Translation. Region: Russian Federation –
Source: Central Bank of Russia
An important disclaimer is at the bottom of this article.
We no longer consider sanctions to be a systemic risk for banks.
In an interview with RBC, Olga Polyakova, Deputy Chairperson of the Bank of Russia, discussed the current progress of the fight against money mules, new measures designed to eliminate this shadow economy, how banks have weathered the economic slowdown and what new requirements await them.
"There is no expectation that the situation will worsen next year."
Experts and bankers are giving different estimates of what will happen to banks' financial results by the end of the year: some expect a new record, while others claim that last year's profits won't be "even close." What's the Central Bank's view? Can we expect any one-time positive effects by the end of the year?
As we've already noted, we forecast bank profits this year to be almost identical to last year's: 3.8 trillion rubles in 2024, and we estimate banks will earn around 3.5 trillion rubles in 2025. Profits for the first nine months of the year were around 2.7 trillion rubles, the same as the previous year. However, we mustn't forget the increase in reserve costs, especially in the corporate portfolio, which is putting greater pressure on bank profitability in 2025.
In terms of a one-time positive effect, this year's financial result was supported by income from securities. However, it's probably not surprising – amid the easing of monetary conditions, banks also saw positive revaluations of fixed-rate securities.
– Will pressure on banks’ profits from reserves continue in 2026?
– Looking at the segments, in our view, credit risks in retail will not have the same significant impact on capital and financial results next year, but in the corporate segment, we cannot rule out continued “maturation” in terms of loans to SMEs (small and medium-sized enterprises) and companies with high debt burdens.
– Can we say that 2025 will be the peak year in terms of credit risk realization?
– The growth of overdue payments has indeed accelerated this year; it cannot be called a peak in terms of credit risk, and we do not see any systemic problems.
Risks related to retail loans are now becoming more acute. These were primarily loans that banks actively issued in 2023–2024, including to new borrowers without a credit history, and the risks associated with these loans are more difficult to assess.
In unsecured consumer loans, delinquencies at the end of the first nine months amount to 12.9% of the portfolio, an increase of 3.8 percentage points since the beginning of the year. However, these loans are well covered by reserves. In the mortgage portfolio, the level of problem loans remains very low – 1.7%. Regarding the banks' corporate business, we currently do not see any significant problems. So-called bad loans (quality categories IV and V, i.e., problematic and hopeless loans) have mostly matured; their share of the total portfolio does not exceed 5% – a completely normal figure – and they are 87% covered by reserves and collateral. Potentially problematic loans account for another almost 7% of the corporate portfolio. Clearly, the key rate is high, there are problems with exports, with rising logistics costs, and this is putting pressure on borrowers' financial standing. But I wouldn't say this is dramatic. Banks are working with these borrowers in a focused manner, accommodating them on restructuring issues, and working together to find suitable solutions.
We don't expect the financial situation of banks' corporate borrowers to deteriorate significantly next year. At the same time, as a regulator, we take a conservative approach to credit risk assessment and encourage banks to create reserves for loans where necessary.
"About 20% of drops are made by minors."
According to the latest Central Bank data, up to 100,000 dropper accounts are opened in Russia every month. At the beginning of the year, the figure was 80,000 monthly. It seems the problem isn't abating. Is this true?
"The problem is actually declining. Beyond the number of mules—that is, citizens involved in illegal activity—we need to look at the volume of p2p transfers through mules' accounts. These transfers are the main method of non-cash payments between shady businesses and citizens. We noticed this three years ago when we saw an increase in such transactions."
To combat, identify, and stop such schemes, we work closely with banks. We've increased the speed at which we detect and stop transactions on mule accounts. As a result, the volume of transactions on mule accounts this year has decreased more than threefold compared to last year. The average transaction amount per mule has also decreased significantly. This is a very significant reduction, and in our view, it's the most important indicator.
What else? We've made it inconvenient to use a dropped card. While such a card might previously last about a month, now it's detected quickly, within hours, sometimes even minutes. This makes the card more expensive: it used to cost around 10,000 rubles, now it's 30,000–50,000 rubles, and if we're talking about a premium card, which typically has higher transfer limits, such cards cost up to 70,000 rubles.
This business is becoming increasingly inconvenient and expensive. Our goal is to eliminate it.
The Central Bank's database already contains data on 1.2 million dropouts; at the end of 2024, there were 700,000. How many such clients are there now? And why was there such a significant increase in their number?
