Step 1
Compile a list of tax numbers
Suppliers, corporate clients, debtors, sellers — your system maintains the list. Split it into groups: each has its own set of checks, repeat interval and responsible person.
Counterparty monitoring
A pre-contract check shows a company as of a single day. To keep watching it for the whole relationship, the list of tax numbers is checked again — by an API request, at intervals that suit you: the director and founders go through the database checks once more, and the result is compared with the previous one. The “was → is now” comparison, alerts and the decision stay in your system and with your specialist.
Repeat check — by an API request Result by run number 152‑FZ
A counterparty changes after the contract: why monitoring is needed
Every change has a deadline
The law gives limited time to react — learning of a change six months later means missing it.
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A check is a snapshot on a date
Before the contract you checked the company: it is active, the director is clean, no court cases. A month later the director is different, after six months the tax service doubts the address, after a year the company is on the strike-off list. The old report knows nothing of this.
- 02
What changes most often
The head and members, address, status: reorganisation, liquidation, impending strike-off from the Unified State Register of Legal Entities. Less often, but at a higher cost — bankruptcy, account blocks, a large claim, inclusion in watchlists and sanctions. Each of these events is published in open registers, but nobody sends it to you.
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A repeat check instead of a manual round
You can re-check the whole database once a quarter and compare reports by hand. With NeuroVision, a repeat check is the same API request for the list of tax numbers: save the first response, run the second and compare. The schedule and comparison are set up in your system.
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The decision stays with you
The service does not decide whether to terminate a contract. It returns the check results, and your process takes over: a lawyer, compliance, the security service or the contract manager.
- 7 working days to update client information when in doubt (115‑FZ)
- 6 months an inaccuracy record before strike-off from the Unified State Register of Legal Entities
- 3 months for a creditor’s objections to the strike-off
Which counterparty changes are worth tracking
You need to watch both the company and the people who manage and own it. You choose the set of events yourself: one for a supplier paid in advance, another for a bank client.
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The company's status
The start of a reorganisation or liquidation, a tax service decision on an impending strike-off from the Unified State Register of Legal Entities, the strike-off itself. For a sole trader — cessation of business. The date of the decision matters so that you can file objections as a creditor in time.
- Learn more
The head and members
A change of director or management company, new members of an LLC, changes in shares. A new person is checked the same way as the previous one: nominee status, bankruptcy, commercial court cases, the Rosfinmonitoring list, sanctions, PEP — these NeuroVision checks are run by tax number or full name through an API request.
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Address and inaccuracy
A change of address, a mass registration address, an inaccuracy record on the address, members or director. After such a record the company has six months to remove it, otherwise the tax service may strike it off the register.
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Courts and bankruptcy
New commercial court cases where the counterparty is the claimant or defendant, a bankruptcy petition, the introduction of supervision. For the director and founders NeuroVision checks commercial court and bankruptcy cases by tax number, and an individual’s bankruptcy — through the federal bankruptcy register (EFRSB).
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Taxes and accounts
Suspension of account transactions, tax arrears, enforcement proceedings — the first signs that a counterparty may fail to pay or deliver. For the director and founders, account transaction blocks, tax arrears and bailiff proceedings are checked.
- Learn more
Sanctions and watchlists
The Rosfinmonitoring list, OFAC, EU, UK and UN sanctions lists, the foreign agents register, PEP — for the director and founders. Lists change, so a month-old result goes stale.
Three priority levels: which changes to react to immediately
A feed of “everything that changed” quickly becomes unreadable, so changes are best split by urgency: a stop factor, check today or take into account at the next review. The levels below are a guide for your process: you assign them yourself, in your own system.
- The company is being liquidated or has been struck off the Unified State Register of Legal Entities
- Supervision has been introduced or a bankruptcy petition has been filed
- The company or its owner is on the Rosfinmonitoring list
- A match with sanctions lists
- A new director or management company
- New members or a change in shares
- An inaccuracy record
- A decision on impending strike-off from the Unified State Register of Legal Entities
- A change of address without an inaccuracy mark
- A new commercial court case where the counterparty is the claimant
- A new enforcement proceeding for a small amount
- The new director is listed as head of many companies
- Bankruptcy of the director or founder
- A member or director is a politically exposed person
- Tax arrears or account blocks for the director
- The tags show the urgency level and the source of the event.
- Stop — halt payments and shipments until the responsible person decides; check — deal with it the same day; for information — take into account when reviewing the limit or contract.
- To find out who really owns a company, see the beneficial owners page. For PEP screening, see the PEP screening page.
How monitoring works: from a list of tax numbers to a decision
Six steps, of which two fall to people: compiling the list and deciding on a change. The rest is API requests and comparing responses.
Step 2
Choose the checks
For each group, mark what to check for the director and founders: bankruptcy, commercial court cases, taxes and blocks, nominee status, watchlists and sanctions. The set is passed in the API request.
Step 3
Record the baseline
The first check gives a starting point: who the director and founders are, what the results are for each. Save the response in your system — all subsequent ones are compared with it.
