Features of Credit Institutions Carrying out Activities in the Field of AML/CFT/PWF in the Context of the Application of Sanctions and Counter-Sanctions

Abstract

The article analyzes the impact of sanctions and counter-sanctions on the procedure and standards of banking services, including on the implementation of credit organizations activities in the field of AML/CFT/PWF. Based on the study of relevant legal acts adopted by authorized Russian bodies and domestic legal doctrine, the author shows that in the current situation of inconsistency between applied models of legal regulation and the established principles of regulation of banking relations, credit organizations are forced to revise their previously successfully tested standards and ethical models of customer service. Therefore, the optimal procedure for the normative consolidation of anti-money laundering procedures in the context of the implementation of counter-sanctions have been determined. The trends in sanction (counter-sanction) compliance and aspects of its interaction with financial monitoring in credit organizations are considered, and a form of formalization of the sanctions (counter-sanction) compliance policy in credit organizations is proposed.