Russia Mutual Legal Assistance Treaty (MLAT), the requested country is obligated to provide assistance if there is dual criminality and the other pertinent requirements of the treaty are met. If there is no dual criminality, assistance is discretionary. At present, no extradition treaty exists between the U.S. and Russia. Russia, which does not extradite its own nationals, has said that it will extradite citizens of other countries with which it has concluded extradition treaties. To date, Russia has provided MLAT assistance in two narcotics related cases.
Cultivation/Production. There are no official statistics on the extent of opium cultivation in Russia, and the USG has no evidence to suggest that more than 1,000 hectares of opium�the threshold which would make Russia a Major Cultivator of Opium�are cultivated. In Russia, there are small, illicit opium poppy fields ranging in size from one to two hectares. This year, more poppies were discovered than in previous years. Typically the opium fields are small backyard plots or are located in the countryside concealed by other crops. In Siberia, in the Central Asian border region, and in the Omsk/Novosibirsk/Tomsk region along the border with Kazakhstan, opium poppies are widely cultivated. According to Russian authorities, in 2003 more cannabis and poppy plants were cultivated on larger plots of land, and wild harvests of these plants expanded throughout Russia. Wild cannabis is estimated to cover some 1.5 million hectares in the eastern part of the country. The MVD reported that throughout 2003, new zones for storing raw poppy and cannabis for drug production continued to be identified.
Drug Flow/Transit. Heroin from Southwest Asia flows through Central Asia, particularly Tajikistan and Kazakhstan, over the southern border into Russia, for domestic distribution and consumption and for transshipment to Europe and, to a much lesser extent, the United States. The Caspian Sea port city of Astrakhan and the Black Sea port of Novorossiysk are major transit points for Turkish and Afghan heroin into Russia. Vast amounts of daily sea traffic, consisting of passengers, autos on ferries and bulk goods in trucks are used to conceal heroin moving into Russia. Both routes mentioned above are also used in reverse to smuggle multi-ton quantities of the precursor chemical acetic anhydride to the clandestine laboratories that produce Afghan and Turkish refined heroin. The lack of border controls with China and Mongolia facilitates smuggling, including drug trafficking, through that region.
In the east, the Russians continue to import the precursor ephedrine from China for Russian domestic production of methamphetamine in kitchen labs in quantities for personal use. Cocaine traffickers also route Colombian cocaine for transshipment to Europe and elsewhere through Russian seaports and airports.
Demand Reduction. Russian authorities are attempting to implement a comprehensive counternarcotics strategy that would combine education, health and law enforcement. Russian law enforcement authorities also have come to support the idea that demand reduction should complement law enforcement efforts to reduce supply.
IV. U.S. Policy Initiatives and Programs
Policy Objectives. The principal U.S. goal in Russia is to help strengthen Russia's counter narcotics law enforcement capacity to meet the challenges of international drug trafficking into and across Russia. The U.S. also tries to increase the knowledge, and improve the techniques of Russian law enforcement personnel with the goal of developing reliable Russian law enforcement partners for U.S. law enforcement.
Bilateral Accomplishments. In 2002, the U.S. Department of State, Bureau of International Narcotics and Law Enforcement Affairs (INL) negotiated a Letter of Agreement (LOA) with the GOR allowing direct assistance to the GOR in the area of counternarcotics and law enforcement assistance. The U.S. also provided technical assistance in support of institutional change in the areas of criminal justice reform, mutual legal assistance, anti corruption and money laundering.
The Road Ahead. The GOR places high priority on counter narcotics efforts and has indicated a desire to deepen and strengthen its cooperation with the United States and other countries. The USG will continue to encourage and assist Russia to implement its comprehensive, long term national strategy against drugs with multidisciplinary sustainable law enforcement assistance projects that combine equipment, technical assistance and expert advisors. DEA is scheduled to provide State Department-funded counter narcotics training to over 200 trainees in 2004, primarily enforcement personnel in the newly created State Narcotics Control agency as well as Russian Customs.
