Financial monitoring has blocked the current account - what to do?

What does it mean

If the current account is blocked, then the activities of the entire enterprise are actually suspended. The owner will not be able to pay the debt, buy goods, pay employees salaries or fulfill other financial obligations. To avoid such a development of events, you need to understand ways to find out whether an organization’s current account is blocked, why this was done, and also how to remove the restrictions.

First, account holders must distinguish between the different types of restrictions that may be imposed by a banking organization. These include:

Complete blocking.
Suspension of a specific operation.
Refusal to implement a certain financial transaction.

Blocking deprives the owner of the ability to make any payments, withdraw funds, pay for goods and services, or transfer funds to another account. This person is not allowed to create other accounts, as well as open deposits in banks.

Blocking of the account and refusal to carry out transactions on the account

First of all, you should understand the difference in blocking an account and refusing to carry out transactions; these are two completely different procedures.

Types of sanctions:

Refusal to perform the operation. The most common type of restriction is the blocking of account transactions by the bank in accordance with Law 115-FZ of 08/07/2001. The reasons for this are:

failure to provide documents confirming the “purity” of the transaction;
the bank suspects that the operation is being carried out to launder income or for the purpose of financing terrorism.

Account blocking. The account may be blocked (account transactions) if the account owner was included in the list of companies and individuals who took part in terrorist or extremist activities. Such a list is posted on the website of the Federal Financial Monitoring Service. Otherwise, complete blocking of the account is possible only by Rosfinmonitoring or the court. Blocking by Rosfinmonitoring is possible for a period of no more than 30 days only if the account owner is related to terrorist or extremist activities. For a longer period of time, account blocking is possible only by court decision. Any disputes with the bank in this case are pointless; it will not be able to make decisions in this matter. To resolve this issue, you will need to contact the Rosfinmonitoring branch, and also find out what exactly the company is accused of.

Suspension or complete blocking

Financial monitoring of a bank may block an account if Rosfinmonitoring suspects the account owner of promoting terrorism through its financing or laundering income obtained in violation of the law. In this case, the owner is included in a special list of organizations and individuals, which is publicly available on the Internet.

Such blocking cannot last more than one month. This is stated in the Law “On Combating the Legalization (Laundering) of Proceeds from Crime and the Financing of Terrorism” No. 115-FZ, in particular in paragraph. 3 tbsp. 8. The blocking period may be extended by court decision. If such a fact occurs in the absence of an appropriate document, then this is a direct violation of the law.

If an organization is not on the list, funds may be frozen or a certain financial transaction may be suspended until the circumstances are clarified. If financial monitoring blocked the current account of the LLC in this case, then such an action is illegal.

About informing about the reasons for refusal

Can Rosfinmonitoring inform a client about why the bank refused to provide him with service?

No, the RFA is not vested with such powers. Law 115-FZ assigns the obligation to inform the client to banks. They must report the termination of the account, the refusal to execute an order or enter into an account (deposit) agreement, as well as the reasons for this (Article 4 of the law). The procedure for providing information to clients is regulated by the bank’s internal documents.

How to check if there is a blockage

To check your account, just try to make any payment or call the financial institution's hotline. But this information can only be provided to the account owner. This data is not disclosed to third parties.

However, on the official virtual resource of the Federal Tax Service there is a service “Bankinform”. Third parties can also use it. Having found this section, you need to select the type of verification, indicate the TIN of the legal entity and the BIC of the banking organization, and also enter the anti-spam security code. As a result, the following information will be obtained:

Account blocking date.
Amount of debt.
Reasons for blocking.

Reasons for blocking your current account by the bank

Any problem can be considered in a local and broader, wider aspect. In a narrow sense, you yourself can cause the suspension of operations on your account through your actions. On the other hand, global processes are currently taking place in the banking sector, which explain the sometimes excessively harsh measures of a credit institution towards you.

