Mining vs. Federal Law No. 115-FZ: How Miners Should Conduct Financial Monitoring
We’ve prepared a short checklist outlining the main measures that miners are required to implement under Russian anti-money laundering (AML) laws:
Develop Internal Control Rules: This is where you define how you will identify your clients and assign them to risk categories. It’s a crucial document that you can refer to in communications with state authorities.
Appoint a Compliance Officer: Designate a qualified individual responsible for ensuring compliance with AML legislation.
Identify Your Clients: Collect the minimum required information in accordance with your internal policies.
Record Suspicious Activities: Keep track of information that may indicate money laundering — such as complex or unusual transactions, or deals that don’t align with the declared business activities.
Report to Rosfinmonitoring: Notify the Federal Financial Monitoring Service (Rosfinmonitoring) of any suspicious client operations — and do not disclose this reporting to anyone.
Freeze Funds When Required: Take measures to freeze (block) funds if such action is required by law.
Maintain Records: Keep all documents and information obtained during financial monitoring for at least five years after your relationship with the client ends.
Respond to Requests: Provide information to Rosfinmonitoring upon request.
What happens if you ignore AML requirements? Non-compliance may lead to administrative penalties — including fines of up to 500,000 RUB or administrative suspension of business activities. Repeated violations may also result in a miner being removed from the Federal Tax Service registry. 📌 It’s crucial to structure your internal processes properly so that financial monitoring doesn’t drain your resources.
If you need a consultation or assistance with preparing the required documentation, feel free to contact us at info@cryptadvisor.ru.