"1.2 million—it's still around that level. The increase in the number of drops in previous periods was also influenced by our actions: drop accounts are blocked, and drop operators need to quickly replace them to compensate for the loss of those who were previously able to work but ended up in our database."
Unfortunately, approximately 20% of droppers involve minors. This can be explained by the fact that young people don't fully understand the risks they're taking, lured by the prospect of easy money. We hope that the amendments to the Civil Code that came into force in August prohibiting banks from opening accounts for minors without the consent of their legal representatives will help address this issue. We, for our part, have issued guidelines for banks to reduce the risk of minors becoming involved in dropper operations. However, it should be noted that older people also fall victim to dropper networks. We estimate that they account for approximately 5%.
— Have you seen any impact since this regulation was adopted? Has the flow of underage drug users decreased?
– It’s too early to talk about the effect; the measure came into effect on August 1, and too little time has passed to make such assessments.
"Citizens don't fully understand the potential consequences of their operation."
Amendments recently came into force introducing criminal penalties for money mules. There are already cases against such individuals. Is this helping to reduce the volume of dubious transactions?
The measure has been introduced, but there are still only a few such criminal cases. One of the first was against a sole proprietor who allowed dropshippers to use his account. Overall, we believe this measure will have a positive effect. Of course, reducing the volume of dropshipping operations depends largely on our work with banks, but the psychological factor of being at risk of criminal liability plays a significant role. Furthermore, I'd like to remind you that criminal liability has been introduced not only for dropshippers but also for the individuals who use their cards.
It's important to note that individuals caught up in drug dropper activities must cooperate with law enforcement and banks and disclose the names of those who brought them into this "work"—the dropper operators. Then, I hope, there will be fewer such cases and fewer criminal penalties for individuals. Incidentally, amendments to the Criminal Code stipulate that if an individual actively cooperates with law enforcement, they may be exempt from criminal liability.
Another of our tasks in this area is education. We need to educate people about the risks and negative consequences of dropper activity and explain the rules of safe financial behavior to prevent fraudsters from luring them into illegal activities.
– It's common for banks, when suspected of money droppers, to avoid pursuing criminal charges or going to court, instead resolving the issue directly with them. The dropper voluntarily files a report of the fraudulent transfer, and the bank gains grounds to return the funds transferred to the defrauded clients. How does the Central Bank view this?
"Yes, of course. I believe that restoring a normal customer experience is the bank's job; it's a form of educational outreach to its clients. It's a perfectly normal approach."
Have you ever recorded cases where someone was intentionally targeted for a drop by sending funds of dubious origin to their card?
"It's very difficult to answer this question; such cases are most often recorded by law enforcement agencies. We, for our part, have already drawn the attention of citizens to the risks of interacting with shadowy online businesses, where the "triangle" scheme is actively used. These are cases where, when making payments to crypto exchanges and online casinos—and such entities operate illegally in our country—a person may unwittingly become involved in transactions related to the financing of criminal activity or drug trafficking. In this case, it's safe to say that the citizen doesn't fully understand the potential consequences of their transaction."
For example, someone sells cryptocurrency through an illegal crypto exchange for a total of 100,000 rubles, and the money arrives in their account in small transfers of 2,000–3,000 rubles. Often, citizens don't realize that the transfers are coming from people placing bets at online casinos, paying for drugs, or from people who, believing the scammers, transferred funds to a "safe account."
As a result of such an operation, the individual ends up in our anti-money laundering database or in our database of all fraud cases and attempts, and their transactions are restricted or blocked in accordance with the law. They are then forced to explain to the bank, law enforcement agencies, or the Bank of Russia whether or not they were involved in the questionable transactions.
– How common are “triangle” schemes nowadays?
"I wouldn't say it's the main method now, but it's still a common payment method. It's popular with shadow businesses because banks see the transfer as between two legitimate clients, without any money laundering involved."
“The goal is not to completely cut off the client from banking services.”
At the end of 2024, the Central Bank announced the launch of a unified platform for exchanging information with banks on individual clients suspected of being droppers. What stage is this work at?
The Antidrop platform concept has been approved, the architecture design has been prepared, and we are currently developing the technical specifications so that we can begin developing the platform itself next year. The algorithms are all ready, and we understand how it should work, but this process is not quick. According to optimistic forecasts, the platform should be operational by mid-2027.
