Step 1
The passport with no manual entry
The cashier scans a Russian passport or a foreign national’s document. The fields go into the transaction record; a photo of a screen, a printout and editing in an editor are flagged at once.
Customer identification at currency exchange offices: passport, watchlists and 115‑FZ thresholds at the counter
Above RUB 40,000 the cashier establishes the customer’s identity, above RUB 100,000 they collect a full questionnaire, and the Rosfinmonitoring lists are checked before the transaction. We recognise a Russian passport and documents from 195+ countries and territories without manual entry, flag forgeries and screen the customer against watchlists and sanctions while they are still standing at the window. The decision on the transaction stays with the bank.
Passport without entry Document anti-fraud Foreign nationals’ documents Watchlists and sanctions INN by passport
Data stored in Russia · Russian software registry no. 19972 · 152‑FZ
Cash currency exchange under 115‑FZ: who may exchange, the RUB 40,000 and RUB 100,000 thresholds, mandatory control
In Russia, cash foreign currency can be bought or sold only at an authorised bank — in a branch, an exchange office or a bank’s operating cash desk. The identification procedure is set by 115‑FZ and depends on the transaction amount.
At any amount, if the transaction looks suspicious, the cashier establishes the customer’s identity.
- Passport recognition
Who carries out the exchange
Federal Law No. 173‑FZ, Art. 11(1); Law No. 395-1, Art. 5(1)(6); Bank of Russia Instruction No. 136-I
Authorised bank
- Foreign currency is bought and sold only through authorised banks and VEB.RF
- Buying and selling cash currency is a banking operation
Where
- On bank premises, including internal structural units
- List of operations — for each unit
At the counter
- Rates, fees and the list of operations — on the notice board
- When the operation is complete, the customer receives a confirming document
- Customer KYC
Three identification thresholds
115‑FZ, items 1.2, 1.11, 1.12, Art. 7(1)(1)
Up to RUB 40,000
- No identification is carried out
- Unless the employee has a suspicion
Up to RUB 100,000
- Simplified identification: full name, document series and number
- The customer presents the original document
Over RUB 100,000
- Full identification: citizenship, date of birth, address, taxpayer ID (INN) if any
- For a foreign national — a document confirming the right to stay in Russia
- Rosfinmonitoring watchlists
Watchlists, control and retention
115‑FZ, Art. 6(1)(1); Art. 7(1)(6), (7) and Art. 7(4)
From RUB 1 million
- Buying or selling cash currency by an individual is a transaction subject to mandatory control
Watchlists
- Freezing measures — no later than 24 hours after the list is published
- Customer base screening — at least once every three months
Storage
- Identification documents and information — for at least five years after the relationship ends
A branch cash desk, an airport exchange office, currency ordered in an app: where the bank meets the customer
The law is the same for all of a bank’s cash desks, but the conditions differ: a queue in a branch, a flow of tourists at the airport, a customer who ordered currency in advance.
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Branch cash desk
- The passport is placed on a scanner or photographed with a tablet camera
- Fields go into the transaction record without retyping
- Watchlists and sanctions — before the cashier counts out the money
-
Exchange office at an airport, a railway station or a shopping mall
- A bank unit with a long queue and a short shift
- Tourists’ documents from 195+ countries and territories
- The same check at every point of the network
-
Cash currency ordered in an app
- The customer goes through KYC session at the time of the order
- At the office the cashier matches the passport to the order
- The amount and customer details are in the order in advance
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Foreign clients
- A foreign passport, visa, residence permit or temporary residence permit — without manual entry
- International screening with PEP
- The name in Latin script and in the original spelling
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Changing and replacing banknotes
- The same thresholds: RUB 40,000 and RUB 100,000
- Passport — when the threshold is exceeded or on suspicion
- A series of transactions on one passport — in the bank’s system
-
Up to RUB 40,000, up to RUB 100,000 and over RUB 100,000: what the cashier establishes about the customer
The threshold is counted on the amount of a single transaction in roubles or the currency equivalent. The set of details grows with the amount, and suspicion cancels any relaxations.
-
Up to RUB 40,000
No identification is carried out — neither full nor simplified.
Removal — the cashier’s suspicion: then the passport and watchlists are checked at any amount. -
From RUB 40,000 to RUB 100,000
Simplified identification: full name and passport series and number from the original document.
Recognition fills in the fields at once, and the watchlists are checked on the spot. -
Over RUB 100,000
Full questionnaire: citizenship, date of birth, registration address, taxpayer ID (INN) if any.
Tax number is found from the passport data, and passport validity is checked against the Ministry of Internal Affairs database. -
From RUB 1 million
Mandatory monitoring: a cash currency transaction by an individual from RUB 1 million.