Part II: Money Laundering and Financial Crimes
Russia�s ability to combat the laundering of criminal financial proceeds domestically and internationally has been considerably strengthened over the past two years by aggressive enactment and implementation of comprehensive money laundering and counterterrorism financing legislation. Despite notable progress and demonstrated political will to aggressively combat these phenomena, the magnitude of money laundering remains large, because of the number and scale of contributing factors. Russia�s abundance of natural resources, infiltration of society by organized crime, high level of corruption (Transparency International Corruption Perceptions Index 2003 assigns Russia a score of 2.7 out of 10. �Highly clean� rates a �10� and the 2.7 score�unchanged from 2002�puts Russia in 86th place out of 133 countries), porous borders, role as a geographic gateway to Europe and Asia, weak banking system, and under-funding of regulatory and law enforcement agencies continue to leave it vulnerable to money laundering. Russia is still used for money laundering by Russian criminals moving funds out of Russia and by criminals from neighboring countries because of familiarity with the language, culture and economic system. The majority of these funds do not appear to be from activities related to narcotics production or trafficking, although these activities are believed to occur. Most of the proceeds of criminal or quasi-criminal activity are believed to derive primarily from domestic sources, including evasion of customs duties and smuggling operations. Such activities, however, are not believed to be connected to narcotics trafficking.
Net flows of money out of the country, primarily attributed to unrepatriated export earnings, tax evasion, and a weak banking system, have slowed noticeably in recent years, due in part to the 1998 ruble devaluation and higher oil prices, which together have led to more than 6 percent annual growth in the economy between 1999 and 2002. The growth in GDP, along with a renewed government effort to advance lagging economic structural reforms, raised business and investor confidence over Russia�s prospects in its second decade of transition, which in turn led to have led to a gradual reduction in capital flight.
The capital flight for 2003 totaled $2.7 billion, however, the underlying quarterly flows were quite volatile. The 2003 figure is down from $8.3 billion in 2002 and $15.2 billion in 2001. A significant but by no means predominant portion of capital flight constitutes proceeds of criminal activity. Central Bank officials have not linked the resumption in capital flight to the current scandal surrounding the arrest and indictment for tax evasion and embezzlement of Mikhail Khodorkovskiy, the CEO of the country�s largest oil producer, Yukos.
Russian Federation Federal Law No. 115-FZ �On Combating Legalization (Laundering) of Criminally Gained Income and Financing of Terrorism� became effective on February 1, 2002, with subsequent amendments to the laws on banking, the securities markets, and the criminal code in October 2002, January 2003, and December 2003. The law requires obligated banking and nonbanking financial institutions to monitor and report transactions to an authorized agency, keep records, and identify their customers. Russian financial institutions (e.g., credit organizations, securities market professionals, insurance and leasing companies, funds transfer organizations, and pawnshops) must monitor and report to the government covered transactions that exceed 600,000 rubles (approximately $20,000) and involve any one of a list of specified characteristics, including, for example, the purchase of securities with cash or the use of foreign currency. Financial institutions must also report suspicious or unusual transactions that contain certain high-risk features or when money laundering is suspected.
Earlier reforms (1999) by the Central Bank of Russia (CBR) instituted regulatory measures to scrutinize offshore financial transactions. In the following six months, wire transfers from Russian banks to offshore financial centers dropped significantly. At the same time the CBR curtailed establishing correspondent relations with offshore banks by raising the standards for �eligible� offshore financial institutions and thereby reducing the number. In August 2003, the CBR issued order 1317-U, which regulates the relations of Russian financial institutions with their counterparts in offshore zones. In addition to requiring reporting of all transactions, offshore banks are in some cases subject to enhanced due diligence and maintenance of additional mandatory reserves to offset potential risks undertaken by the Russian institution for specific transactions. Foreign financial entities, including those from known offshore havens, are not permitted to operate directly in Russia: they must do so solely through subsidiaries incorporated in Russia, which are subject to domestic supervisory authorities. During the process of incorporation and licensing, each director of the Russian company must be identified and investigated by Russian authorities; therefore nominee or anonymous directors are, as a practical matter, not permitted under Russian law and regulation. Enforcement of these procedures will be carried out as part of the regular domestic bank inspection process. (Since the regulation is brand new, there is not yet a track record of enforcement.) For Russian businesses that want to open operations abroad, including in offshore zones, government permission is required. The Ministry of Economic Development and Trade (MEDT) has a department that reviews requests from Russian firms, and the CBR must also approve the overseas currency transfer if the MEDT approves. In both these cases, the regulatory body for the offshore activity is the same as for domestic activity.
The CBR has issued guidelines regarding anti-money laundering practices within credit institutions, to include know your customer (KYC) and bank due diligence programs; yet, according to a Financial Action Task Force (FATF) report of April 2003, KYC regulations in Russia are currently inadequate. Though banks are required to know, record, and report identities of customers in suspicious transaction report (STR) filings, and to maintain appropriate records, the current requirement to identify beneficial owners of accounts refers only to establishing the identity of the legal or natural person who controls the funds, not the original source or true owner, thereby in effect allowing a bank to simply identify the nominal owner of the account. According to recent press reports, however, the Central Bank is in the process of drafting amendments to the current banking laws to bring them in line with the revised FATF Forty Recommendations, for consideration by parliament in spring 2004. Amendments to make identification and reporting of all suspicious transactions mandatory, as opposed to only transactions containing certain features, are also underway. Additionally, consistent with FATF recommendations, the criminal code was amended in December 2003, removing a specific monetary threshold for crimes connected with money laundering, and thus paving the way for prosecution of criminal offenses regardless of the sum involved.
