What is Federal Law 115 and why can it lead to bank accounts being frozen?

Since 2001, Federal Law No. 115-FZ, aimed at combating money laundering and the financing of terrorism, has been in effect in Russia. According to this law, credit institutions have the right to suspend any transactions they deem suspicious and require account holders to provide supporting documents. This legislation plays a key role in ensuring the financial security and transparency of the banking system, as well as in the fight against financial crime. It is important that bank clients understand the need to comply with the law and are prepared to provide the necessary documents upon request by the bank.

Various financial transactions may come under suspicion. For example, withdrawing cash from a legal entity's account to pay salaries or transferring 10,000 rubles from a personal account to a friend as a loan. We discussed with a bank representative how such transactions are monitored and what factors may raise suspicions in financial institutions.

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How Federal Law 115 works and what transactions are monitored;
How bank transactions are verified;
What to do when your account is blocked;
What to do to avoid blocking.

Vyacheslav Andryushkin, Deputy Chairman of the Management Board of SDM-Bank, answered the questions.

How Federal Law No. 115-FZ works and what operations do banks monitor?

Banks analyze all operations in their systems to identify suspicious payments and transactions that require mandatory control. It is important to understand how this happens and what measures are taken to ensure the security of financial transactions.

Operations subject to mandatory control include all actions specified in Article 6 of Federal Law No. 115-FZ. These include, among other things, money transfers, currency exchange, and transactions with securities. Also subject to mandatory control are transactions related to the purchase or sale of real estate, as well as operations related to the financing of terrorism and laundering of proceeds from crime. It is important to take into account that this control is aimed at preventing criminal activities and ensuring the security of the country's financial system.

withdrawal or deposit of cash to a legal entity's account;
real estate transactions in the amount of 5 million rubles or more;
sending or receiving money from counterparties from countries that do not comply with FATF requirements.

Banks transmit information about suspicious transactions to Rosfinmonitoring. This service conducts independent checks of transactions. Clients do not receive notifications about the transfer of data, since banks do not inform about such actions, and Rosfinmonitoring does not publish reports on the results of its checks.

Rosfinmonitoring, if it detects signs of irregularities in a financial transaction, has the right to request additional documents from the bank to clarify the information. This allows for a more in-depth investigation and the identification of possible violations. It is important to understand that compliance with regulations and transparency in financial transactions help avoid negative consequences and ensure the legality of all actions.

Suspicious transactions in banks. Each bank establishes its own internal criteria for evaluating transactions. These criteria are not publicly available, making them inaccessible to clients. However, understanding the general principles can help avoid unwanted situations. For example, transactions involving large amounts, frequent transfers between different accounts, or transactions involving countries with high financial risks may raise questions from financial institutions. Therefore, it is important to be attentive to your financial activities and comply with the law.

Banks may pay attention to the accounts of individual entrepreneurs where there are no receipts or expenses for a long time, followed by a sudden large sum. Cryptocurrency transactions, especially large amounts, transfers to counterparties that may appear suspicious, and payment splitting also raise concerns. These factors may lead to additional checks and questions from financial institutions.

Banks have the ability to review all client transactions that may appear suspicious, including transactions up to 1 million rubles. This helps prevent fraud and protect the financial interests of both clients and financial institutions. Establishing such controls is important for ensuring the security of money transfers and maintaining trust in the banking system.

The bank independently decides on how to handle suspicious transactions. Possible steps include:

submitting transaction details to Rosfinmonitoring, even if it is not subject to mandatory control;
suspending the transaction to ensure it does not pose a risk;
refusing to process the transaction;
suspending remote access to the account.

Blocking access to an account is an extreme measure that banks use in exceptional cases. In a highly competitive environment, banks strive to attract and retain customers, so they do everything possible to simplify interaction with the financial system. Blocking access to funds occurs only for serious reasons and is used much less frequently than, for example, transaction verification. This helps maintain customer trust and ensure their financial security.

In this section, we will consider the verification process in detail.

How a bank verifies transactions and a client

A bank typically follows the following algorithm: upon detection of a suspicious transaction, it suspends its execution, notifies the client, conducts a thorough investigation, and makes a final decision on further action.

Defining a suspicious transaction is an important element of the work of commercial banks. In most cases, this process is automated, which helps improve the efficiency and speed of transaction processing. Computer programs used in banks conduct an initial assessment of all transactions based on pre-established criteria. If the program identifies a suspicious transaction, it suspends its execution and transfers the information to a bank employee for further analysis. This provides an additional level of security and helps prevent fraud and financial losses.

Notifying the client. The bank informs the client about the suspension of the transaction until further clarification. Typically, this information is communicated via push notifications in the banking app. This allows customers to stay up-to-date on the status of their financial transactions and take appropriate action.

