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Янв2020

Выводы ФАТФ по итогам оценки соответствия национальной системы России

1. Росфинмониторинг является основным элементом функционирования российского режима ПОД/ФТ, поскольку он отвечает за руководство и координацию выработки и реализации политики и осуществления оперативной деятельности в области противодействия ОД/ФТ. Эта работа получает активную поддержку, в том числе на законодательном уровне, поскольку российское правительство уделяет наиболее приоритетное внимание вопросам ПОД/ФТ. Взаимодействие и сотрудничество на национальном уровне являются одной из сильных сторон российской системы ПОД/ФТ.

2. Российские власти имеют глубокое понимание существующих в стране рисков ОД и ФТ, которые изложены в отчетах о национальных оценках рисков отмывания денег и финансирования терроризма от 2018 года и были доведены до сведения группы экспертов-оценщиков. Риски ОД и ФТ хорошо определены и поняты. Финансовые учреждения хорошо понимают эти риски, однако, степень их понимания другими подотчетными субъектами различается.

3. В распоряжении Росфинмониторинга имеется огромный объем данных, включая большое количество сообщений. Росфинмониторинг использует современные технологии и высокий уровень автоматизации процессов для определения приоритетности, инициирования и содействия в расследованиях дел, осуществляемых правоохранительными органами. Правоохранительные органы регулярно и эффективно получают и используют эти оперативные финансовые данные в целях расследования случаев отмывания денег, финансирования терроризма и предикатных преступлений, а также для отслеживания преступных доходов. Прокуроры дополнительно обеспечивает использование оперативных финансовых данных в процессе разработки дел, поскольку они систематически анализируют расследования для проверки того, что правоохранительные органы отрабатывают все возможные финансовые элементы в ходе расследований.

4. В России расследования деятельности, связанной с отмыванием денег, частично соответствуют характеру существующих в стране рисков. Правоохранительные органы регулярно проводят финансовые расследования параллельно с проведением расследований предикатных преступлений. Большинство расследований случаев отмывания денег касается приобретения или сбыта имущества, добытого преступным путем, и поэтому большинство дел связаны с менее тяжкими преступлениями. В России часто расследуются случаи самоотмывания, в отличие от случаев отмывания денег через третьих лиц, которые выявляются и расследуются в меньшей степени. Также имеют место случаи расследования сложных дел, связанных с ОД, однако, у правоохранительных органов могут иметься дополнительные возможности для выявления и расследования изощрённых и/или более масштабных схем отмывания денег, особенно в финансовом секторе, связанных с выводом незаконных доходов, особенно касающихся в широком плане коррупции. Наказания, накладываемые на физических лиц за отмывание денег, являются умеренно эффективными. Хотя юридические лица не подлежат уголовному преследованию в России, российские власти не продемонстрировали применение административных наказаний в отношении юридических лиц. Альтернативные меры являются существенной составной частью набора средств и инструментов, имеющихся в России для борьбы с финансовыми преступлениями и преступлениями, касающимися использования фиктивных компаний, которые потенциально связаны с отмыванием денег.

5. Для борьбы с финансированием терроризма в России существует надежная правовая база, которая в значительной степени соответствует международным стандартам. В среднем, в России ежегодно осуществляется 52 судебных преследований за финансирование терроризма. С 2013 года в России было осуждено более 300 человек за ФТ, большинство из которых были приговорены к лишению свободы на сроки от 3 до 8 лет. Российские власти наглядно демонстрируют, что они лишают террористов, террористические организации и лиц, занимающихся финансированием терроризма, активов и средств совершения преступлений с помощью различных подходов, в частности, посредством включения в списки террористов, административного замораживания, судебных постановлений и конфискации. Несмотря на то, что общая сумма конфискованных активов и средств совершения преступлений является относительно низкой, она соответствует характеру рисков, существующих в России.

6. В целом, в России имеется хорошая система для применения адресных финансовых санкций за финансирование терроризма и распространения ОМУ, но в некоторых сферах имеются недоработки и недостатки. Это касается, в том числе, недостатков в безотлагательном применении адресных финансовых санкций и отсутствия в законодательстве четких подлежащих обязательному выполнению требований, распространяющихся на всех физических и юридических лиц (помимо подотчетных субъектов).

7. Наблюдается широко распространенная и сохраняющаяся тенденция неисполнения обязательств, касающихся применения предупредительных мер в целях ПОД/ФТ. Несмотря на то, что количество нарушений снизилось в последние годы, пороговые суммы для направления сообщений о подозрительных операциях являются низкими, а автоматизация процесса приводит к направлению очень большого количества сообщений. Хотя эти сообщения используются подразделением финансовой разведки для анализа данных, в них не содержится подробных сведений, либо информации, указывающей на серьезные подозрения или операции, требующие срочного внимания. Увеличение числа направляемых СПО может привести к росту количества случаев прекращения деловых отношений и отказов в осуществлении операций в связи с озабоченностью по поводу ОД/ФТ. На момент проведения выездной миссии в России отсутствовала возможность обмениваться информацией внутри финансовых групп.

8. Начиная с 2013 года, Банк России использует некоторые элементы риск-ориентированного подхода в своей надзорной деятельности и в последние годы усовершенствовал риск-ориентированный подход в надзорной сфере. В 2013 году были ужесточены требования к лицензированию финансовых учреждений, которые в настоящее время позволяют в значительной степени снизить риск того, что преступники смогут стать владельцами или получить контроль над финансовыми учреждениями. Однако в основе надзорной деятельность лежат, главным образом, пруденциальные факторы, и Банк России в чрезмерной мере полагается на дистанционный (камеральный) контроль. Несмотря на отзыв ряда лицензий, применяемые наказания не во всех случаях являются эффективными или сдерживающими, а суммы налагаемых денежных штрафов являются небольшими.

9. В России была усовершенствована законодательная база и оперативный подход в целях повышения прозрачности юридических лиц, что затрудняет возможность незаконного использования юридических лиц, создаваемых в России. Требования о регистрации были ужесточены, а в отношении юридических лиц проводится регулярный анализ, и они исключаются из реестра за предоставление неточной информации или за отсутствие реальной коммерческой деятельности. Юридические лица хранят информацию о своих бенефициарных владельцах, и компетентные органы эффективно осуществляют надзор за соблюдением этого требования. Финансовые учреждения и УНФПП также собирают информацию о бенефициарных владельцах своих клиентов, но возможности по проверке этой информации являются довольно ограниченными.

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