Full identification, and the bank sends the transaction details to Rosfinmonitoring. -
A foreign national
A foreign passport from 195+ countries and territories; over RUB 100,000 — a document confirming the right to stay, where required: a visa, residence permit or temporary residence permit.
Sanctions and PEP — international screening by the name in Latin script. -
Suspicion and structuring
A series of transactions just below the threshold, someone else’s money, a customer acting on instructions.
The cashier establishes the customer’s identity at any amount if they have a suspicion.
Identification at the currency desk: three steps from the passport to the confirming document
The cashier puts the passport on a scanner or photographs it with a tablet — the service does the rest. The customer waits at the window no longer than for an ordinary exchange.
Step 2
Watchlists, sanctions and passport
The customer is checked against the list of terrorists and extremists, the register of foreign agents and sanctions lists; a Russian passport — against the Ministry of Internal Affairs database, a foreign national — through international screening with PEP. Above RUB 100,000 the taxpayer ID (INN) is found from the passport.
Step 3
Decision and entry in the core banking system
The results arrive as JSON in the bank’s system. The cashier carries out the exchange and issues the confirming document; a watchlist match is passed by the bank’s system to the responsible officer before the money is handed over.
Someone else’s passport, a front customer, a person from a watchlist: what an exchange desk risks
Three thresholds — three sets of details
Cash currency is a convenient way to take money out or hide it. The cashier sees the customer for a couple of minutes and enters the data by hand — and the schemes are built on exactly that.
- 01
Someone else’s or invalid passport
Currency is bought with a lost or purchased passport. Document anti-fraud and a validity check against the Ministry of Internal Affairs database come before the money is paid out.
- 02
Front customer
One person brings the money, but someone else’s passport is presented. Matching the face with the passport photo at the moment of the check shows that the document is not theirs.
- 03
Customer from a watchlist
A person from the Rosfinmonitoring list buys currency above the threshold. Watchlists are checked automatically by full name and date of birth, not from the cashier’s memory.
- 04
Manual entry error
A typo in the passport number or in the transliteration of a foreign name — and the watchlist check runs on someone else’s data. Recognition removes retyping.
- 40 000 ₽ a transaction without identification, if there is no suspicion
- 100 000 ₽ the limit of simplified identification
- RUB 1 million a transaction subject to mandatory control
Cashier’s checklist: document, amount, watchlists and the transaction record
Four groups, eighteen lines. The tag shows who closes the line: our check, the bank’s system or the AML/CFT officer.
- A Russian passport or a foreigner's document from 195+ countries and territories is recognised, and the fields go into the transaction record
- A photo of a screen, a printout, a pasted-in photo and editing in an editor — before the money is paid out
- Validity of a Russian passport against the Ministry of Internal Affairs database
- A foreign national’s visa, residence permit or temporary residence permit — as an additional document
- The customer’s face matches the photo in the passport
- Transaction amount in roubles and the threshold: RUB 40,000, RUB 100,000 or RUB 1 million
- Full questionnaire above RUB 100,000: citizenship, date of birth, address, taxpayer ID (INN)
- A series of transactions by one customer below the threshold in a day
- Confirming document for the transaction
- The list of terrorists and extremists and the foreign agents register
- OFAC, EU, UK and UN sanctions lists
- Foreign national — international screening with PEP
- Police wanted list
- Decision on a watchlist match and freezing
- Check results as JSON — into the customer record in the core banking system
- Retention of information and documents — at least five years
- Re-running the watchlist check for customers from the transaction history — via the API
- Report on a transaction subject to mandatory control
- NeuroVision — the line is closed by NeuroVision: document recognition, anti-fraud, watchlists, sanctions, taxpayer ID (INN) and the questionnaire
- Bank system — a bank system line: amount and threshold, series of transactions, confirming document and retention
- Responsible officer — a decision by the AML/CFT officer
A tourist with a passport in characters: how to identify a foreign national at the exchange window
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Unfamiliar document
Risk. The cashier sees a passport from this country for the first time and does not know where the number and expiry date are.
NeuroVision. The document type is determined automatically among 16,000+ types from 195+ countries and territories, and the fields go into the questionnaire. -
A name in two spellings
Risk. The name is written differently in Latin script and in the original, and the cashier enters one of the variants with an error.
NeuroVision. The fields and the MRZ are read without manual entry, and sanctions and PEP are checked against the exact spelling. -
Right to stay
Risk. Above RUB 100,000 the data from a document confirming the right to stay in Russia is needed, if it is required for this foreign national.
