Step 1
Opened
The check returned a match — the case is created automatically, with the source record, the client data and a deadline. A case on the Rosfinmonitoring list goes first in the queue.
AML case management and reporting
Every match against watchlists, sanctions, PEP and registers becomes a case: a deadline, an owner, the designated compliance officer's reasoned decision and a log entry. Compliance case management and internal control reports under 115‑FZ — in the NeuroVision workspace or in your CRM.
Statuses and assignments Reasoned decision Log of all actions
AML case management: the match, the client and the source in one card
One match — one case
A match doesn't get lost in email and spreadsheets: it has an owner, a deadline and a history until it is closed.
- 01
What matched and where
The list or register, the record from it, the date and time of the source's response, and the fields that triggered the match — full name, date of birth, tax ID. No trips to the register's website and no screenshots.
- 02
Who the client is
Questionnaire and document data, the risk level, the results of the other database checks. You see how the client differs from the person on the list and where they coincide.
- 03
Who is responsible and by when
The case status, the assigned employee and the 115‑FZ deadline that started running when the match occurred. Overdue cases move to the top of the queue.
- 04
What has already been done
Analyst comments, requests to the client, attached documents and every status change — with the author and the time.
- 1 working day to report a freeze to Rosfinmonitoring
- 7 working days to update details when their accuracy is in doubt
- 12 programmes in internal control rules under Government Resolution No. 667
Where cases come from: watchlists, sanctions, PEP, foreign agents, wanted lists and publications
A case opens when a database check returns a match — at client onboarding, at a repeat database check or at an employee's request. The response fields and check outcomes are described in the documentation on retrieving results.
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The Rosfinmonitoring list
The most urgent case. A match against the list of organisations and individuals involved in extremism or terrorism starts the timer for the freeze and the report. Watchlist screening
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Sanctions lists
OFAC, EU, UK, UN. The case shows the degree of similarity and an alias flag: the employee sees why the match was triggered. Sanctions screening
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Politically exposed persons
PEPs and their associates. A case is not a refusal: the decision to accept the client is made by a manager, and the client is assigned a high risk. PEP screening
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Foreign agents and wanted lists
Ministry of Justice register, Interior Ministry wanted list, Prison Service, Bailiffs. A match is confirmed by date of birth and tax ID — the case closes quickly if it's a namesake. Database checks
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Adverse media
Information from the media and open sources in compliance screening. A publication is a reason to look into the matter and revisit the risk, not an automatic refusal. Ongoing AML monitoring of customers
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Repeat database check
A new match for an existing client. The lists have been updated — a case opens for the client whose result has changed. Ongoing AML monitoring of customers
The path of a case: opened, assigned, reviewed, decided, closed
Five statuses that are easy to build into the programme documenting your internal control rules.
Step 2
Assigned
The shift lead or a queue rule assigns an analyst. You can see who has how many open cases and which are close to their deadline.
Step 3
Reviewed
The analyst compares the client with the list record: date of birth, tax ID, citizenship, documents. If there is too little data — a request to the client, and the case waits for the reply with the status “information needed”.
Step 4
Decided
The designated compliance officer picks the outcome and writes a reasoned justification. If a measure is needed — a freeze, a refusal, a report to Rosfinmonitoring — the case records who took it and when.
Step 5
Closed
The case goes to the register with its full history. The client's risk level is updated, and the materials are kept with the client file for at least five years after the relationship ends.
Confirmed, false positive, information needed: how a review ends
Each outcome has its own consequence for the client and for the report. A person chooses the outcome; the system only suggests what data is missing.
Reasoned justification: what to write in the designated compliance officer's decision
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Not “checked”, but why
Internal control rules require the record of the designated compliance officer's decision to include a reasoned justification. The case template asks you to state which fields were compared and what follows from that.
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Who drafted and who decided
The internal report contains the details of the employee who drafted it, their signature, and the decision of the designated compliance officer and, if needed, of a manager. The case stores all three with dates.
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Evidence next to the decision
The register record with the response date, the client's documents and the reply to the information request — all attached to the case. Three years later you won't have to dig through email.
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A decision can't be quietly rewritten
Changing an outcome creates a new record with the author and the time rather than editing the old one. The reviewer sees the entire case history.
Your organisation defines the form and deadlines of the internal report in its own rules — the case template is configured to match.
24 hours, one business day, three months: 115‑FZ timers on the case card
Statutory deadlines run from a specific event: a list being published, a transaction being detected, doubts arising. The case remembers that event and shows how much time is left.