We will provide all banks with access to this platform. It's important not just to accumulate data, but to create an environment where every bank can see information about drops from other banks. This will allow us to more quickly identify the "migration" of drops between banks and reduce their spread throughout the system as a whole.
Previously, mules preferred large banks, where it was easier for them to "disappear." Now, large banks work effectively with us and quickly close mules' accounts and terminate their operations. Therefore, mules are moving to other banks—medium-sized or even very small ones. We're also seeing a fragmentation of transactions: while the average monthly mule transaction amount used to be just over 1 million rubles, it's now 100,000–150,000 rubles. And even this amount is being split between banks—mules open multiple cards at different banks and make small transfers.
It's more difficult for banks to assess such transactions individually, but we see the full picture across the banking system. We currently exchange information with each bank individually, and the platform will improve the speed and quality of information exchange on risky bank clients and streamline compliance procedures.
– How many banks might be in the test group next year?
"It's difficult to say yet. But I would note that the banking sector as a whole is interested in such a database being created. When the "Know Your Customer" platform was being developed, we heard banks' doubts and concerns, but now they view the development of the new "Antidrop" platform as a benefit. We believe the client identifier in the system will be the INN (Individual Taxpayer Identification Number – RBC), which banks have long used and are comfortable with. During our surveys, banks confirmed to us that this choice was appropriate."
– If a bank receives information from the Central Bank about a specific client, will it be obligated to restrict their transactions automatically, or will this be left to the bank’s discretion?
– The second option. The Antidrop platform data is more of ancillary information, and credit institutions will retain the right to independently determine a client's risk level. The Know Your Client platform currently operates in a similar manner. We see signs that a client has committed a questionable transaction, but the bank needs time to work with such a client.
– Will connecting banks to this service be mandatory?
Yes. It's also important to note that while banks previously didn't require clients to provide their Taxpayer Identification Number (TIN) as a mandatory account detail, we will introduce this requirement—both when opening new accounts and for existing accounts. This means banks will need to gather the necessary data themselves. Banks already have tools from the Federal Tax Service of Russia that allow them to obtain a client's TIN without contacting the client.
– There's already information that those included in the "Antidrop" database won't face a complete shutdown of their banking operations, but rather restrictions on peer-to-peer transactions and cash deposits. Why is the approach with limits being discussed? What might those limits be?
"It's too early to talk about limits; this issue is still under discussion. Of course, the goal isn't to completely cut off the client from banking services. We will set limits so that the mule account becomes unprofitable for shadow businesses, while the individual retains access to key banking services."
Potentially risky operations that organizers of shadow transactions often use include, for example, receiving money from third parties, mass collection of money, and depositing cash into an account when the source of these funds is opaque.
Customers will be able to conduct routine transactions—payroll, goods, and services—all of this will be available. We're focusing our efforts to avoid exacerbating negative customer experiences. We prioritize access to financial services and educational outreach, and I hope that when the Antidrop platform launches, this business will become unattractive to droplets.
What's the mechanism for rehabilitating clients included in the Anti-Drop database? Will there be a clear timeframe for how quickly a client can be removed from the database?
"There will definitely be a rehabilitation mechanism. We plan that if restrictive measures are imposed, the client will need to contact their bank and provide the necessary explanations. We don't plan to create interdepartmental commissions, as envisaged in other mechanisms. This will be a dialogue between the client and the bank, and the bank will then forward the information to the Central Bank regarding its decision. If the client is deemed a drop, they will need to take their mistakes into account and rectify the situation."
“We don’t see any abuses on the part of banks.”
– Overall, due to measures taken to combat fraud and dropshipping, the issue of banks unjustifiably blocking individual cards has become more common. Are there any abuses in this area?
"Let's first clarify the wording. Blocking remote banking services due to suspected fraudulent transactions or transactions conducted without the client's voluntary consent are measures applied in accordance with Federal Law 161-FZ ("On the National Payment System" – RBC). These are information security issues, a related area."
Anti-money laundering legislation has a different mechanism for combating mule operations. I can say that we don't see any abuses by banks. When a bank sees certain indicators of a transaction that raise questions, such as a large cash deposit, it stops the transaction. But this is always followed by a conversation with the client. If the client is open and answers the bank's questions, the transaction goes ahead. If not, then the bank was right.