NeuroVision. A visa, residence permit and temporary residence permit are recognised as an additional document in the same session. -
Sanctions and PEP
Risk. The bank must take the available measures to identify a foreign public official and may serve them only by written decision of a manager.
NeuroVision. International screening shows PEP status and sanctions before the transaction.
A foreign national goes through the same check as a Russian citizen — on the same cashier’s tablet and without an interpreter.
Five ways to get around the thresholds and push someone else’s money through an exchange
Structuring
Several transactions just below RUB 40,000
A large amount is exchanged in parts on different days or at neighbouring offices. Linking transactions by passport number is configured in the bank’s system.
Several performers
Each exchanges a little
Acquaintances and hired people exchange currency on their own passports. Identical amounts and times at different points of the network are visible in the bank’s system.
Someone else's passport
A lost or purchased passport
A transaction above the threshold is made on someone else’s document. Passport validity and document anti-fraud filter out forgeries and invalid passports.
A watchlist customer through an intermediary
A relative buys the currency
The money of a person from a watchlist is exchanged by someone else. Watchlists are checked for every customer, and the responsible officer reviews the suspicious transaction.
Reverse exchange
Buy and sell straight away
Cash roubles of doubtful origin are exchanged for currency and back at another office. Repeat transactions on one passport are visible in the customer’s history in the bank’s system.
115-FZ
The customer is identified before the money is paid out
A regular currency desk customer: when the passport and watchlists are checked again
A customer comes to the same branch for years, but watchlists are updated and passports change. A repeat check is needed where the risk changes.
-
List updates
Rosfinmonitoring and sanctions authorities update their lists, and customers are checked against watchlists at least once every three months. The check of customers from the transaction history is re-run via the API.
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A new passport
The customer changed their passport or surname. The new document is recognised without manual entry, and watchlists and validity are checked again.
-
An above-usual amount
A customer who used to exchange RUB 30,000 brings RUB 500,000. The full questionnaire and taxpayer ID (INN) — in the same session, without asking again.
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Doubts about the information
The customer’s data differs from the previous transaction. The passport is recognised again, and the questionnaire is updated without manual entry.
Checks for a bank’s currency desk: catalogue and prices
Each check is switched on separately — for the threshold, the customer type and the exchange point. You pay for completed requests. All database checks are in the catalogue AML checks.
Customer at the window
A passport and a foreign national’s documents without manual entry.
- OCR · anti-fraud
Russian passport recognition
A Russian passport is recognised from a photo or from the cash desk scanner: the fields arrive as a JSON response in the bank’s system.
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 - OCR
Visa, residence permit, temporary residence permit
A visa, residence permit or temporary residence permit is recognised as an additional document in the same session.
10 ₽ per document
Learn more - KYC
Face comparison with the passport photo
Liveness and a one-off match of the customer’s face to the photo in the document within the current check.
from 29 ₽ per session
Learn more
Before the money is paid out
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
Over RUB 100,000
The full questionnaire and document status.
- 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 - 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 - Police
The police register of controlled persons
A check on a foreign national against the register of controlled persons that the police have kept since February 2025: people who have lost the legal grounds to stay in Russia. Russian citizens do not need the check — by law they are not in the register.
5 ₽ / check
Learn more
What customer identification costs at a currency exchange
The price is per session of one customer and per database check. No subscription fee: the more transactions a year, the lower the price.
-
A Russian passport or a foreign national’s document without manual entry, anti-fraud: a photo of a screen, a printout, a pasted-in photo, editing. Visa, residence permit, temporary residence permit — RUB 10.
- Enable
Document + face
from 29 ₽ per session
Everything in “Document”, plus face comparison with the passport photo and liveness. For ordering currency in an app and large amounts.
- Build a set
Watchlists and questionnaire
5 ₽ per check
The list of terrorists and extremists, the register of foreign agents, OFAC, EU, UK and UN sanctions, passport validity, taxpayer ID (INN) from the passport. International screening — RUB 36.
One session — one customer. At 10,000 checks a year the “Document” session is RUB 18 on the calculator. Transactions up to RUB 40,000 without suspicion require no identification — you pay only for those where it is needed. Calculator on the pricing page.
Embedding at the cash desk: cashier’s tablet, passport scanner, core banking system and the bank’s perimeter
The check sits where the cashier processes the transaction: in the workstation, in the core banking system or on a tablet at the window. Steps are switched on by scenario rules — passport above RUB 40,000, full questionnaire above RUB 100,000.
- Web SDK
- Scanner
- iOS and Android
- REST API
- Docker
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 banks put NeuroVision on currency desks
A cash desk needs a service that does not lengthen the queue, understands tourists’ documents and keeps data in Russia.
