Anti-Money Laundering


On 24 April 2012 the Government adopted Resolution No. 375 amending its Regulation on submission of information to the Federal Service for Financial Monitoring (Rosfinmonitoring) by companies that carry out activities with their clients’ monetary funds and other assets (“controlling organizations”).

The Resolution follows the recent changes to the Anti-Money Laundering Law (see our update for 31 October – 13 November 2011). Under the Law, controlling organizations (e.g., lending organizations, professional participants of the securities market, insurance and leasing companies) must provide Rosfinmonitoring, at its request, with additional information they have regarding transactions of their clients, and lending organizations must additionally provide information on the cash flow in their clients’ accounts (deposits).

According to the Resolution, controlling organizations (other than lending organizations) must provide Rosfinmonitoring at its request with additional information on all those civil law contracts of certain clients that they are aware of, as well as on all the transactions with monetary funds and other assets performed by the controlling organizations upon instruction of such clients.

Lending organizations must also provide Rosfinmonitoring at its request with quite a broad range of information on transactions of their clients, including, among other things, copies of civil law contracts, copies of transaction passports and banking control sheets, account statements for a certain period, data on the incoming balance in their clients’ accounts as of a certain date and copies of client files.

The requested information must be provided to Rosfinmonitoring within five business days of receipt of the request.

The Resolution entered into force on 10 May 2012.

For further information please contact Igor Ostapets or Irina Dmitrieva in the Moscow office of White & Case, tel + 7 495 787 3000 .