Step 1
Passport and liveness
The customer photographs the passport and goes through liveness — on the website, in the app or at the crypto ATM. The fields arrive in the form with no retyping, forgery and screen photos are flagged immediately.
KYC for cryptocurrency exchangers and crypto ATMs: passport, tax number and lists before the exchange
A digital currency exchanger has become a subject of 115‑FZ and a participant of the Bank of Russia register, and the tax number is a mandatory field of the purchase and sale contract. We recognise the passport with no manual entry, check the face and the document for forgery, find the tax number and check the customer against the Rosfinmonitoring lists and sanctions — on the website, in the app and at the crypto ATM. The decision on the deal stays with you.
Passport without entry Document anti-fraud Liveness INN by passport Watchlists and sanctions A corporate client by tax number
Russian software register No. 19972 · 152‑FZ
A digital currency exchanger under 282‑FZ and 115‑FZ: the register, the customer's tax number and accounts from 2027
Law No. 282‑FZ introduced the register of exchangers, and the accompanying Law No. 283‑FZ added them to the organisations that identify customers under 115‑FZ. Until 30 June 2027 it is possible to work without the register, but from 1 July 2027 residents exchange digital currency only with market participants.
From 1 September 2027 the exchanger checks before the deal that the wallet and the bank account belong to the customer themselves.
- Customer KYC
Who is considered an exchanger
282‑FZ, Art. 18, 44; Part 28 of Art. 55; Part 2 of Art. 56
Systematic exchange
- Two or more deals of purchase and sale of digital currency per month with a total volume of over 3.5 million ₽
- Deals for one's own account and not on organised trading
Requirements
- Only an organisation from the Bank of Russia register and a member of a self-regulatory organisation
- Own funds — no less than 15 million ₽
- The main and backup software and hardware systems are in Russia
Deadlines
- Until 30 June 2027 — work before inclusion in the register
- From 1 July 2027 — deals of residents only through market participants
- Rosfinmonitoring watchlists
The exchanger's customer under 115‑FZ
115‑FZ, Art. 5, 6, para. 1, 1.5-1 of Art. 7; 282‑FZ, Part 3 of Art. 31
Identification
- The exchanger is an organisation that identifies customers under 115‑FZ
- The customer's tax number is a mandatory field of the digital currency purchase and sale contract
- Identification may be entrusted under a contract to a bank, a digital depository, a broker or a trustee
Transaction control
- Purchase and sale of digital currency is on the list of transactions subject to mandatory control
- Internal control rules and a responsible employee — as for other subjects of 115‑FZ
Non-qualified investor
- Buys from the exchanger after a test and familiarisation with the risks
- The annual amount is within the limits set by the Bank of Russia
- Wallet check
Deal, wallet and account
282‑FZ, Part 3, 9, 12 of Art. 35; Art. 45; Part 3 of Art. 56; Part 1 of Art. 53
Digital analysis
- The currency and addresses are checked before the deal, and if that is not possible — no later than three business days
- The obligation and the responsibility lie with the exchanger
From 1 September 2027
- The wallet, bank account and electronic wallet for settlement belong to the customer
- The recipient is checked against the Bank of Russia database of transfers without consent
- If they do not match — the deal is refused
Register
- A repeated violation of Art. 6, 7, 7.3 and 7.5 of 115‑FZ within a year is a ground for exclusion from the register
Online exchanger, exchange office, crypto ATM network, OTC desk: whom to check and where
Checking a crypto exchanger's customer depends on where they pay: by card on the website, in cash at the cashier or at the terminal. The law is the same, but the check points differ.
-
Online exchanger
- The customer goes through KYC session on the website or in the app before the first order
- The card or account for settlement — in the same name as in the passport
- The address for crediting — admission rules in your system
-
Exchange office with a cashier
- The cashier photographs the passport, the customer goes through liveness on a tablet or phone
- Lists and sanctions — while the customer waits at the counter
- Cash is accepted after the decision of the responsible employee
-
Crypto ATM network
- Passport and liveness — on the terminal screen or via a link on the customer's phone
- The terminal is a device of an exchanger from the register, its systems are in Russia
- A repeated session when the amount is above your threshold
-
OTC desk and corporate customers
- A company — by tax number, the representative goes through their own session
- International screening with PEP for large deals
- Source of funds — the customer's questionnaire and documents in your system
-
Bank or broker with exchange
- Banks and brokers submit documents to the register of exchangers
- The customer is already identified — the tax number and lists are added for the deal
- Identification may be entrusted to a bank, a depository, a broker or a trustee
-
One-time customer, investor, company, non-resident: what to collect from an exchanger's customer before the deal
The exchanger sees the customer once, but is responsible for the deal as a subject of 115‑FZ. The set of data depends on who has come and what they are buying or selling.
