In a joint action Bankir.Ru, Association of Regional Banks of Russia and the magazine paper machine. Banks and the business world “was asked several questions about why the letters of Bank of Russia are encouraged to request contract customers conducted transactions, and whether it is a mandatory requirement. Specialists of the Central Bank explained the recommendatory nature of these instructions.

«In accordance with paragraph 2 of Article 7 of the Federal Law № 115-FZ of the credit institution, as the organization carries out transactions involving money or other property, shall in order to prevent the legalization (laundering) of proceeds from crime and terrorist financing to develop rules for internal controls, taking into account the recommendations of the Bank of Russia.

These recommendations are contained in the Letter of the Bank of Russia on July 13, 2005 number 99-T “On the issue guidance on the development of credit institutions of internal controls in order to counteract the legalization (laundering) of proceeds from crime and terrorism financing (hereinafter – Letter number 99-T), paragraph 2.4 which recommended credit organizations to develop program verification of information about the client or the client’s transactions, the beneficiary to confirm the reasonableness of the suspicion of a client legalization (laundering) of proceeds of crime or terrorist financing. According to paragraph 2.4.5 of these recommendations, a credit institution may apply to the client requesting the necessary explanations, including additional information explaining the economic sense of the unusual transactions.

also notes that in letters Bank of Russia, there is no direct guidance on the request of a client-specific documents for an operation ».

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