Of course, the Bank of Russia is actively working with banks to improve the accuracy of their operations, sending informational letters, and providing recommendations to improve the quality of interactions with clients and make faster decisions on unblocking an account if suspicions of a suspicious transaction are not confirmed.
– There's talk of creating a unified system to limit the number of cards per person. When might it be launched?
Legislative changes to limit the number of cards per person haven't been introduced; they're still being discussed. It's difficult to say when this will be implemented. We proposed a limit of five cards per bank and 20 cards across the entire banking system. When we began combating dubious p2p transactions, I was honestly surprised to learn that someone could have, say, 40–50 cards per bank.
Next, we need to think about how to administer this. We're also considering the Taxpayer Identification Number (TIN) as an identifier, which will allow us to verify the number of accounts and cards per person.
"Banks should not be a 'window' for purchasing cryptocurrencies abroad."
Recently, the Central Bank and the Ministry of Finance revealed plans to fine-tune the regulation of the cryptocurrency market in Russia, including legalizing crypto exchanges and so on. Some argue that while it's impossible to effectively ban Russians with crypto from using foreign crypto exchanges, it's possible to make it more difficult to convert fiat money into crypto. How might this work?
We see interest from individuals and businesses in cryptocurrency, but these investments are associated with risks. The Bank of Russia, together with the government, is developing a draft law to clarify this area and establish regulations. We expect to complete discussions by the end of the year, so that such a law can be adopted next year and implemented in 2027. This will help define market participants and investors, create a legal infrastructure for cryptocurrency transactions, and permit the operation of crypto exchanges, brokers, custodians, and exchangers. We do not rule out the possibility that, subject to special capital adequacy and AML/CFT requirements, banks could also act as such intermediaries, allowing clients to use the services of organizations they trust.
At the same time, we believe it is necessary to ban the activities of illegal intermediaries who violate the law and do not protect the interests of their clients.
– Will the Central Bank issue any new recommendations to banks, as there is currently no such regulation?
Russian banks should not be a gateway for purchasing cryptocurrency abroad without complying with AML/CFT procedures and Russian laws. While in Russia, citizens with the skills to perform such transactions should be able to conduct them through legal Russian intermediaries. Banks, in turn, must protect their clients and monitor the legality of transactions.
We will include relevant provisions in the regulations, but the Bank of Russia's current recommendations also clarify the risks of such transactions for banks. We may need to conduct additional work with banks in this area, but we don't currently see a need to issue any new recommendations.
"Banks can increase capital through profits."
In the spring, ACRA reported that at least six systemically important banks had insufficient capital reserves, given the increasing capital buffer requirements. Do you agree? Are there currently more or fewer than six such banks?
"We're not discussing individual credit institutions. But overall, I can say that systemically important banks are profitable and can use their profits to increase capital and comply with regulations. Yes, capital reserves are unevenly distributed both at systemically important banks and in the banking sector as a whole. But there are no violations; the banks are stable."
Under our baseline scenario, all systemically important banks will be able to independently increase capital using profits, comply with regulations, and continue lending to the economy. As a reminder, starting January 1, 2026, systemically important banks will be required to meet capital adequacy ratios with buffers (including countercyclical buffers) at 10%, and starting January 1, 2027, at 10.75%.
We work closely with each bank to ensure they can manage the situation even in a hypothetical stress situation: reduce growth rates, sell loan portfolios, and, if necessary, raise funds from shareholders for additional capital. These are fairly standard procedures. Every year, the largest banks develop financial stability recovery plans to have a set of actions in the event of any stressful situation. As a regulator and supervisory body, we need this to ensure that, even in a hypothetical stress situation, the bank knows what steps it will take to maintain financial stability.
– Do you see a qualitative improvement in the capital situation in Russian banks this year?
Yes, we do. Overall, according to data for the first nine months of 2025, the sector's capital buffer is approximately 8 trillion rubles, with an increase of 1 trillion rubles since the beginning of the year. This is sufficient for banks to cover potential losses in the event of potential stress, but it is important that they continue to gradually increase their capital. Many banks already have capital buffers above the required level, but there are also those that are meeting the standards in accordance with the buffer restoration schedule we announced in 2022. As a reminder, banks must reach the target minimum standards and buffers by 2028.
Until recently, the market was pricing in a possible easing of sanctions against Russia, but now the statements are different. How does the Central Bank assess the likelihood of further sanctions? And in general, do you consider sanctions a systemic risk for banks now?