-
One-time customer
Passport, tax number and face — in one session with no manual entry.
Watchlists and sanctions — before the deal, even if the customer has come only once. -
A non-qualified investor buys currency
Before purchase — a test, familiarisation with the risks and an annual amount within the limits set by the Bank of Russia.
Identity is confirmed by the KYC session; the test and the amount are handled by your system. -
The customer sells currency for roubles
The account or card for the payout — in the customer's name: the name from the passport arrives in the form.
The address the currency came from, and the rules for its admission — in your system. -
A company or sole trader
A company — by tax number: status, director, founders.
Representative goes through their own KYC session, the authority under a power of attorney is confirmed by your employee. -
Non-resident
Foreign national's passport from 195+ countries and territories, sanctions and international screening with PEP.
Deal restrictions — under the rules of the Bank of Russia and currency control. -
A customer identified by a partner
A bank, a depository or a broker carry out identification under a contract with the exchanger.
The procedure for passing the result to the exchanger — under your contract with the partner.
Checking a crypto exchanger's customer: three steps from the passport to sending the currency
The customer goes through the widget on the website, in the app or via a link on the phone, the rest goes through the API. A session with liveness takes from seconds to a minute.
Step 2
Tax number, lists and sanctions
From the passport data the tax number is found for the purchase and sale contract, the customer is checked against the list of terrorists and extremists, the register of foreign agents and sanctions lists; a non-resident — against international screening with PEP.
Step 3
The decision in your system
The results arrive in JSON by the session identifier. Your system compares the name of the card or account holder, applies the address admission rules and carries out the deal or sends the customer to manual review.
Drops, other people's cards and deceived customers: why an exchanger needs a live person before every deal
An exchanger is a gateway between roubles and digital currency
It is through them that other people's money is tried first of all. Every scheme begins with the wrong person in front of the camera.
- 01
A drop with someone else's passport
The deal is made out on a bought or lost passport. The validity of the passport against the Ministry of Internal Affairs database and document anti-fraud — before the deal, liveness shows that the person in front of the camera is not the document owner.
- 02
Payment from a third party's card
Roubles arrive from another person's card — most often it is the money of a fraud victim. The name from the passport arrives in the form, and your system compares it with the card holder.
- 03
A customer under dictation
A person deposits cash into a crypto ATM on the instructions of a “bank employee”. The session records who carried out the deal, and the check of the recipient against the Bank of Russia database of transfers without consent is in your system.
- 04
A mask and a deepfake at the terminal
The terminal camera is deceived with a photo, a video recording or a mask. Liveness tells a live person from a photo, a screen, a mask and a deepfake in the same session.
- 3.5 million ₽ per month — from this volume deals are considered exchange
- 100 000 ₽ per month — the limit for a customer from the database of transfers without consent
- 3 working days the deadline for digital analysis after a deal
Exchanger deal checklist: passport, tax number, lists, the customer's wallet and account
Four groups, eighteen lines. The tag shows who closes the line: our check, your system or the Bank of Russia rules.
- A Russian passport or a foreigner's document from 195+ countries and territories is recognised from a photo, the fields arrive in the form
- A screen photo, a printout, a pasted-in photo and editing in an editor — before the deal
- Validity of a Russian passport against the Ministry of Internal Affairs database
- The tax number from the passport — a mandatory field of the purchase and sale contract
- The form of the company and the representative, data on the beneficiary
- Liveness: a live person is in front of the camera, not a photo, a screen, a mask or a deepfake
- The face matches the photo in the document
- A repeated session at the terminal when the amount is above your threshold
- One passport — one customer profile, repeat visits are visible
- The list of terrorists and extremists and the foreign agents register
- OFAC, EU, UK and UN sanctions lists
- A non-resident and a large customer — international screening with PEP
- The test, familiarisation with the risks and the annual amount of a non-qualified investor
- Requirements for the internal control rules and the responsible employee
- The address for crediting or the source of the currency — admission rules before the deal
- Monitoring of the customer's transactions: splitting, transit, related customers
- The card, account and wallet belong to the customer; the recipient — against the database of transfers without consent
- Signs of deals made without the customer's voluntary consent
- NeuroVision — the line is closed by NeuroVision: document recognition, anti-fraud, liveness, tax number, lists, sanctions and international screening
- Your system — a line of your system: the form, the test, the amount, the check of the card and account, the rules for admitting addresses and transactions
- Bank of Russia — the rule is set by the Bank of Russia
Verification at a crypto ATM: how to check a customer at the terminal without a cashier
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Passport at the terminal
Risk. At the terminal there is no cashier to compare the photo in the passport with the person.