Local aspect of the problem: claims against your business

In most cases, blocking of your current account occurs at the initiative of the tax service, and banks are obliged to unquestioningly carry out its will. Most often, a directive is issued if a bank client delays paying taxes, submitting financial statements, or is suspected of illegal actions.

At the same time, there are often cases when the initiator of account blocking is not an external body, but the bank itself - through its special financial monitoring service. When making decisions to suspend operations on a client’s account, your bank, like all others, is guided by the following documents:

Tax Code of the Russian Federation, Article 76 (on suspension of transactions on bank accounts);
Federal Law 115 (on combating money laundering and terrorist financing);
Letter from the Central Bank of Russia (methodological recommendations on increasing the attention of credit institutions to individual customer transactions).

All transactions carried out by the client on the account are carefully monitored by financial monitoring for compliance with these standards. If something seems suspicious to the bank, it can, on its own initiative, impose sanctions in the form of blocking the account of an individual entrepreneur or LLC. Financial monitoring can do this for the following reasons:

The bank has suspected that your company is headed by a nominee director who actually has no authority . For example, the service may discover that several organizations are headed by the same person. Denominations are illegal (Article 173 of the Criminal Code), so the bank has the right to demand an explanation;

You made a questionable transaction on your account . For example, if the bank finds discrepancies with supporting documents, or there are no such documents at all. Questions may be raised by a payment that does not comply with the organization’s OKVED codes;

Changes to the company's constituent documents without notifying your bank . When inconsistent data enters the bank’s database, it blocks the account until the circumstances are clarified. Thus, any changes to the company’s Charter must be brought to the attention of your credit institution;

False address of a legal entity . Audits are carried out not only by the tax office, but also by banks. If the company cannot be found at the specified address, the account will be blocked immediately;

Payments to the tax office are less than 0.5% of turnover . According to the recommendations of the Central Bank, such client behavior seems suspicious. Clients who withdraw money from a current account and pay taxes from a personal card may face blocking. The problem is that the bank does not analyze your method of paying taxes, although in this situation you are acting legally;

Frequent cash withdrawals from your current account . This is one of the red flags of money laundering, although the client may not break the law by paying taxes through a personal card or terminals;

Inaccurate description of the purpose of payment . Even when paying through your personal account, the bank monitors where the money from the current account is spent. If the same phrase appears on the payment slip over and over again, the bank may find it suspicious;

Suspicious counterparty . By law, the bank is obliged to monitor not only you as a client, but also your counterparties. If you are an honest entrepreneur, but received a payment from a blacklisted person, your account may be blocked. The rule here is “tell me who your friend is, and I’ll tell you who you are”;

Court decision to suspend operations on the account of an owner under investigation.

In practice, most of the blocking could have been avoided if banks had taken steps forward, called in case of unclear transactions and found out - that is, if they had worked proactively. Although for many such a service remains, as they say, “from the realm of fantasy.”

What to do if your current account is blocked, how to unblock it?

To unblock your account, you need to actively act, even if you consider yourself innocent of anything. For individual entrepreneurs and LLCs, the same scheme applies to what to do if the account is blocked. You will know right away that you cannot use it - the first time you try to make a payment in the Internet bank, a notification about the suspension of payment transactions will appear. At the bank itself, the operator will notify you. So, take the following steps:

Find out the initiator of the blocking . If the initiator is the tax office, in practice the bank cannot always explain in detail how to unblock the account, because it only knows what it received as a directive from the Federal Tax Service. Then you are forced to go there and find out the reasons for the blocking on the spot. If it was the bank that imposed the ban, it is obliged to provide you with complete information upon calling about the reasons and the documents that you must provide to it in order to “whiten” your reputation.

Apply to your bank . Let's assume they explained to you over the phone what the reason for the blocking was. Do not rely on words - if the clarification drags on, you should still have the document in your hands. Contact the bank with a written statement asking them to explain the reason for the suspension of debit transactions. You should have a second copy of your application with the bank’s note that it has been accepted for consideration, containing the date the application was accepted. The bank has only two business days to respond.

