The Russian Federal Service for Financial Monitoring (abbreviated in
Russian as ‘Rosfinmonitoring’) has issued recommendations on how companies that
offer book-keeping services should comply with the legislation on money
laundering and the financing of terrorism.
When they supply their services, such
companies are obliged:
- to identify
their clients (to request documents confirming the name, organizational and
legal form, taxpayer’s identification number (INN), primary state registration
number (OGRN) and address of a legal entity);
- within 3 days,
to notify Rosfinmonitoring of any suspicious transactions;
- not to
disclose that they handed over the relevant information to Rosfinmonitoring;
- to store
documents and information that are obtained for at least 5 years after terminating
the relationship with the client.
The criteria for suspicious transactions
are:
- a confusing or
an unusual nature of a transaction which has no economic substance or any
obvious legitimate goal;
- inconsistency
between the transaction and the objectives of company’s operations as those are
established by the constituent documents;
- repeated
transactions whose nature gives reason to believe that the purpose of such
transactions is to avoid mandatory control under the money laundering law;
- any other
circumstances which give grounds to believe that transactions are aimed at
money laundering or the financing of terrorism.
In supplying its services, Acsour strictly follows all requirements of
current Russian legislation, including recommendations of Rosfinmonitoring. We
pay close attention to the companies we accept as clients. We are delighted to
inform you that none of our clients has been involved in suspicious
transactions.