Still, issues remain in this sphere. According to the FATF, a recent CBR audit revealed that although most Russian credit institutions perform their obligations as required by Russian money laundering and terrorist finance laws, approximately nine percent of credit institutions and 11.7 percent of credit institution branches were found to be out of compliance with one or more of the requirements of Russian law. Typical breaches involve inadequate record keeping, failure to follow client identification requirements as set out in the internal control rules, mistakes in formulating and submitting records in electronic form to the CBR, and incorrectly classifying transactions as not being subject to obligatory control.
Article 8 of Russian Federation Law 115-FZ calls for the Financial Monitoring Committee (FMC), an independent executive agency administratively subordinated to the Ministry of Finance, to serve as Russia�s financial intelligence unit (FIU). The FMC is responsible for coordinating all of Russia�s anti-money laundering and counterterrorism financing efforts. The FMC, which first became operational in February 2002, is as an administrative FIU, having no law enforcement investigative powers.
The FMC opened seven regional departments in 2003. Each of the territorial offices corresponds with one of the seven federal districts that comprise the Russian Federation. The Central Federal District office is headquartered in Moscow; the remaining six are located in the major financial/industrial regions throughout Russia. The primary functions of the territorial offices are to establish cooperation with regional law enforcement and other authorities to enhance information that comes into the FMC, and to supervise anti-money laundering and terrorism financing legislation compliance by institutions under FMC supervision. Additionally, the satellite offices must identify and register at the regional level all of the pawnshops, leasing, and gaming entities under their jurisdiction. They also are charged with coordinating efforts between the CBR and other supervisory agencies with respect to implementation of anti-money laundering and counterterrorist financing regimes.
Recent amendments to the anti-money laundering law have increased the FMC�s information gathering authority to include activities of investment foundations, nonstate pension funds, gambling businesses, and sales of precious metals and jewelry. Moreover, the amendments allow the FMC, in concert with banks, to freeze possible terrorist-related financial transactions up to one week. (Banks may freeze transactions for two days, and the FMC may follow up with an additional five days.) Consistent with FATF recommendations, further amendments are currently being drafted to expand the list of entities and individuals obliged to report to the FMC on suspicious financial operations. New entities will include lawyers, notaries, realtors, accountants, auditors, and other individuals providing legal services. Using encrypted software provided by the FMC, virtually all reporting from credit, securities, and insurance institutions is submitted via electronic means.
To date, the FMC has received over one million reports, approximately 50 percent of which are mandatory (currency) transaction reports and the other 50 percent suspicious transaction reports. According to the FMC, 12,000 of these reports contained evidence of criminal activity and were turned over to competent law enforcement authorities�the Ministry of Internal Affairs, the State Narcotics Control Committee, or the Federal State Security Service�for investigation, which resulted in the opening of 200 criminal cases. Thirteen of those criminal cases have thus far been sent to court.
In October 2003, the Russian Ministry of Internal Affairs (MVD) announced money laundering investigations against two large banks, Sodbiznesbank and Eurotrust. According to the MVD, four senior officials from Sodbiznesbank were allegedly involved in illegal transactions involving approximately $16.1 million, and three employees at Eurotrust were under investigation for laundering approximately $258 million of criminal proceeds.
In light of the reforms to Russia�s anti-money laundering regime, FATF withdrew its call for countermeasures against Russia in September 2001, and removed Russia from its list of noncooperative jurisdictions in October 2002. The U.S Treasury Department Advisory, which had instructed U.S. financial institutions to �give enhanced scrutiny� to all transactions involving Russia, was also lifted. In February 2003, the FATF granted Russia observer status, and following a successful FATF mutual evaluation in April, Russia became a full FATF member at the June 2003 plenary. At its first plenary as a full-fledged FATF member, Russia announced its intention to create a FATF-Style Regional Body (FSRB) for the five Central Asian States of Azerbaijan, Kazakhstan, Kyrgyzstan, Tajikistan, and Uzbekistan. Russia is currently pursuing this initiative.