No, we no longer consider sanctions a systemic risk for banks. Currently, more than 130 banks are subject to sanctions, representing approximately 95% of the sector's assets. We believe the period of adaptation to new realities and restructuring of banking businesses as a whole has passed.
“The concentration on the balance sheets of individual banks has indeed increased.”
– A risk you've certainly highlighted more than once is banks' increased concentration on large clients. Has this problem worsened after the wave of restructurings?
– During restructuring, as a rule, the bank’s concentration does not increase – usually restructuring is associated with a change in the order of interest payments and loan terms, but does not increase the volume of debt.
Currently, we don't see this problem worsening. However, the balance sheets of some banks are indeed showing increased concentrations. We are working with them on a case-by-case basis, and we have plans to reduce these concentrations with each bank individually. We see that some are already taking certain steps in this direction.
– What stage are preparations for the implementation of new concentration standards and the "orange zone" for banks?
– As for incentives for banks aimed at reducing concentration, we are currently finalizing the concept and plan to announce the details at the end of this year or the beginning of next year.
The basic idea remains: banks will pay additional contributions to the Mandatory Deposit Insurance Fund (MDIF) for increased concentrations. We understand that banks won't be able to immediately normalize the accumulated concentrations, so we want to create an additional economic incentive to accelerate the process. As I've already mentioned, the mechanism is still being developed; the "orange zone" was its working title at the initial stage; we are moving away from that term.
Regarding the new H30 concentration standard, the relevant draft law has been developed and is currently being coordinated with the relevant agencies. We expect the standard to come into effect no later than 2027. Under the new standard, concentration requirements for banks will be gradually tightened, and our goal is to ensure that by 2031, banks' borrower concentrations do not exceed 25% of their capital.
As you noted, some banks are already taking steps to reduce their exposure to large clients. How does this translate into this, given that they already have outstanding debt?
"Basically, a bank has two key ways to reduce concentration: reduce the debt of a specific borrower by redistributing it within the banking sector, or increase capital to dilute the concentration. The latter—quickly and significantly increasing capital—is more difficult. The first option means refinancing an existing loan, distributing the debt among a syndicate of banks, or using another bank's guarantee. We create regulatory incentives to redistribute risk within the system through such instruments."
– Have there been such cases of debt distribution to a syndicate on the market before?
"Of course. This method isn't very common yet, but it's one of the tools for reducing concentration."
– Until 2022, syndicated lending was very actively developed by subsidiaries of foreign banks.
"They don't do this on the Russian market anymore. But the range of banks participating in syndicates is growing."
“We have no complaints about Transcapitalbank as a health resort.”
Central Bank Chairwoman Elvira Nabiullina recently explained the reason for the large hole in Tavrichesky Bank, which, despite its reorganization, still lost its license. It was due to investments in Eurobonds, including Finance Ministry Eurobonds. But Russian sovereign securities could have been substituted, so why didn't they work at Tavrichesky?
– The substitution does not involve a change in the currency on the balance sheet, so the open foreign exchange position that the bank acquired in 2022 could not be closed to the same extent.
– Can we say that many banks undergoing rehabilitation have this problem?
"No, you can't say that. The problem isn't typical for other banks undergoing financial rehabilitation."
– Recently, there was also the case of Investtorgbank: its receiver, Transkapitalbank, transferred it to the Deposit Insurance Agency, while purchasing its portfolio of “healthy loans.”
"Those were the conditions, yes. For entirely objective reasons, a civilized divorce took place between these two banks. We have no complaints about Transcapitalbank as a rehabilitator; they operated conscientiously and responsibly. We discussed various paths for the further development of these banks in dialogue with the owners and management of Transcapitalbank. Ultimately, we came to the conclusion that Transcapitalbank needed to be preserved separately and the rehabilitative process of Investtorgbank completed. Transferring it to the DIA was the only option."
– Is the logical conclusion of the Investtorgbank reorganization still a recovery?
"The main objective was to ensure the stability of the banking system, and this has been achieved. Going forward, assets will gradually be used to pay off creditors and repay liabilities, and once all obligations to creditors and depositors have been met, voluntary liquidation will follow. There will be no bankruptcy or other negative consequences."
Koshkina Yulia, Feinberg Anton, RBC
Please note: This information is raw content obtained directly from the source. It represents an accurate account of the source's assertions and does not necessarily reflect the position of MIL-OSI or its clients.
