New obligations of accounting firms as regards fighting money laundering and the financing of terrorism
Legal Digest \ 21.05.2018

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.