Step 4
Repeat the check on a schedule
Daily, weekly or monthly — you choose the frequency by the group’s risk. The request returns a run number (runId), and the result is obtained by polling every 5–10 seconds.
Step 5
Compare with the baseline
Your system matches the new response against the previous one: what was, what is now, when. If a new director or member appears, run the same checks for them.
Step 6
The decision and the log
The responsible person decides what to do: halt payments, request documents, leave as is. Save the decision and its date in the counterparty file in your system.
What a counterparty change looks like: was and is now
This is how a change card may look in your system when two API responses are compared: what was, what is now, when, which checks the new director passed and who made the decision. NeuroVision provides the results of each check run; your system stores the comparison and the decision. Data is processed under 152‑FZ.
115‑FZ, tax due diligence and the Unified State Register of Legal Entities: which deadlines monitoring helps you meet
Russian laws do not contain the words “continuous counterparty monitoring”. There are deadlines for updating information, a due diligence standard and rules for striking companies off the register — and each is easier to comply with when you learn of a change on time.
- Article on 115‑FZ
115‑FZ: updating client information
Banks, microfinance organisations, leasing companies, insurers, brokers and other organisations listed in Article 5
What the law requires
- Update information on the client, representatives, beneficiaries and beneficial owners at least once a year, and for low-risk clients once every three years
- When in doubt about the accuracy of information — update it within seven working days
- Assess risk not only when accepting a client but also during service (subparagraphs 3 and 3.1 of paragraph 1 of Article 7)
What regular checking gives
- A change of director or members, or an inaccuracy record, is visible at the next check — the seven-day countdown is not missed
- The results of each check with the run date are stored in your system — for internal control and Bank of Russia inspections
- Get test access
Tax Code: due diligence for the whole term of the contract
All companies that account for expenses and deductions on transactions with a counterparty
What the law requires
- Article 54.1 of the Tax Code does not impose a duty to check a counterparty, but it restricts deductions on transactions not performed by the stated counterparty
- In letter no. BV-4-7/3060@ the Federal Tax Service describes the standard of commercial due diligence: business reputation, solvency, ability to perform the contract
What regular checking gives
- It shows that the counterparty was checked not only on the day of signing but also while deliveries were under way
- Results with dates — in the transaction file next to the contract and primary documents
- Calculate the cost
129‑FZ: inaccuracy and strike-off from the Unified State Register of Legal Entities
For creditors, suppliers extending deferred payment and anyone to whom the counterparty owes money
What the law requires
- A company is given 30 days to respond to a notice of inaccurate information, after which the tax service makes the record (paragraphs 5–6 of Article 11)
- A company with no reporting or account transactions for 12 months, or with an inaccuracy record for more than six months, may be struck off the register by the tax service (Article 21.1)
- A creditor may file objections within three months of the decision’s publication — then the strike-off will not happen
What regular checking gives
- The sooner you learn of a decision on impending strike-off, the more time there is for objections and debt recovery
A one-off check, monitoring or due diligence: which to choose
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A one-off check — before the contract
The company and the people behind it, against registers; the decision is often automatic. Suited to admitting a supplier or seller.
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Monitoring — while the relationship lasts
The same checks, but repeated and only with a review of differences from the previous result. Suited to bank clients, suppliers paid in advance, debtors on deferred payment, marketplace sellers — everyone you work with for longer than a single transaction.
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Due diligence — before a large deal
More areas, PEP and publications, beneficial owners, company documents; conclusions are drawn by lawyers and auditors. After the deal the company can be put on regular checking.
These are not three different products but three modes of one platform: usually a check on entry, monitoring for the whole relationship, due diligence before a large deal. How to check a company manually is explained in the article on checking by tax number, and through the API, on the counterparty check page; for in-depth checks, see the due diligence page. Each repeat check is paid for as an ordinary run — under the price matrix.
Who needs counterparty monitoring
Anyone whose relationship with a company lasts longer than one payment: money in advance, goods on deferred payment, servicing a corporate client.
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Banks and MFIs
- Corporate clients and sole traders: updating information under 115‑FZ on time
- A change of beneficial owners and director — a reason to revisit the risk
- Solutions for banks
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Leasing and factoring
- Lessees and debtors for the whole term of the contract
- Bankruptcy, account blocks, impending strike-off
- Leasing and factoring
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Procurement and supply
- Suppliers paid in advance on a long contract
- A change of director and address before the next payment
- Supplier checks
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Distribution and wholesale
- Buyers on deferred payment with a credit limit
- Courts and enforcement proceedings — a signal to revisit the limit
- Objections to the strike-off of a debtor from the Unified State Register of Legal Entities
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Marketplaces and B2B platforms
- Corporate sellers before each payout
- Liquidation, sanctions and a change of the seller’s owner
- Solutions for marketplaces
How much counterparty monitoring costs
The price is made up of the checks you run: each repeat check is paid for like an ordinary one. No subscription fee for database checks and no annual licence.
