The client's tax number and the director's passport
The tax number is entered in the web console or sent as a request from your system. The client uploads the representative's passport through a link — the document is read with no manual entry.
The data to identify a client under 115‑FZ before the contract is signed: the company by tax number, whether it is a shell company, whether the director is a nominee, and the director and shareholders against the Rosfinmonitoring watchlist and sanctions — in one request.
Data stored in Russia · Russian software registry no. 19972 · 115‑FZ and 152‑FZ
Accounting firms, sole-trader accountants and auditors are subjects of 115‑FZ under article 7.1. Below is when the duties arise and what they mean for every new client.
NeuroVision supplies the data for screening the client. The internal control rules, the decision whether to take the client on, freezing and reports to Rosfinmonitoring are set and carried out by your firm.
115‑FZ art. 7.1(1)(1) — transactions on behalf of or on the instructions of a client.
115‑FZ arts. 7 and 7.1 — identification, the watchlists and reporting.
115‑FZ arts. 7.1(1)(3) and 7.1(2.1); 222‑FZ — from 30.12.2024.
A new client has sent their details — before the contract you need to know who they are and to collect the data for the client file under 115‑FZ. These are the tasks NeuroVision takes on.
Status in the state registers, liquidation, the date of registration, account freezes ordered by the tax service, commercial court cases and debts to the budget — from a single tax number.
Most often enabled:
The director and shareholders by the tax numbers from the register, with no namesakes: nominee or serial director, links to other companies, bankruptcy.
Most often enabled:
The director, the shareholders and the client's representative are checked against the list of terrorists and extremists. The result, with the date of the check, can be filed with the client record.
Most often enabled:
The OFAC, EU, UK and UN lists; for foreign shareholders — PEP status, sanctions from 50+ countries and adverse media.
Most often enabled:
The passport of the director or the representative is read with no manual entry and checked against the police database and for signs of forgery and editing.
Most often enabled:
By tax number: bankruptcy, account freezes, tax arrears and professional income tax status. By passport — wanted lists and bailiff debts.
Most often enabled:
Before taking the client on: the company by tax number, the director and shareholders against the watchlist and sanctions, and the representative's passport. If the information cannot be established, the law requires you to refuse.
If a person from the watchlist turns up among your clients, you have no more than 24 hours from publication to freeze. A repeat check runs through the API on the client data you have stored.
Once a year, and once every three years for low-risk clients, and straight away when the director or the shareholders change: a repeat check by tax number shows what has changed.
The order of the checks is set by 115‑FZ and by your internal control rules.
NeuroVision supplies the data for every step.
The client's tax number is enough — there is no need to ask them for documents, the data comes from the registers. The representative's passport adds checks against the police database, wanted lists and debts.
Registered a month ago
A fresh registration, a director with a dozen companies, debts to the budget. A check by tax number shows the signs of a shell company before the service contract is signed.
One person signs, another decides
The register lists the director as a nominee or a mass director. An affiliation check shows which other companies they are linked to.
The tax service has suspended transactions
A tax service decision to freeze an account signals problems with filings or debts. The check shows the date, the number of the decision and the reason.
The company is clean, the people are not
A shareholder or the director is on the Rosfinmonitoring watchlist or on sanctions lists. Checking the people behind the company finds it in the same request.
The representative's document has been edited
The document is checked for forgery and traces of editing: fonts, fields and a photo of a screen. 40+ anti-fraud checks on the document.
115‑FZ
the client is screened before the contract
Every check is enabled separately and you pay for the requests performed. Descriptions, sources and response fields are in the API check catalogue.
A corporate client by tax number
Status, signs of a shell company, accounts and court cases.
A company is checked against the state register of legal entities and a sole trader against the register of sole traders: whether it is active, whether it is being wound up, when it was registered, and who the director and shareholders are.
Tax authority decisions suspending account operations: the date, the decision number and the reason for the freeze.
5 ₽ / check
Learn moreAn individual's outstanding debt on taxes and payments administered by the tax service.
5 ₽ / check
Learn moreA history of disputes from the commercial court case file, bankruptcy cases included. Matching is done by tax number, so namesakes never reach the results.
5 ₽ / check
Learn moreA flag that the person is listed as a nominee or serial company director.
5 ₽ / check
Learn moreA person's links to legal entities: where they are a shareholder or a director, and whether they hold sole trader status.
5 ₽ / check
Learn moreThe people behind the client
The document, status and debts of a director, a shareholder or a sole trader.