Bring all missing documents requested by the bank . If you run a transparent business, often the freezing of an account is due to a misunderstanding. On thematic forums on the Internet you can find many customer reviews about how the accounts worked again after two to three hours. Perhaps things aren't so bad for you either. The main thing is to act immediately.

File a complaint with the Central Bank of the Russian Federation . If within two days your bank does not respond to your application, you need to send an application outlining what is happening to the Central Bank of the Russian Federation (by regular mail, through the Internet reception of the Bank of Russia). You can also call the hotline. The application will be processed immediately and you will be notified of the decision.

If the reason for blocking is a court decision, you need to fulfill its requirements (repaying the debt, paying a fine, etc.).

If the blocking is caused by a violation of paragraph 115 of the law on legalization, it is necessary to collect a complete package of documents confirming the legality of the transactions . This list varies depending on the specific situation (agreements, contracts, wills, etc.).

Main reasons for blocking

Banks must supervise transactions carried out by organizations if their amount exceeds RUB 600,000. or is the equivalent amount in foreign currency. This is stated in Art. 6 of the above Law No. 115-FZ. In this case, financial monitoring is carried out in relation to such operations as:

Receiving money into your account and cashing it out.
Transfer to foreign bank accounts or receipt of money from them.
Crediting or debiting funds to a company that has been operating for less than 3 months.
Opening deposits and crediting funds to them.

According to Art. 7 of Law No. 115-FZ, banks must identify and analyze data on the movement of funds in client accounts in order to highlight transactions that seem dubious. Thus, financial organizations must record the following cases:

Convoluted deals that make no economic sense.
Transactions that do not correspond to the purposes provided for by the charter.
Operations whose purpose may be to evade inspections.
Refusals of account holders to perform transactions in respect of which bank employees have suspicions of money laundering.

Knowing whether a bank can block a current account and on what grounds, the organization will take a more responsible approach to financial transactions. If they meet at least one of the criteria specified above, then the banking organization may request documents from the account owner that will confirm the legality of its implementation. In the absence of such, blocking is inevitable.

About the suspension of transactions

Can Rosfinmonitoring suspend the operation?

Yes maybe. The service is authorized to do this by Article 8 of Law 115-FZ. The order is:

The bank blocks the transaction for the above reasons for 5 days and transfers the information to the RFM.
The service conducts a preliminary inspection, and if the grounds for blocking are confirmed, it decides to suspend operations for up to 30 days.
If the period for which the bank blocked the operation comes to an end, and there is no decision of the RFA on suspension, then the operation is carried out.

Additional reasons

There are additional criteria that banks must pay attention to. For example, the methodological recommendations of the Central Bank of the Russian Federation No. 18-MR indicate that banking organizations should pay attention to the following clients:

Which inflate the amount of payments to 0.9% of turnover and higher.
Which do not pay salaries to employees or the money paid does not correspond to the available number.
Which create a wage fund for workers based on the amount of earnings less than the subsistence level established in the region.
They pay personal income tax, but do not pay insurance premiums.
They do not have funds in the account or their amount does not correspond to the purposes of accrual.
The turnover of funds has sharply increased significantly.
They did not pay for stationery and other household goods, and did not pay current payments.
VAT was allocated in invoices for the purchase of goods that are not subject to this tax.

Who can the bank block and for what reasons?

Analysis and monitoring of financial transactions is carried out according to the criteria established by the Central Bank, listed in Regulation No. 375-P (2012). According to this Regulation, any operation that suggests:

illegal cash withdrawal (withdrawal of a large amount of cash from a card/account if it was credited by bank transfer);
confusing cash settlement schemes (“transit” operations);
concealing the true purposes of financial transactions and parties to the transaction;
illegal transfer of large sums abroad;
extremist activities;
terrorism, etc.