Russia has a legislative and financial monitoring scheme that facilitates the tracking and seizure of all criminal proceeds. None of this legislation, however, is specifically tied to narcotics proceeds. Russia�s laws criminalizing money laundering and terrorist financing also provide for the forfeiture of criminal proceeds. Russian legislation provides for a variety of investigative techniques such as search, seizure and compelling the production of documents, as well as the identification, freezing, seizing and confiscation of funds/assets. Where sufficient grounds exist to suppose that property was obtained as the result of a crime, investigators and prosecutors can apply to the court to have the property frozen or seized. Law enforcement agencies have power to identify and trace property that is, or may become, subject to confiscation or is suspected of being the proceeds of crime or terrorist financing. In accordance with its international agreements, Russia recognizes rulings of foreign courts relating to the confiscation of proceeds from crime within its territory and can fully or partially transfer confiscated proceeds of crime to the foreign state whose court issued the confiscation order. However, Russian law still does not provide for the seizure of instruments of crime. Businesses can be seized only if it can be shown that they were acquired with criminal proceeds. Legitimate businesses cannot be seized solely on the basis that they were used to facilitate the commission of a crime. While Russian law enforcement has adequate police powers to trace and seize assets, most Russian law enforcement personnel lack experience and expertise in these areas.
The Russian Federation has enacted new legislation and executive orders to strengthen its ability to fight terrorism. On January 11, 2002, President Putin signed a decree entitled �On Measures to Implement the UN Security Council Resolution (UNSCR) No. 1373 of September 28, 2001.� Noteworthy among this decree�s provisions are the introduction of criminal liability for intentionally providing or collecting assets for terrorist use, and the decree�s instructions to relevant agencies to seize assets of terrorist groups. This latter clause, however, conflicted with existing domestic legislation. Accordingly, on September 24, 2002, the Duma approved an amendment to the anti-money laundering law, resolving the conflict, and allowing banks to freeze assets immediately, pursuant to UNSCR 1373. This law came into force on January 2, 2003. Further, Article 205.1 of the criminal code, which was enacted in October 2002, criminalizes terrorist financing. On October 31, 2002, the Federation Council (Russia�s upper house) approved a supplemental article to the 2003 federal budget, allocating from surplus government revenues an additional 3 billion rubles ($100 million) in support of federal antiterrorism programs and improvement of national security.
In February 2003, at the request of the General Procuracy, the Russian Supreme Court issued an official list of 15 terrorist organizations. According to press reports, the financial assets of these organizations were immediately frozen. In addition, Russia has assisted the United States in investigation of terrorist financing, providing vital financial documentation and other evidence establishing the criminal activities of the Benevolence International Foundation (BIF). Russian authorities have also provided U.S. federal law enforcement authorities with valuable evidence relating to terrorist fundraising activities of an individual currently being prosecuted in the United States for possession of counterfeit currency.
The United States and Russia signed a Mutual Legal Assistance Treaty in 1999, which entered into force on January 31, 2002. To date, the FMC has signed cooperation agreements with the FIUs of the United States, Poland, Britain, the Czech Republic, Belgium, Italy, Panama, France, Estonia and Ukraine. Additionally, the FMC is an active member of the Egmont Group of FIUs, having taken on sponsorship of several candidate countries for 2004. The FBI, DEA and Homeland Security all exchange operational information with their Russian counterparts on a regular basis.
In addition to membership in the FATF, Russia holds membership in the Council of Europe�s Select Committee of Experts on the Evaluation of Anti-Money Laundering Measures (MONEYVAL). Russia ratified the Council of Europe Convention on Laundering, Search, Seizure, and Confiscation of the Proceeds from Crime in January 2001. Russia is a party to the 1988 UN Drug Convention and has signed, and is expected to soon ratify, the UN Convention against Transnational Organized Crime, which entered into force on September 29, 2003. In November 2002, Russia ratified the UN International Convention for the Suppression of the Financing of Terrorism. Russia also became a signatory to the UN Convention Against Corruption, which has not yet entered into force, on December 9, 2003.
The enactment of comprehensive anti-money laundering legislation in 2001, followed by creation of a fully functioning FIU in 2002 and entry into the FATF in 2003, marked major milestones in Russia�s anti-money laundering regime. Although Russia has developed a solid foundation for combating money laundering and can effectively begin to serve as a role model for other governments in its region, legal loopholes remain open that Russia should immediately address. Russia should enact legislation that would provide for the seizure of instruments, as opposed to merely the proceeds, of criminal activity. Russia should also enact more stringent banking legislation requiring financial institutions to identify the true source, or beneficial owner, of funds, as opposed to identifying only the person or entity that controls the funds of a particular account. Russia should continue to address deficiencies in anti-money laundering compliance programs at banking and nonbanking financial institutions, through continued education and outreach to the affected industries. Finally, Russia should continue its active participation in international fora.