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Appeal to all international banks from Ukrainian association UkrSWIFT

Correspondent relationship is a crucial part of every established bank business lines. Due to the Russian invasion in Ukraine, SWIFT has taken a decision to disconnect number of Russian Banks from the SWIFT network. This was the first step taken by SWIFT towards disabling financing of war. However, majority of Russian banks continue to operate with full access to international payments either through direct correspondent accounts, either through nesting.

On behalf of Ukrainian SWIFT Users' Group in Ukraine, Association UkrSWIFT, we call for your support in the fight against Russia and its military operations on the territory of Ukraine.

In the situation of Russian military aggression, to continue support of money flows to/from Russia, is not only unethical, but also possesses a huge risk of executing the transactions directly connected with needs of the military operation. As such transaction flows from sanctioned banks can be moved to smaller Russian banks or conducted through nested accounts opened with banks in other countries.

Last but not the least, provision of transaction banking capabilities to Russian Banks falls into the business lines which contradicts the following regulations, recommendations, and best practices, in particular:

1) Fifth Money Laundering Directive 2018/843 and Annex II

2) Wolfsberg principles

3) Proceeds of Crime Act 2002 (as amended by the Serious Organised Crime and Police Act 2005) (POCA) - this is the primary UK AML regulation that defines the offences that constitute money laundering.

4) The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (as amended by the Money Laundering and Terrorist Financing (Amendment) Regulations 2019) (the Money Laundering Regulations) - this legislation transposes the Fifth Money Laundering Directive into the UK law -

5) The Terrorism Act 2000 (as amended by the Anti-Terrorism, Crime and Security Act 2001 and the Terrorism Act 2006) (TA) - this legislation deals with counter financing of terrorism obligations on banks and financial institutions, which also include CDD, transaction monitoring and reporting obligations.

6) Sound management of risks related to money laundering and financing of terrorism - consultative document (

7) FATF-GAFI, the Financial Action Task Force standards and recommendations to prevent Money Laundering

We appeal for support of your Institution to discontinue relationship with Russian banks and prohibit other financial institutions holding correspondent accounts with your Bank from provision of nested transactions to Russian banks. Taking the guidance from the above-mentioned documents we believe that provision of correspondent banking services to Russian banks, currently cannot be justified with any risk appetite of any financial institution and.

Correspondent relationships with Russian banks should be ended immediately.

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