NeuroVision. The passport is photographed by the terminal camera, the fields arrive in the form, forgery and screen photos are flagged before cash is accepted. -
A live person at the camera
Risk. The terminal camera is easier to deceive with a photo or a video on a phone.
NeuroVision. Liveness tells a live person from a photo, a screen, a mask and a deepfake and compares the face with the photo in the passport. If the terminal camera is not suitable — the session link opens on the customer's phone. -
Lists while the customer waits
Risk. A customer from the Rosfinmonitoring list deposits cash and leaves with the currency.
NeuroVision. The tax number, lists and sanctions — from the passport data before the terminal accepts the money. -
Amount and wallet
Risk. A large amount is split into several deposits, the currency is withdrawn to someone else's address.
Your system. The threshold for a repeated session and the limits are set by you, and so are the rules for admitting the address for crediting.
A crypto ATM is a device of the exchanger: the customer at the terminal goes through the same KYC session as on the website. The decision on the deal is made by the exchanger.
Five ways to pass other people's money through an exchanger or a crypto ATM
A drop for a percentage
The deal is carried out by a front person
A student or a pensioner is hired to exchange other people's money in their own name. Lists, the wanted persons database and document anti-fraud show the risk before the first deal, and repeat visits on one passport are visible in your system.
A third party's card
The roubles do not come from the customer
Payment comes from a card whose holder does not match the passport. The name from the recognised passport is compared in your system with the card holder before the currency is issued.
Splitting the amount
Several small deals instead of one
A large amount is split into deposits at different terminals and by different people. A repeated session when your threshold is exceeded confirms that the deal is carried out by the same person, and the links between deposits are tracked by your system.
Someone else's face at the camera
A photo, a video or a mask
The terminal or the webcam is deceived with a printout, a video on a phone or a mask. Liveness tells a live person from a photo, a screen, a mask and a deepfake.
A person from the list through a relative
Watchlist and sanctions
A person from the Rosfinmonitoring list sends relatives to the exchanger. The relative is checked against lists and sanctions before the deal, and the links between customers are tracked by your system.
115-FZ
The customer is checked before the exchange
When to check an exchanger's customer again: a new wallet, a large amount, updated lists
A regular customer of the exchanger goes through KYC once, but the lists change, and wallets and cards change even more often. A repeat check is needed where the risk changes.
-
A new wallet or card
The customer asks to send the currency to a new address or to pay out roubles to a new card. Address admission and the check of the card holder's name are handled by your system, and in case of doubt the customer goes through a short repeated session.
-
An amount above your threshold
Before a large deal — a short session with liveness. This way the deal is not carried out by a person who has gained access to someone else's account.
-
List updates
Rosfinmonitoring and the sanctions authorities update their lists. The customers in your database are rechecked against the new versions, each check as a separate request, matches go to manual review.
-
A new passport or surname
The customer has changed the document. The new passport is recognised with no manual entry, the tax number and lists are checked again, and the customer data is updated.
Crypto exchanger customer checks: catalogue and prices
Each check is switched on separately — for the customer type, the amount and the exchange point. Payment is for completed requests. All database checks are in the catalogue AML checks.
Client
Passport without manual entry, anti-fraud and live presence.
- OCR · anti-fraud
Russian passport recognition
A Russian passport is recognised from a photo: the fields arrive as a JSON response to the platform.
from 16 ₽
Learn more - OCR · anti-fraud
Foreigners' documents: 195+ countries and territories
A foreign citizen's document is recognised from a photo; the name in Latin script is taken from the machine-readable zone.
from 16 ₽
Learn more - KYC
Liveness and face-to-document comparison
A check that a live person is in front of the camera, and a comparison of their face with the photo in the document.
from 29 ₽ per session
Learn more - Police · SMEV
Validity of a Russian passport
The authenticity and validity of a Russian passport through the interagency interaction system. It catches expired, replaced, lost and invalid documents and verifies that the passport was issued to this particular person.