The Federal Financial Monitoring Service (Rosfinmonitoring) includes bank clients in a special list of individuals and legal entities involved in extremist activities and/or terrorism. But you don’t have to be an extremist or terrorist to be among those clients whose card or account was blocked by Sberbank, citing 115-FZ. There are many cases where relatives regularly transferred small amounts to their loved ones on a card and their cards were blocked.

Blocking is also possible when a person does not want to take a large amount of cash with him when going on a trip, but deposits this money into a bank account and cashes it out upon arrival at the destination. The banking financial monitoring system can identify such transactions as an attempt to legalize illegally obtained income. Moreover, in this case, it does not matter that the bank has complete information that the same person topped up the card balance and cashed out funds from the account. Only the fact of withdrawing a large amount from the card account is taken into account.

Important! Reviews from Sberbank clients indicate that the bank can block a card both in the case of regular financial transactions on the card and in a one-time transaction with a large sum of money.

The bank requested documents

What to do if financial monitoring has blocked your current account:

The reasons need to be found out first.
Next, you should provide the bank with the required documents. The law does not establish information that must be verified. Therefore, banks can request the information they deem necessary. Most often, this includes: payment documents, contracts, payment of taxes, legal sources of funds, and other supporting information.

If, after the account owner has provided the necessary documents and the withdrawal of money is refused, such actions can be appealed as follows:

At the Central Bank.
In a court.

How does the bank verify customer transactions?

The Central Bank monitors the work of banks and gives them instructions on how to verify clients. He developed recommendations dated July 21, 2017 No. 18-MR and No. 19-MR, which are based on the requirements of Law No. 115-FZ “On Legalization and Anti-Corruption.” Guided by these instructions, a special department of the bank, financial monitoring, recognizes suspicious transactions and unreliable clients. This unit will check:

whether the bank client conducts real activities,
do account transactions make economic sense,
who actually manages the account: a director or a figurehead.

If the financial monitoring department suspects a client of cashing out, it may suspend banking services or refuse cooperation altogether, and then blacklist the company. The bank will report all suspicious transactions, regardless of the amount, to Rosfinmonitoring.

If the company’s payment exceeds 600 thousand rubles, financial monitoring will definitely check the operation. Some companies, knowing this rule, begin to split large payments and transfer amounts less than 600 thousand, and this further attracts the bank’s attention to their operations. If you need to transfer two million to a counterparty, it is better to do it in one payment, and if the bank is interested, then provide it with documents on the transaction.

Challenging a blocking decision

According to paragraph 3 of Art. 845 of the Civil Code, the bank does not have the right to establish restrictions on the use of the account unless this is provided for by law. He also does not have the right to use funds for his own purposes. It is the provisions of this article that should be followed when drawing up a claim or complaint.

In addition, according to Art. 849 of the Civil Code of the Russian Federation, the bank is obliged to implement a client’s order to issue money within the next day after receiving it. If the client proves that his actions are lawful, the bank refusal is considered illegal.

Based on paragraph 1 of Art. 395 of the Civil Code, the court can not only oblige a banking institution to transfer funds that belong to the account owner, but also charge a percentage for their use.

If the blocking is initiated by the tax service

A banking organization can not only independently block a current account based on financial monitoring, but also perform the same actions at the request of the tax authority. The reasons for freezing the account of a banking organization at the request of the Federal Tax Service are provided for in clause 3 of Art. 76 Tax Code of the Russian Federation. These include the following:

Failure to submit a tax return within the deadlines established by law.
Having debt in the form of taxes, fines or penalties.
Failure to provide a calculation of the tax for individuals, which is withheld from employees.
Failure to comply with the conditions imposed by the tax service.

The Federal Tax Service is obliged to notify the owner of the decision to block the account. If the notice is not delivered, the account status can be checked by contacting the tax service or using the above-mentioned BANKINFORM service.

