These changes were initiated as part of the implementation of legislation aimed at combating the financing of criminal activities and the legalization of income obtained through illegal means, as well as taking into account the results of the National Risk Assessment.
The updated document clarifies the criteria by which clients, their operations, or types of activities can be classified as high-risk. For example, such cases include operations of non-resident clients conducted under unusual conditions, as well as situations where the client does not provide sufficient information about the beneficial owner or has a complex and opaque ownership structure without a clear economic justification.
Additionally, the list of high-risk factors has been expanded to include cases where clients use multiple devices, frequently change IP addresses, including foreign VPNs, and receive numerous transfers from different unrelated individuals that are quickly withdrawn or cashed out.
High-risk operations and activities also include anonymous methods of funding and payments, operations with virtual assets, arms sales, fundraising through international crowdfunding platforms without donor identification, as well as the use of crypto-crowdfunding through ICOs, IDOs, token sales, and NFTs. The document also specifically mentions operations of individuals that exhibit signs of dropper activity.
The updated order retains the criteria for low risk. These include government bodies, companies, and institutions, public organizations that disclose information about their beneficiaries, as well as certain insurance and pension products.
Note:
Dropping refers to the use of bank cards, accounts, or electronic wallets to transfer, cash out, or conceal the source of funds in the interests of third parties. A dropper is typically referred to as a person through whose account the money of other people passes.
Crypto-crowdfunding is the process of raising funds through digital tools and platforms related to cryptocurrencies and virtual assets, including tokens, crypto projects, and other financing mechanisms.
