The Central Bank of Russia has published guidance on anti-money laundering law amendments that took effect on 3 March 2026, removing credit institutions’ ability to delegate identification or simplified identification of retail customers to bank payment agents (BPAs). As a result, BPAs are no longer permitted to conduct customer identification under existing agreements with credit institutions. The update highlights a 180-day statutory period (Clause 2 of Article 3) for credit institutions to bring their BPA agreements into line with the amended legislation. It states that BPAs should not continue to perform identification functions during this period.