Federal Law-115 “On combating money laundering”

This legal act was adopted back in 2001, but only in the last few years have citizens of the Russian Federation felt its effects when, for no apparent reason, banks began to block their accounts and plastic cards. This is due to the fact that since the adoption of the law, amendments and additions have been made to it, which vested banking institutions with broader powers.

But this is not the only thing that has led to an increase in blocking cases. More and more citizens prefer cashless banking and are increasingly beginning to use banking products and services. They receive wages, stipends, social assistance, pensions on bank cards, use them to pay for goods in stores, cafes, on the Internet, pay for the services of providers, utilities, etc. All this movement of funds is recorded by the bank and in the event of suspicious activity or turnover of large amounts in the account, the bank may, on the basis of 115 Federal Laws, refuse service to the client and apply appropriate sanctions:

prohibit opening new accounts, replenishing deposits, issuing and receiving plastic cards, re-issuing old cards;
block all existing cards and current accounts of the client;
block access to remote customer self-service services (Sberbank Online, mobile bank, application, etc.);
completely disconnect from the banking system;
leave the opportunity for the client to make financial transactions on blocked cards and accounts through the operating cash desk, and if we are talking about large sums, then this must be done after each transaction has been agreed upon with the bank.

Attention! If Sberbank has blocked a current account on the basis of Federal Law No. 115, then the account owner may experience certain difficulties when opening accounts in other banking institutions.

Along with the expansion of the powers of banks as a result of amendments to 115-FZ, the degree of their responsibility also increases. Therefore, they are increasingly picky about clients and check the sources of income and other receipts to the account/card for their legitimacy. For violation or evasion of compliance with the norms of this legislative act, banking institutions risk losing their license. Only in the last couple of years has this become the most common reason for the cessation of activities by banking and financial institutions.

Federal Law No. 115 “On Combating Money Laundering” pursues the only goal - to prevent and impede the financing of terrorism and the legalization of “black” income by all possible and impossible means. This legal act clearly defines the responsibilities of institutions working with financial assets, funds and property of citizens, as well as the degree of their responsibility for evading these responsibilities. The Law includes not only banks and financial and credit organizations as such institutions, but also insurance, microfinance companies, etc.

115-FZ states that each such institution is obliged to conduct financial monitoring and analyze all financial transactions (receipts, transfers, payments and other transactions) of its clients and analyze them in order to detect dubious or suspicious monetary transactions.

Expert opinion

Anastasia Yakovleva

Bank loan officer

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Unlock

If, at the initiative of the tax service, financial monitoring blocked the current account, what should I do? The bank will not be able to help in this case. Therefore, you need to contact the tax service. If there is an error, you must provide documents that confirm the relevant fact. Evidence for this may include:

Receipts and payments.
Notes on acceptance of documents, postal notifications.
Reconciliation acts.

If it becomes known that financial monitoring has rightfully blocked a current account, what should I do? The only way out of the situation is to eliminate the identified violation. After completing the necessary actions, the inspector should provide supporting documents.

Unblocking is carried out in the following periods:

Within one business day after payment of fines and arrears (if a corresponding bank statement is provided). This is stated in paragraph 8 of Art. 76 Tax Code of the Russian Federation.
Within one working day after providing documents on sending the declaration or reporting. This is stated in paragraphs. 1 clause 3.1 art. 76 Tax Code of the Russian Federation.
Within one working day after submitting the necessary documents to the tax service. This is also stated in paragraphs. 1 clause 3.1 art. 76 Tax Code of the Russian Federation.

At the same time, in practice, unblocking can be carried out in a few days if the debt has been paid, and in some cases it can take up to 1 month. In this case, the bank reviews the documents in accordance with internal rules.

