Rosfinmonitoring has approved instructions for identifying beneficiary owners of clients. Instructions are valid for all market participants who are obliged to identify the beneficiaries of their clients, from banks to law firms.
Russian legislation has imposed for a long time a duty to identify beneficiaries, on a wide range of service providers, including real estate offices, notaries, attorneys and law firms, but until recently the procedure itself has not been regulated. Thus, the guidelines are step-by-step instructions for its implementation.
The instructions set the obligation of independent verification of the information provided by the client. The instructions also specify the obligation to notify Rosfinmonitoring in the event of any discrepancy between the client’s declaration and the outcome of the verification. Thus, any information that the client has reported about himself in the framework of the “Know your client” procedure is questioned, which is an extremely tough position compared to similar rules in other countries.
Thus, the client, applying for the provision of services in Russia to service providers obliged to identify the client and its beneficiaries, should clearly understand that the information that he has reported will most likely be rechecked. In case of inconsistency of data, the client will be denied a service, and information about the refusal will be submitted to Rosfinmonitoring with subsequent administrative and criminal risks.
You can read the Methodical Guidelines here.