Banks are trying to avoid using phone calls and SMS to communicate with customers due to the increase in fraud. Many customers have lost trust in these methods of communication, making them less effective. Instead, financial institutions are opting for safer and more reliable communication channels, such as mobile apps and online banking, which protect data and build trust with users.

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How to recognize a call from scammers and protect yourself Telephone scams

Telephone scammers use a variety of tricks to deceive people and steal their money or personal information. To minimize the risk of becoming a victim, it's important to recognize the signs of a scam call. Pay attention to the following: the caller may claim to be from a bank or government agency, demand urgent information, or threaten consequences if you refuse. Also, be wary if the call comes from an unfamiliar number or if the caller is trying to create a sense of pressure.

To protect yourself from telephone fraud, follow these simple guidelines. Never give out personal information, such as your card number or passport details, over the phone. If you suspect a call may be fraudulent, hang up and call the organization making the call back. Use official numbers posted on the company's website. It's also a good idea to install apps on your phone that help identify and block unwanted calls.

Be alert to any suspicious calls and don't hesitate to report them to law enforcement. Education and awareness are key in combating telephone fraud.

Investigation is an important process in the banking industry, where an institution requires confirmation of the legitimacy of financial transactions. The bank may request evidence confirming that the transaction was initiated by the account holder. Depending on the specific circumstances, the client may be required to provide various documents. These may include contracts with counterparties, property purchase and sale agreements, invoices, or correspondence with the recipient of funds. Compliance with these requirements promotes the transparency of financial transactions and helps prevent fraud.

The client can send evidence via chat in the banking app or provide it in person at the nearest bank branch.

The bank can initiate a request not only for current transactions but also for completed transactions. This may occur if the client, for example, begins regularly transferring funds from their corporate account abroad, frequently withdrawing cash, or exceeding the limits set by the bank. Such measures are aimed at preventing fraud and complying with financial regulations.

The bank's decision on the transaction. Once the client provides all the necessary documents and confirms the legality and validity of their transaction, the bank makes a decision to proceed with it. Processing time can vary from several hours to several days, depending on the speed of the client's response to the bank's requests.

Certain restrictions may be imposed during the transaction verification period. For example, the bank may require the company director to personally attend the branch to process transactions on the current account, including settlements with counterparties. Only essential transactions, such as employee payroll, office rent, tax payments, and other mandatory payments, may also be permitted. These measures are aimed at ensuring the transparency of financial transactions and compliance with the law.

What to do if your account is blocked

If a client fails to respond to a request for information about the nature of a transaction for a long time, or if the transaction raises suspicions of illegality, the bank has the right to block remote access to the account and terminate the agreement with the client. Such measures are aimed at protecting the bank's financial interests and preventing fraudulent activities.

To unblock remote access to your account, you must contact the bank and provide proof of the legitimacy of all payments and transfers. The best option is to visit the office in person, where you can present documents such as contracts. This is usually enough for the bank to conduct an investigation and decide whether to restore access.

How to avoid account blocking

There are several effective recommendations that can help minimize the risk of account verification or remote access blocking. First of all, it is important to regularly update passwords and use complex character combinations to protect your account. It is also worth enabling two-factor authentication, which will add an additional layer of protection. It is necessary to closely monitor your financial transactions and promptly respond to any suspicious transactions. In addition, avoid using public Wi-Fi networks to access banking services, as this increases the risk of cyberattacks. Keep software and antivirus programs on your devices up-to-date to protect them from malware. By following these simple rules, you can significantly reduce the likelihood of problems with your account.

Proper execution of routine payment transactions is of great importance for individual entrepreneurs and legal entities. It's important to pay salaries, contractors, and rent on time. If a client regularly fails to pay their invoices through bank transfers and prefers to withdraw cash, this may raise suspicions from the bank. In such cases, it's recommended to maintain transparent financial records and use non-cash payments to reduce risks and increase trust with financial institutions.

Indicate the purpose of payments for individuals, such as "loan" or "birthday gift." If you are lending someone a significant amount, it is recommended to enter into a loan agreement and have it notarized. This will help avoid misunderstandings and protect your interests in the event of a dispute. Properly formalizing financial relations will provide legal protection for both parties and guarantee the return of funds.

It is important to verify the counterparties with whom you do business. This verification can be performed through various official resources, such as the Central Bank of the Russian Federation's "Know Your Customer" platform, as well as the websites of the Federal Bailiff Service (FSSP) and the Federal Tax Service (FTS). These tools will help ensure the reliability and integrity of your partners, which reduces business risks and facilitates successful cooperation.

It is possible that a company operates legally but is collaborating with an unreliable contractor. In such cases, the bank has the right to initiate an account audit to ensure that the organization is not involved in illegal activities within its supply chain. This helps avoid the risks of money laundering and other financial crimes by ensuring the security of financial transactions.

The main thing about blocking an account under Federal Law 115 in 4 points

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