Passport, watchlists and questionnaire — in the time it takes the customer to take out their money
Recognition, document anti-fraud and watchlist checks work on the same data. The cashier does not retype the passport, and the responsible officer sees the result of each check in the bank’s system.
There is no need to assemble a solution from several vendors and reconcile their responses.
Currency desk glossary: simplified identification, mandatory control, confirming document
A short guide to the terms found in 115‑FZ and in a bank’s internal control rules.
- Authorised bank
- A bank that, under a Bank of Russia licence, may carry out foreign currency operations, including buying and selling cash currency.
- Authorised bank
- Identification
- Establishing information about the customer and confirming it with documents: full name, citizenship, date of birth, document, address, taxpayer ID (INN) if any.
- Customer identification
- Simplified identification
- Establishing the full name and the document series and number of an individual customer; for currency exchange — for transactions up to RUB 100,000.
- Simplified due diligence
- Mandatory monitoring
- Transactions the bank reports to Rosfinmonitoring; for buying and selling cash currency — from RUB 1 million.
- Mandatory reporting
- Structuring
- Splitting a large amount into transactions below the identification threshold.
- Structuring
- The list of terrorists and extremists
- A Rosfinmonitoring list of persons about whom there is information on involvement in extremist activity or terrorism.
- Terrorist list
- Document confirming the right to stay
- A visa, residence permit, temporary residence permit and other documents of a foreign national.
- Residence document
- Confirming document
- A document on a cash currency transaction that the bank issues to the customer when it is complete, on paper or in electronic form.
- Transaction receipt
- Public official
- A person holding a public office, and their close relatives; requires enhanced attention from the bank.
- PEP
- Document anti-fraud
- A check that the document in front of the camera is genuine, not a photo of a screen, a printout or an edit.
- Document fraud detection
Read also
115‑FZ requirements, forged documents and checking foreign nationals — in our blog.
126 29
KYC, AML and Digital Identification
115-FZ: What Businesses Are Required to Do and How to Meet the Law’s Requirements
456 13
KYC Document Verification
How KYC Systems Detect Forged Documents
377 30
KYC, AML and Digital Identification
KYC for international clients and non-residents in 2025: current requirements and application practice
433 23
KYC, AML and Digital Identification
How Sanctions Screening, PEP Checks, and Risk Profiling Work After Customer Identification
Questions about identification at currency exchange
It is establishing the identity of a customer who buys or sells cash currency and checking them against watchlists before the transaction. The bank does this under 115‑FZ: the scope of information depends on the amount, and on suspicion it does not depend on the amount.
Yes, if the amount does not exceed RUB 40,000 or its equivalent in currency. The exception is when a bank employee suspects money laundering or terrorist financing: then the cashier establishes the customer's identity at any amount.
For transactions up to RUB 100,000 the cashier establishes the full name and the document series and number from the original passport. Above RUB 100,000 a full questionnaire is required: citizenship, date of birth, address, taxpayer ID (INN) if any.
Buying or selling cash foreign currency by an individual for RUB 1 million or more, or its equivalent in currency. The bank sends information about such a transaction to Rosfinmonitoring.
In Russia, foreign currency is bought and sold only through authorised banks and the state corporation VEB.RF. For the customer this means a bank cash desk: a branch, an exchange office or an operating cash desk.
A passport and, for a transaction above RUB 100,000, also a document confirming the right to stay in Russia, if it is required: a visa, residence permit or temporary residence permit. NeuroVision recognises documents from 195+ countries and territories and checks a foreign national against sanctions and PEP.
By the customer's full name and date of birth before the transaction, and the customer base at least once every three months. NeuroVision checks the list of terrorists and extremists for RUB 5 and returns matches to the bank's system.
Passport recognition takes less than a second, and the watchlist and sanctions checks run in parallel. The customer waits no longer than for an ordinary exchange.
Yes. The image from the cash desk scanner is sent to the recognition API, and where there is no scanner, the cashier photographs the passport with the tablet camera through the widget.
No. We recognise the document, check the customer and pass the result to the bank's system. The decision on the transaction, freezing and reports to Rosfinmonitoring remain with the bank's responsible officer.
In Russia: in the NeuroVision cloud or on the bank's servers with on-premises installation. The retention period is set in the scenario, and the bank keeps identification documents and information for at least five years after the relationship with the customer ends.
This page covers the exchange of cash foreign currency in a bank under 115‑FZ. The exchange of digital currency is governed by the law on digital currencies; see the page for crypto exchangers.
We will build an identification scenario for your currency desks
Tell us how many cash desks and exchange points you have and whether you serve many foreign customers. We will set up thresholds and checks for 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
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