5 ₽ / check
Learn more
Before the exchange
Watchlists and sanctions by full name and date of birth.
- Rosfinmonitoring
The list of terrorists and extremists
Screening against the list of people involved in extremist activity or terrorism. A mandatory check under 115-FZ.
5 ₽ / check
Learn more - OFAC · EU · UK · UN
International sanctions lists
Screening against the consolidated lists of OFAC (USA), the European Union, the United Kingdom and the UN. Every match carries a similarity score and a flag if it was triggered by an alias.
5 ₽ / check
Learn more - Ministry of Justice
The foreign agents register
A check against the Russian Ministry of Justice's foreign agents register. Its entries carry a date of birth and a tax number, so a match can be verified.
5 ₽ / check
Learn more - An international database
Compliance screening: PEP and sanctions
International screening against politically exposed persons and their associates, sanctions lists from more than 50 countries, regulatory actions and adverse media coverage. For Russian citizens it runs from the international passport or from the full name and date of birth.
36 ₽ / check
Learn more
Form and deal
Tax number, wanted persons and bankruptcy.
- Federal Tax Service
INN by passport
Determining the tax number from the passport data. It unlocks the checks that need precise identification of the person — with no namesakes.
5 ₽ / check
Learn more - Police
Police wanted list
A search of the federal database of people wanted by the police. Filtered by the full date of birth — results with no namesakes.
5 ₽ / check
Learn more - Federal Bailiffs Service
Enforcement proceedings
Active enforcement proceedings from the bailiffs' database: the amounts owed, the claimants, the type of recovery and an estimate of how close the person is to bankruptcy given their total debts.
5 ₽ / check
Learn more - Federal bankruptcy register
Personal bankruptcy
A search of the federal bankruptcy register: personal bankruptcy cases filed and completed. By tax number the result is unambiguous.
5 ₽ / check
Learn more
How much KYC of an exchanger's or crypto ATM's customer costs
The price is per one KYC session of one customer and for each database check. No subscription fee: the more checks per year, the lower the price.
- Calculate
Document
from 16 ₽ per session
A Russian passport or a foreigner's document with no manual entry, anti-fraud: photo of a screen, printout, pasted-in photo, editing. An additional document — 10 ₽.
-
Everything from “Document”, plus liveness, face-to-document comparison and deepfake detection. For online exchange and crypto ATMs.
- Build a set
Tax number, lists and sanctions
5 ₽ per check
Tax number from the passport, list of terrorists and extremists, foreign agents register, OFAC, EU, UK and UN sanctions. International screening — 36 ₽.
One session — one person: a company representative goes through their own. At 10 000 checks a year the “Document” session costs 18 ₽ per the calculator. Calculator on the pricing page.
Connecting to the exchanger: a widget on the website, a link for the cashier, a session at the crypto ATM
The check is built in where the customer exchanges money: in the order on the website, in the mobile app, in the cashier's account and in the terminal interface. The steps are switched on by scenario rules — passport and liveness at the first deal, repeated liveness at a large amount.
- Web SDK
- WebView
- Crypto ATM
- REST API
Test scenario in the personal account
Payment for completed checks, the data retention period is set in the scenario, support through a ticket system.
Why crypto exchangers and crypto ATM networks choose NeuroVision
An exchanger needs a provider that checks the customer in the same way on the website, at the counter and at the terminal — with payment for completed checks.
The customer, their tax number and lists — in one session at any exchange point
Passport recognition, liveness, tax number and list checks work on the same data. The form for the purchase and sale contract is assembled with no manual entry.
There is no need to assemble a solution from several vendors and reconcile their responses.
Crypto exchanger glossary: systematic exchange, digital analysis, account ownership
Briefly about the concepts found in the law and in the contract with an exchanger's customer.
- An organisation carrying out digital currency exchange
- A business company from the Bank of Russia register that systematically buys and sells digital currency for its own account and not on organised trading.
- Exchanger
- Systematic exchange
- Two or more deals per month with a total volume of over 3.5 million ₽.
- Systematic exchange
- Crypto ATM
- A terminal through which the customer buys or sells digital currency for cash; it is not named separately in the law and works as a device of the exchanger.
- Crypto ATM
- Digital analysis
- Checking digital currency and addresses for links to unlawful activity and assessing the risk of the deal — before the deal or no later than three business days.