Calculate the cost- 01
Checks of the head and founders — 5 ₽ per register. International screening: sanctions, PEP and publications — 36 ₽
- 02
A repeat check — the same run at the same prices: you set the frequency and schedule, and pay for the checks performed
- 03
Trial period of 1 month. A quote for your list of tax numbers and repeat frequency — on request
Connecting monitoring: the API and your accounting system
Terms
- A 1-month trial period
- A dedicated manager
- Payment for the checks performed
Counterparty monitoring glossary
Terms found in changes and the decision log.
- Counterparty monitoring
- Regular checking of the companies on your list and comparison with the previous result, so that you learn of changes in time.
- ongoing monitoring
- Baseline
- The data on a company and the people behind it at the time of the first check; later checks are compared with it.
- baseline
- Change
- The difference between a new result and the previous one: was, is now, date and urgency level under your process’s rules.
- alert
- Stop factor
- An event on which payments and shipments to the counterparty are halted until the responsible person decides.
- Inaccuracy record
- A mark in the Unified State Register of Legal Entities that the tax service doubts the address, members or director of a company (Article 11 of 129‑FZ).
- Impending strike-off from the Unified State Register of Legal Entities
- A tax service decision to strike off a dormant company; creditors may object within three months (Article 21.1 of 129‑FZ).
- Fedresurs
- The Unified Federal Register of Information on the Facts of Legal Entities’ Activity: liquidation, reorganisation, supervision, change of director and other events.
- Fedresurs
- Serial director
- A person listed as director or founder in many companies is a sign of nominee management.
- Commercial due diligence
- The standard of reasonable counterparty selection: reputation, solvency, ability to perform the contract (Federal Tax Service letter no. BV-4-7/3060@).
- due care
- Updating client information
- The duty of organisations listed in Article 5 of 115‑FZ to keep client data up to date within the set deadlines.
- CDD refresh
Read also
Counterparty checks, due diligence and 115‑FZ obligations — on our blog.
163 30
KYC, AML and Digital Identification
Due Diligence: What It Is and How to Vet a Counterparty
146 26
KYC, AML and Digital Identification
How to Vet a Company and Its Beneficial Owners Before a Deal: KYB in Simple Terms
114 29
KYC, AML and Digital Identification
115-FZ: What Businesses Are Required to Do and How to Meet the Law’s Requirements
418 20
KYC, AML and Digital Identification
AML, KYB, and Beneficiary Verification: How to Build Compliance for B2B Customers
166 30
KYC, AML and Digital Identification
Politically Exposed Person (PEP): Who It Is and What 115-FZ Requires
Questions about counterparty monitoring
It is regular checking of the companies you work with and comparison of the result with the previous one: director, members, address, status, courts, bankruptcy, sanctions. Unlike a one-off check, monitoring runs for the whole relationship and shows only what has changed. In NeuroVision a repeat check is an API request for your list of tax numbers; the schedule and comparison are handled by your system.
A check by tax number shows the company on the date of the request and is needed before the contract. Monitoring starts with the same check, then repeats it and compares the results. How to check a company manually is described in the article on checking by tax number; through the API, on the counterparty check page.
It depends on how often you run the repeat check: run it daily and you see a change within a day. The result of database checks is asynchronous: the request returns a run number, and the result is obtained by polling every 5–10 seconds. The registers themselves publish information with a delay: for example, an entry on a new director appears in the Unified State Register of Legal Entities after the tax service registers the change.
There is no direct obligation for everyone. Organisations listed in Article 5 of 115‑FZ update client information at least once a year (for low risk — once every three years), and when in doubt about its accuracy — within seven working days. For tax purposes, the Federal Tax Service describes the standard of commercial due diligence in letter no. BV-4-7/3060@.
If the company owes you money, as a creditor you can file objections to the strike-off with the tax service within three months of the decision’s publication. Then the company will not be struck off, and the debt can still be recovered. The period runs from the day of publication, so it is important to learn of the decision in time.
A new person is checked with the same set as the previous one: checks are run by tax number or full name — nominee status, bankruptcy, commercial court cases, the Rosfinmonitoring list, sanctions, PEP. The run is triggered by a request from your system when you see a change in the company information.
Each tax number goes in a separate request, so your system can send a list of any size one by one and split it into groups with their own checks and repeat intervals. Confirm request limits when connecting.
The check result is requested through the API, so your system or an integration partner can pass it to 1C, CRM or ERP. The schedule of repeat checks and the manager alert are set up on your side.
Repeat check results stored in your system record that you watched the counterparty for the whole term of the contract: what changes occurred, when you learned of them and what you decided. This is one piece of evidence of due diligence, but not a substitute for the contract, primary documents and verification of the signatory’s authority. More about documents is on the due diligence page.
Checks of the head and founders — 5 ₽ per register, international screening: sanctions, PEP and publications — 36 ₽ under the price matrix. Each repeat check is paid for as an ordinary run. A quote for your list of tax numbers and repeat frequency is available on request: leave a request and we will send a quote. Trial period — 1 month.
Let us discuss monitoring your counterparties
Tell us how many companies are on your list and which changes matter to you — we will open test access and send a quote.
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