What to do if your current account is blocked by mistake

If, as a result of the bank's analysis of clients' financial transactions, suspicious transactions have been identified, the cardholder or account holder is notified. This happens as follows:

The bank sends a message (SMS or email) about the upcoming blocking of cards and accounts.
The client receives a request to provide the bank with information (information) about the legitimacy of the origin of funds involved in financial transactions with a card or account, as well as documentary evidence of the economic meaning of such transactions.
After submitting documents confirming the legality of financial transactions, the bank sends the client a notification about the fact of receipt of the papers and the timing of their consideration.
After an investigation and verification of the provided data, an appropriate decision is made, of which the cardholder is notified personally.

As a result of the check, the client must be informed when their access to accounts and remote servicing services will be unblocked and whether this will be done at all. There are often cases when a bank blocks a card without good reason or by mistake. If your current account with Sberbank has been blocked by mistake and you don’t know what to do, you need to contact the bank to clarify the situation.

Attention! If the information provided by the client is not enough to establish the legal origin of the amounts in the accounts, the bank can send a corresponding request to the branch at the place of registration (location) of the client where he opened an account, received a card, etc.

To restore access to accounts and self-service services, you must provide the bank with documentary evidence that all income (receipts on the card) are absolutely legal and expenses are justified. Then the accounts and cards must be unblocked and access to the Sberbank Online service restored. Bank employees resolve such issues on an individual basis, taking into account all the features of each specific case.

Important! If Sberbank blocks access to accounts or cards twice during one reporting year, the client is completely denied banking services and his account is closed.

The bank can also refuse service and block the card if it has identified some questionable transactions on the card/accounts, requested documents, and the client simply ignored this requirement. In this case, you just need to do what the banking institution asks for and wait until the documents are reviewed and a decision is made on them. If the bank’s decision for some unknown reason was negative and the account was not unblocked, the client can only wait a while and try again to prove the legality of his transactions and restore access to accounts and cards. The bank admits this possibility and may reconsider the case a little later.

When the bank notifies the client about the need to confirm the legitimacy of receipts on the card and about the possible blocking of accounts, it must inform how these documents must be submitted. It is better to follow the instructions of the banking institution to avoid possible difficulties and delays in the delivery and processing of papers.

The bank may request documents:

by mail;
scanned to email;
hand over personally to an authorized employee of the nearest bank branch.

Regardless of the method of document delivery, it is necessary to take into account that:

in an email with scanned documents, you must indicate your full name in the “Subject” column, and the size of the letter itself should not exceed 12 MB and it is better that all scanned copies are in PDF format;
when sending documents by registered mail by regular mail, delivery times must be taken into account, since letters often reach the addressee with a significant delay, and the bank, having not received the required documents within the prescribed period, may make a decision completely unfavorable to the client;
If you are unable to provide the bank with documentary evidence of the legality of your sources of income on time, you should notify the banking institution in the manner specified in the notification and justify the reasons.

Neither the law nor the Sberbank regulations have a clear list of documents that can confirm the legality of financial transactions and the economic meaning of transactions, because sources of profit and expense items can be very diverse. It can be:

various agreements - contract, lease, purchase and sale, etc.;
accounts;
invoices;
receipts;
calculation sheets;
tax documents;
bank statements (for cards and accounts of other banking institutions) and so on.

Attention! In some situations, Sberbank blocks cards based on information received from Rosfinmonitoring that its client is suspected of extremist/terrorist activities.

Until the client is removed from the list of persons suspected of terrorism or extremist acts, he will be able to manage his funds in blocked accounts. But he will be able to do this only in the form and amount discussed in 115-FZ (clause 2.4 of article 6 and clause 4 of article 7.4).

Poll: are you satisfied with the quality of services provided by Sberbank in general?

Not really

The grounds for including individuals and entrepreneurs in this list are listed in Article 6 (clause 2.1) of the same legislative act. If the client is convinced that he was included in this “black list” by mistake and by accident, he can rectify the situation by sending a corresponding application to Rosfinmonitoring.