- Blockchain analytics
- Identifier address
- A unique sequence of characters for recording digital currency — the wallet address.
- Wallet address
- Account ownership by the customer
- A check that the wallet, bank account or electronic wallet for settlement of the deal belongs to the customer themselves; mandatory from 1 September 2027.
- Account ownership
- A deal without voluntary consent
- A deal without the customer's consent or with consent obtained by deception or abuse of trust; information on such cases is collected by the Bank of Russia.
- Authorised push payment fraud
- Delegation of identification
- A contract under which an exchanger's customers are identified by a bank, a digital depository, a broker or a trustee.
- Reliance
- Non-qualified investor
- An investor who buys digital currency after a test and within the annual amount set by the Bank of Russia.
- Retail investor
- Liveness
- A check that a live person is in front of the camera, and not a photo, a screen, a mask or a deepfake.
- Liveness detection
Read also
Anti-fraud, sanctions, non-residents and transaction monitoring — in our blog.
369 10
Anti-Fraud, Liveness and Deepfake Protection
Anti-fraud: what it is and how to prevent online fraud
422 23
KYC, AML and Digital Identification
How Sanctions Screening, PEP Checks, and Risk Profiling Work After Customer Identification
367 30
KYC, AML and Digital Identification
KYC for international clients and non-residents in 2025: current requirements and application practice
166 16
KYC, AML and Digital Identification
KYT (Know Your Transaction): What It Is, How Transaction Monitoring Works, and Where the Travel Rule Fits In
Frequently asked questions about KYC for cryptocurrency exchangers and crypto ATMs
It is establishing the customer's identity and checking them against lists before the deal. From 1 September 2026 a digital currency exchanger is a subject of 115‑FZ: it identifies customers, checks them against the Rosfinmonitoring lists, obtains the tax number for the purchase and sale contract and controls transactions.
An organisation that systematically buys and sells digital currency for its own account and not on organised trading: two or more deals per month with a total volume of over 3.5 million ₽. Only an organisation from the Bank of Russia register with its own funds of at least 15 million ₽ may operate; until 30 June 2027 — until inclusion in the register.
Yes. For a digital currency purchase and sale contract the customer's tax number is among the mandatory data. NeuroVision finds the tax number from the passport data — RUB 5 per check.
The customer scans the passport and goes through liveness at the terminal camera or via a link on their own phone. Lists and sanctions are checked before the terminal accepts cash. The crypto ATM works as a device of the exchanger, the decision on the deal stays with the exchanger.
Before the deal the exchanger will check that the wallet, bank account and electronic wallet for settlement belong to the customer, and compare the recipient with the Bank of Russia database of transfers without consent. If the data do not match — the deal is refused.
Yes. Under a contract the exchanger may entrust identification to a bank, a digital depository, a broker or a trustee. Responsibility for the customer remains with the exchanger.
If a non-qualified resident investor buys — yes: a test, familiarisation with the risks and an annual amount within the limits set by the Bank of Russia. The test is run by your system, NeuroVision confirms that it is taken by the same person.
Liveness confirms that there is a live person in front of the camera and that the face matches the photo in the passport. It tells a live person from a printout, a screen, a mask and a deepfake. This way a deal will not be carried out on someone else's passport.
Checking a wallet address and transaction monitoring are separate tasks, they go beyond the customer's KYC. This page describes the check of a person: document, face, tax number, lists and sanctions; the rules for admitting addresses remain in your system. More details — on the page about AML checks of crypto wallets.
No. We check the customer and pass the results to your system. The decision on the deal, the refusal and reports to Rosfinmonitoring — are with your responsible employee.
The Web SDK works on the website, in a mobile browser, in the WebView of a mobile app and in the terminal browser; for server-side integration there is the REST API. A session link can also be sent to the customer.
Document with liveness — from RUB 29 per session, tax number and list checks — RUB 5 each, international screening — RUB 36. There is no subscription fee. The test — in the test scenario of the personal account.
We will select the checks for your exchanger or crypto ATM network
Tell us where customers exchange money and how many deals you carry out per month. We will build a KYC scenario under 115‑FZ and give you test access.
Can't put your request into words? Book a call and our team will contact you at a convenient time
Book a call
The company is included in the register of IT companies and the register of personal data operators of the Russian Ministry of Digital Development.
Address: Moscow, Presnenskaya Embankment 12 — Moscow City business centre, Federation Tower. Nearest metro stations: Delovoy Tsentr and Mezhdunarodnaya.