- Freeze — immediately, but no later than 24 hours after the list is posted on the Rosfinmonitoring website (art. 7(1)(6))
- Report on the measures taken — no later than one business day after they are applied
- The full table of measures and deadlines for the lists is on the list checks page
- Reporting to Rosfinmonitoring — no later than three business days after the transaction is detected (art. 7(3)). The case records the detection date
- The client is not informed about the measures (art. 7(6)) — requests to the client from the case are worded neutrally
- Update when accuracy is in doubt — within seven business days (art. 7(1)(3))
- Scheduled update — once a year, and once every three years for low-risk clients
- Checking all clients against the list at least once every three months and informing Rosfinmonitoring of the results (art. 7(1)(7))
- Documents and materials — for at least five years from the termination of the client relationship (art. 7(4))
- This is a guide to the text of the law, not legal advice; the exact text is in ConsultantPlus. For organisations supervised by the Bank of Russia, internal control rules are developed taking its requirements into account (art. 7(2)). Re-checking the whole database is on the page AML client monitoring.
Compliance reporting for internal control: three reports from the case register
AML reporting is not only about reports to Rosfinmonitoring. Internal audit, management and the reviewer ask different questions: how many matches there were, who reviewed them and how, and whether deadlines were met. The KYC session log is exported as an archive — log export method.
- Show the register
Case register for a period
For the manager and the compliance officer.
The report includes:
- open and closed cases
- match source
- outcome
- owner
- deadline and actual closing time
Breakdowns:
- by analyst
- by source
- overdue
- export to CSV and XLS
- Set up reconciliation
Quarterly list reconciliation
For informing Rosfinmonitoring of the results.
The report includes:
- reconciliation start date
- how many clients were checked
- matches and their outcomes
- measures taken
Basis:
- re-checking the whole database against the list at least once every three months — art. 7(1)(7) of 115‑FZ
- Build a package
Materials for the reviewer
Reports for the regulator and internal audit.
The package includes:
- case cards with justification
- register records with the response date
- action log
- templates of the internal report and SAR/STR
For the internal control audit programme:
- a sample of cases for the period
- who changed what and when
- the archive is kept for at least five years
Who should run AML cases under 115‑FZ: from microfinance firms to platform operators
Everyone who, under 115‑FZ, appoints a designated compliance officer and checks clients against lists. The more clients you have, the costlier manual tracking in a spreadsheet gets.
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Microfinance organisations and pawnshops
- A stream of onboarding, frequent name matches, short decision times on loans. The case does not let the money out until the list match is closed.
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Leasing and factoring
- Matches among the executives and beneficial owners of corporate clients. The case records which person and which deal the decision was about.
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Payment services and wallets
- Repeat database checks produce cases on existing clients — they need to be reviewed without stopping other clients' payments.
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Brokers and investment platforms
- Foreign clients, sanctions lists and PEPs: many similar names, and a manager's decision on accepting a PEP.
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Crypto services and DFA operators
- Sanctions, lists and wallet addresses. A client case is linked to the AML check of a crypto address.
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Platform operators and marketplaces
- Sellers, contractors and payout recipients. A register match — a case before the first payout, not after.
What your organisation decides: reports to Rosfinmonitoring, freezing, refusal
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Reports to Rosfinmonitoring
Submitted by your organisation in the manner established for it. The case prepares the materials and a template and records the submission date — but does not submit the report itself.
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Freezing funds
The block is carried out by your accounting or banking system. The case holds a note of who applied it and when, and a timer for the report.
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Refusing a client
Refusing service or a transaction is your organisation's decision under its rules. The system does not refuse clients automatically on a match.
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Internal control rules
Internal control rules are drafted and approved by your organisation's head. Case management is configured to fit your programmes, not the other way round.
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Transactions and links
Payment alerts and account links are in KYT: transaction monitoring and graph investigations. Here — client matches.
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Disputed KYC sessions
Document authenticity and the client's frames are reviewed by a KYC verifier. Here — matches in lists and registers.
This is a guide, not legal advice. NeuroVision works with legal entities and sole proprietors under a contract; data is processed in Russia under 152‑FZ.
How much AML case management costs
The checks that generate cases are paid for under the price matrix. Case management and reporting are priced by the number of users and the database size.
- Build a set
Database checks
5 ₽ per check
Rosfinmonitoring list, sanctions, foreign agents, wanted lists — each check separately. A package of 16 basic passport checks — 50 ₽.
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PEP, sanctions and adverse media in one check — a source of cases for foreign clients and deals.