Full or partial unlocking

Sometimes the tax and federal financial monitoring service requests the banking organization to completely block the funds in the account. This can be done even if the account balance is much greater than the amount indicated in the decision to temporarily suspend the right to use the account. Then you need to submit an application to the tax service to partially lift the imposed restrictions. If the question is how to pay taxes if the current account is blocked, then it is resolved in the same way. The document is accompanied by a bank statement indicating the funds held in the account.

In accordance with paragraph 4 of Art. 76 of the Tax Code, the service must send to the bank a decision to remove the restriction from the account within one business day from the moment the corresponding decision is made. The procedure is expedited by sending the notification in electronic format. As a result, the company's operations return to normal.

If the deadlines for lifting restrictions are violated, the account owner has the right to receive compensation. In this case, a penalty is established based on the current refinancing rate.

About appealing the decision

The client was denied service, citing the provisions of Law 115-FZ. How can he appeal this decision?

A client who has been refused service may submit documents or information to the bank confirming that there are no grounds for refusal. The bank must review these documents within 10 working days. As a result, the client will be told:

that the basis for denial of service has been eliminated;
that it cannot be eliminated based on the documents and data provided.

If the above step does not help, the client has the right to contact the interdepartmental commission at the Bank of Russia . At the same time, he must submit documents in accordance with the Directive of the Central Bank dated March 30, 2018 No. 4760-U. The commission will consider these documents, as well as the bank’s reasoned justification for refusing service. As a result, a decision will be made:

about the absence of grounds according to which the bank decided to refuse service (decision in favor of the client);
about the absence of grounds for revising the decision made by the bank (decision in favor of the bank).

The rendered decision is communicated to the parties within 3 working days from the date of adoption. It is binding on the bank.

If the interdepartmental commission made a decision in favor of the client, then upon his subsequent application the bank will not be able to refuse to open an account or conduct a transaction.

In addition, the client always has the right to go to court.

Account blocking by court

It may also be that, based on a court decision, financial monitoring blocked the current account. What to do in this case? First of all, find out about the reasons for this action. After receiving a court decision, the bank must completely stop carrying out debit transactions, be it cash withdrawals or money transfers.

Usually the reason lies in the presence of a debt to counterparties, government agencies or other financial organizations, which the account owner does not pay voluntarily. This is an interim measure. Thanks to blocking, it becomes possible to satisfy the demands of creditors. The restriction is lifted after the execution of the court decision. If you do not do this yourself, the money will be written off forcibly in the course of enforcement proceedings in the case.

What payments will attract the bank's attention?

Firstly, transit operations. That is, the company receives money from one counterparty and immediately transfers it to another. The Central Bank believes that such transactions are a sign of money laundering.

But according to one criterion, the bank does not block the account, so it will pay attention to other payments to the company that confirm the reality of its existence: whether the client pays rent and utility bills from the account, whether he purchases office supplies, etc.

Secondly, banks control the volume of tax deductions. According to the instructions of the Central Bank, the company must pay taxes of at least 0.5% of the account turnover. The difficulty is that the account turnover and the tax base may not coincide. In this case, the company cannot adhere to the tax burden recommended by the Central Bank. But let us remind you that one criterion is not a reason to block a client’s account and refuse banking services.

Thirdly, payments must comply with the company’s declared OKVED. For example, the bank will pay attention to the discrepancy and take action if money is received for construction materials, but transferred for products. These activities are in no way related to each other.

Fourthly, payments to shell companies. These companies are used to illegally convert non-cash funds into cash. The Central Bank and the Federal Tax Service monitor the accounts of such companies and regularly enter their details into their electronic databases.

Fifthly, agency payments and payments under assignment agreements. Banks pay special attention to these transactions, since a number of tax evasion schemes are built on their basis. In addition, financial monitoring will pay attention to cash transactions, currency conversions, and the first operations of a newly opened company.