The passport of the director or the representative is read with no manual entry; documents from 195+ countries and territories.
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 moreDetermining the tax number from the passport data. It unlocks the checks that need precise identification of the person — with no namesakes.
5 ₽ / check
Learn moreA search of the federal bankruptcy register: personal bankruptcy cases filed and completed. By tax number the result is unambiguous.
5 ₽ / check
Learn moreActive 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 moreConfirmation of registration as a payer of professional income tax.
5 ₽ / check
Learn moreAML/CFT and sanctions
The mandatory watchlist, foreign lists and the client's documents.
Screening against the list of people involved in extremist activity or terrorism. A mandatory check under 115-FZ.
5 ₽ / check
Learn moreScreening 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 moreInternational 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 moreA 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 moreThe document is checked for forgery and traces of editing: fonts, fields and a photo of a screen.
A client's contracts, invoices and bank statements — the fields follow the template of your forms, with no manual entry.
Checks against registers and lists cost a fixed price per request, with no subscription fee and no annual licence. A small firm does not pay for volume it does not have.
5 ₽ per check
A nominee director, account freezes, the Rosfinmonitoring watchlist, sanctions lists and bankruptcy — each on its own.
50 ₽ per package (3.125 ₽ per check)
16 checks from the passport of a director or a sole trader: passport validity, the Rosfinmonitoring watchlist, sanctions, wanted lists, debts, bankruptcy and court cases. Bought separately they cost 80 ₽.
36 ₽ per check
PEP status, sanctions lists from more than 50 countries, regulatory actions and adverse media — for foreign shareholders and directors.
Company checks by tax number, document recognition and anti-fraud are priced separately — we will quote for your number of clients.
For a small firm the web console and a link for the client are enough. A large outsourcer or an audit network connects the checks to its own system through the API.
Payment for the checks performed, with 24/7 support.
An accounting firm needs a vendor who checks both the company and the people behind it, needs no compliance department and charges only for the checks performed.
A real company with a clean history may still have a bankrupt director or a shareholder on the watchlist.
NeuroVision brings both parts into one answer — no looking the director up in three services and saving screenshots to the client's folder.
115‑FZ, financial monitoring and company checks — on our blog.
Yes, if it provides accounting services as a business and prepares or carries out transactions on behalf of or on the instructions of a client — article 7.1 of 115‑FZ. Rosfinmonitoring treats bookkeeping, filing returns and advising companies as such transactions. The firm or the sole trader draws up internal control rules, identifies clients before taking them on and checks them against the Rosfinmonitoring watchlist. Reports and notifications are filed with Rosfinmonitoring through the online portal on its website; unlike the organisations under article 5, such firms do not register with Rosfinmonitoring.
Since 30 December 2024 (law No. 222‑FZ), audit firms and individual auditors providing audit services identify their clients, assess risk, run internal control and keep records. The asset freezing requirements do not apply to audit services. Auditors have had to report suspicions about an audited entity to Rosfinmonitoring since 2018.
There is no separate law on tax advice, and article 7.1 of 115‑FZ does not name tax advisers expressly. The duties arise if the adviser provides legal or accounting services as a business and prepares or carries out the client transactions listed in article 7.1.
No. Identification is carried out by your firm under its own internal control rules, and it files the reports and notifications itself. NeuroVision checks the client against the registers, the watchlist and sanctions and returns a result with its source and date — you use that data in the client file.
When taking the client on — before the work starts. If a person from the watchlist turns up among your clients, the accounting firm freezes their assets within 24 hours of the watchlist being published and notifies Rosfinmonitoring within one working day, which is why clients are checked every time the watchlist is updated. Auditors providing audit services do not apply freezing.
The tax number gives you the company's status, the date of registration, account freezes, tax debts and commercial court cases. The director is checked against the register of nominee and mass directors and for links to other companies. Each check on a director costs 5 ₽.
Yes. The director's passport or the representative's is read with no manual entry — documents from 195+ countries and territories. Contracts, invoices and bank statements are read to the template of your forms: the fields come back in JSON.
No. The client's tax number can be checked in the web console, and the client uploads the representative's passport through a link. If the firm has its own system, the checks are connected over the REST API.
Checks against registers and lists cost from 5 ₽, a package of 16 checks from the director's passport costs 50 ₽, and compliance screening 36 ₽. Company checks by tax number and document recognition are quoted on request. Test access lasts 1 month.
Tell us how many clients you have and how many new ones arrive each month, and whether any of them are sole traders or companies with foreign shareholders — we will put together a set of checks 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
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