- Calculate
Case management and reporting
on request
Queue, statuses and assignments, decisions with justification, a log, internal control reports, on-premise installation.
A check skipped for lack of data is not billed. A KYC session with a document — from 16 ₽, with liveness — from 29 ₽. Trial period — 1 month. Price matrix and calculator.
Integration: compliance workspace, an API for your CRM, on-premise installation
- Queue and statuses
- Roles and 2FA
- Cases in your CRM
- Cloud or your own perimeter
A trial period of 1 month.
Contract-based support. Data in Russia.
AML case glossary: ICR, designated compliance officer, false positive, SAR
Terms of the workspace, internal control rules and talking to a reviewer.
- Case
- The card of a single match: the list record, the client, the deadline, the owner, the decision and the action history.
- case
- Case management
- Tracking cases from opening to closing: queue, statuses, assignments, reports.
- case management
- Match
- A check response where the client's data agrees with a list or register record.
- hit / match
- False positive
- A match with a namesake: the list record refers to another person.
- false positive
- Internal control rules (ICR)
- Internal control rules under 115‑FZ: the programmes by which an organisation checks clients and records decisions.
- AML/CFT policy
- A designated compliance officer
- The employee responsible for implementing the internal control rules; makes decisions on matches.
- compliance officer
- Reasoned justification
- An explanation of the designated compliance officer's decision: what was compared and why that conclusion was reached.
- rationale
- Case log
- An immutable history of actions: who opened, assigned and decided, and when.
- audit trail
- SAR / STR
- A report on suspicious activity or a transaction. In Russia — a report to Rosfinmonitoring under art. 7(3) of 115‑FZ.
- SAR / STR
- Freezing
- Blocking the funds or other property of a person on the list.
- asset freeze
Read also
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False Positives in AML Screening: How to Reduce Escalations and Preserve Onboarding Conversion
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Financial Monitoring and AML/CFT in Simple Terms: What It Is, Who It Applies To, and How It Works
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115-FZ: What Businesses Are Required to Do and How to Meet the Law’s Requirements
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Fintech Compliance Under Federal Law 115-FZ: How to Build a KYC and AML Loop Without Overloading the Team
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How Sanctions Screening, PEP Checks, and Risk Profiling Work After Customer Identification
Frequently asked questions about AML case management and reporting
Tracking each AML screening match as a separate case: the card holds the list record, the client data, the 115‑FZ deadline and the owner. A case goes through the statuses “opened”, “assigned”, “reviewed”, “decided”, “closed”, and every action goes to the log.
From database checks: the Rosfinmonitoring list, the OFAC, EU, UK and UN sanctions lists, PEP, the foreign agents register, wanted lists and adverse media. A case opens at client onboarding, at a repeat database check or at an employee's request.
The designated compliance officer of your organisation and, where necessary, a manager. The system shows the data and deadlines but does not decide for a person and does not refuse clients automatically.
An explanation of why a decision was made: which fields were compared and what follows from that. The requirements for internal control rules (Government Resolution No. 667, para. 27) provide for a record of the designated compliance officer's decision and its reasoned justification. The case template won't let you close a case without a justification.
Freezing under a list — no later than 24 hours after the list is posted, the report on it — no later than one business day, reporting a suspicious transaction — no later than three business days after detection, updating details when in doubt — seven business days.
A case register for a period with outcomes, deadlines and owners; a report on the quarterly reconciliation of clients against the list; a package of materials for the reviewer and internal audit. Export — to CSV and XLS.
No. Besides transaction reports, the law requires information to be documented under the internal control rules, kept for at least five years, and the results of list reconciliation to be reported quarterly. That is internal compliance reporting.
The reports gather what a reviewer asks for most often: cases with justification, register records with the response date, the action history. The form of documents for the regulator is defined by your rules and the supervisor's requirements — templates are configured to match.
A case includes SAR / STR and internal report templates: the materials are assembled automatically. In Russia this is a suspicious transaction report, and your organisation submits it to Rosfinmonitoring — no later than three business days after detection.
Yes. Check results arrive through the API, the case opens in your CRM or core banking system, and the decision and log are stored with you. The NeuroVision workspace can still be used for reports and audit. Case management pricing — on request, database checks — from 5 ₽.
We'll set up AML match review to fit your internal control rules
Tell us how many clients you have, how many matches you get per month and where the log is kept now, — and we'll propose statuses, roles, justification templates and a quote.
Can't put your request into words? Book a call and our team will contact you at a convenient time
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