No specific guidance although there have been various amendments to the federal AML law signed in 2001 (with the latest amendment dated July 2012) and a number of recommendations and instructions issued by public authorities.
The last mutual evaluation has been conducted in 2008
For legal entities, there is no specific threshold under which the due diligence is not required. For individuals the minimum threshold is set
as RUB15,000 (approx EUR 375).
However, there are thresholds above which compulsory control (which means report to regulator) is required, for example, when:
a) the amount of transaction is equal to or exceeds RUB600,000 (approx EUR15,000) if it is in petty cash or wire transfer to the
payee located in countries which do not follow FATF recommendations, certain transaction with bank deposits, etc;
b) transactions with immovable assets if the amount is equal to or exceeds RUB3,000,000 (approx EUR75,000);
c) receipt of monetary funds or other assets by non-profit organisations from foreign entities if the amount is equal to or exceeds
RUB200,000 (approx. EUR5,000)
name, c itizenship, personal identity document details, date of birth, migration card data, document confirming the foreign
citizen's or person's right to stay in Russia, residential (registration) address and taxpayer identification number (if any).
name, taxpayer identification number or code of the foreign organisation, state registration number, registration address and
Organisations shall take substantiated measures to establish and identify beneficiaries, and on a regular basis update information on clients and beneficiaries.
Local regulations state that increased risk operations include: operations with residents of states mentioned in local guidance, operations with international Politically Exposed Persons (‘PEPs’) (and their close relatives), closure of transactions in real estate, performance of banking operations and closure of other transactions with the use of internet technologies and operations with residents of states which do not comply with generally accepted standards as identified through international sources.
Local regulations state that international PEPs (and their close relatives) are subject to additional controls.
Local regulations state that for the establishment of correspondent relations with non-resident banks, the institution shall request information including full name, address, licence information, information about the presence or absence at its location of the legal entity etc. The decision on the establishment of such relations shall be adopted with the consent of the head of the institution or of the institution's employee as authorised to do so.
None stated in local regulations.
Federal Service of Financial Monitoring (FSFM)
Companies are obliged to verify the source and report transaction if (also refer to A8 above) a) the amount of transaction is equal to or exceeds RUB600,000 (approx EUR15,000) if it is in petty cash or wire transfer to the payee located in countries which do not follow FATF recommendations, certain transaction with bank deposits, finance lease arrangement, income from lottery, transactions with precious metals, etc.; b) transactions with immovable assets if the amount is equal to or exceeds RUB3,000,000 (approx EUR75,000); c) receipt of monetary funds or other assets by non-profit organisations from foreign entities if the amount is equal to or exceeds RUB200,000 (approx EUR5,000). d) any transaction in which the receiver or sender is located in a country which does not have AML legislation and which does not cooperate with other countries in the area of AML, etc.
Yes, but the amount and action (e.g., withdrawal of a licence) depends on the specific case.
Yes. There are specific Instructions issued by FSFM on 5 October 2009 (with amendments of April 2012) in respect of suspicious transaction reporting and in particular using electronic tool or special software for reporting.
No. Upon receipt of suspicious transaction report FSFM may verify the information reported by the company and if necessary pass on the information to other competent government body for further consideration.
Subject to local legislation and inter-governmental agreements.
A Russian Internal Passport is compulsory at 14 (but there is no penalty for not having one until the age of 16) and it is reissued at age 20 and 45. Citizens can use any other document for identification, although in certain cases an internal passport is required (e.g. notarial transactions, sale of land and other high-value assets).
There are no critical exceptions to the law.
Russian law recognizes electronic signatures as legal, admissible and enforceable when the parties explicitly agree to use them. However, for enforceable digital signatures, Russia requires that one use a certificate and service provider that has been certified by the Russian government.
Summary of law
Russian courts have held that a signature may not be denied validity simply because it is electronic. However, to be clearly enforceable, digital signatures must be exchanged through a government-certified, specialized service provider that acts as an electronic courier in order to enable electronic document exchange.
General requirement is that the copies of documents provided should be certified by an appropriate person, for example a Notary Public.