These changes were initiated to implement legislation aimed at combating the financing of criminal activities and the legalization of income obtained unlawfully, as well as taking into account the findings from the National Risk Assessment.
In accordance with the new rules, the criteria have been updated under which operations, clients, or types of activities may be classified as high risk. Such cases include, for example, situations where a non-resident client conducts financial operations under unusual conditions, or when they inadequately disclose information about their beneficiaries and have a complex ownership structure that lacks economic justification.
Also included in the list of high-risk factors are cases where a client frequently changes IP addresses, including the use of foreign VPNs, as well as receiving a significant number of transfers from various non-related individuals followed by a rapid withdrawal or cashing out of funds.
High-risk activities and operations now also include anonymous methods of funding and making payments, transactions with virtual assets, arms trading, fundraising through international crowdfunding platforms without donor identification, as well as the use of crypto-crowdfunding through ICOs, IDOs, token sales, and NFTs. Additionally, operations by individuals exhibiting signs of dropper activity are highlighted separately.
In the updated document, criteria for low risk remain. These include, in particular, government bodies, companies, and institutions with public disclosure of beneficiaries, as well as certain insurance and pension products.
Note:
Dropping is the practice of using bank cards, accounts, or electronic wallets to transfer, cash out, or conceal the origin of funds for others. A dropper is usually referred to as a person through whose account money belonging to others passes.
Crypto-crowdfunding is the process of raising funds using digital platforms and tools related to cryptocurrencies and virtual assets. This can include raising funds through tokens, crypto projects, and other digital financing.
