A customer passed checks at onboarding, but the Rosfinmonitoring lists, sanctions lists and the PEP database change over time. NeuroVision returns the results of checks against these lists: repeat them with an API request on your system’s schedule, compare with the previous result and learn about a new match before the inspector does. The response deadline is set by 115‑FZ; the decision is made by your compliance team.
115‑FZ counts the time from the publication of the list. Learning of a match at the next scheduled check means being late.
Rosfinmonitoring regularly adds to the list of terrorists and extremists, the Interagency Commission (IAC) takes freezing decisions, and sanctions lists and the database of politically exposed persons change too. A customer who was clean on the day of onboarding can appear on a list a week later.
The 24 hours to freeze funds under the national list start from the moment the information appears on the Rosfinmonitoring website. If you check your base once a quarter, this deadline is easy to miss.
Exporting tens of thousands of customers, running them through the new version of the list and reviewing the matches by hand can be done once a quarter, but no more often. Repeat API requests can be sent from your system on a schedule, so that you review only the changes.
NeuroVision does not freeze funds and does not send reports to Rosfinmonitoring. It returns the result of the check, and from there your process runs under your internal control rules.
Screening at onboarding and repeat checks use the same checks. The difference is that repeat checks run again when a source changes and are compared with the previous result: you only need to review the changes.
A new version of the Rosfinmonitoring list is checked against the customer base by full name and date of birth. Removed entries are returned separately: if a customer has been taken off the list, the measures must be lifted no later than the next working day. More in the watchlist check.
Decisions of the Interagency Commission on freezing and the UN Security Council lists on terrorism and the proliferation of weapons of mass destruction. Each has its own deadlines, so the source must be recorded in the match record. The check against IAC decisions is available on request.
OFAC, the EU, the UK and the UN as part of international screening. Important for customers with foreign documents, international transfers and crypto services. More in sanctions screening.
The customer was appointed to a post, became a relative of a PEP or left office. The new status changes the measures under art. 7.3 of 115‑FZ: a written decision by a manager, the source of funds, heightened attention to transactions. More in PEP screening.
Ministry of Internal Affairs and Federal Bailiff Service wanted lists, enforcement proceedings, courts of general jurisdiction: information that appears after a customer has been taken on and matters for assessing business reputation (subpara. 1.1, para. 1, art. 7 of 115‑FZ).
The passport has become invalid, the customer has been declared bankrupt or has appeared in the register of controlled foreign persons. This is grounds to doubt the accuracy of the details and to update the application form within seven working days. All checks are in the individual check catalogue.
Running all checks on the whole base for no reason is expensive and pointless. Tie the repeat check to an event: a new version of the list has come out — check all customers against that list only. Everything else follows the schedule you set in your internal control rules.
Five steps. People are needed in two: to decide whom to check and how often, and to review a match. The rest is done by your system and API requests.
Customers you already serve are in your system: full name, date of birth, citizenship, and for legal entities — name and taxpayer ID (INN). Split them into groups by risk level: each has its own set of checks and repeat interval.
The first check gives a starting point: lists, sanctions and PEP status for the customer as of the onboarding date. Keep the API response on your side — every later check is compared with it.
A new version of a list or sanctions list has come out — run a check across the base. Documents and statuses follow your schedule. The request returns a run number (runId); you get the result by polling every 5–10 seconds.
Your system matches the new response against the previous one: what it was, what it is now, and when. A new match gets an urgency and a response deadline, for example “freeze — within 24 hours of publication”.
The responsible officer confirms the match or marks a namesake and records the measures. Decisions are kept in your system’s log: it is the source for the quarterly screening report.
A repeat check returns a new result for the customer, and your system compares it with the baseline: a queue of changes, a “before → after” card and the officer’s decision. The screens are an example of such a card built from two API responses. A match with a list is a reason to take measures under the internal control rules on time: a full namesake is not the same person.
This page. Lists, IAC decisions, sanctions, PEP, wanted status and documents of a customer you already serve. A new match is a reason to review the customer’s risk level.
Transactions and transfers: amounts, counterparties, countries, signs of unusual transactions. More on the KYT page.
Transfers made without the customer’s consent, Bank of Russia indicators, suspension of transactions under 161‑FZ. More on the fraud monitoring page.
A change of director or shareholders, court cases and bankruptcy, sanctions against the legal entity’s executives. More on the counterparty monitoring page.
A legal-entity customer can be under two checks at once: against lists — here, and for changes at the director and founders — in KYB.
All organisations under art. 5 of 115‑FZ whose customer stays with them for longer than a single transaction: an account, a loan agreement, a brokerage account, a wallet.
The words “continuous monitoring” do not appear in 115‑FZ — it is a FATF standards formula. But the law sets deadlines that start running without your involvement: from the publication of a list, from the appearance of doubts, from the start of a quarter. Regular checks help you not to miss them.
All organisations under art. 5 of 115‑FZ
Customers you already serve, their representatives and beneficial owners
Credit institutions and branches of foreign banks
The price is made up of the checks you run when you onboard a customer and at each repeat check. No subscription fee for checks and no annual licence.
5 ₽
per check: list of terrorists and extremists, passport validity, bankruptcy, register of controlled foreign persons
36 ₽
per check: sanctions and PEP in one request
on request
base size, set of checks and repeat frequency — in a quote tailored to your process
Checks skipped for lack of data are not charged. Prices are in the price matrix. The trial period is 1 month. A set for your base — submit a request, and we will send you a quote.
A repeat check is an API request from your system on a schedule. Comparison with the previous result, urgency and the decision log stay with you: NeuroVision returns the results of checks.
Payment is for completed checks.
Terms found in check results, the log and the internal control rules.
It is a repeat check of customers you already serve against the Rosfinmonitoring lists, IAC decisions, UN lists, sanctions lists and the database of politically exposed persons. Unlike the check at onboarding, it is repeated for as long as the customer stays with you and shows only what has changed. At NeuroVision a repeat check is an API request; the schedule, comparison with the previous result and the decision log are in your system.
Yes. 115‑FZ requires you to check all customers against the list of terrorists and extremists and the UN lists at least once every three months and to report the results to Rosfinmonitoring, and to update customer details at least once a year, for low risk — once every three years. The term “continuous monitoring” itself does not appear in the law: how often to re-check the base between these deadlines is for you to define in your internal control rules.
It depends on how often you run the repeat check: if you run it after every new version of a list, you see the match right after it. Database checks are asynchronous: the request returns a run number, and you get the result by polling every 5–10 seconds. The deadline to freeze — 24 hours — runs from the publication of the list on the Rosfinmonitoring website; the official source is your personal account on that website.
The measures must be lifted no later than the next working day after removal (subpara. 6.1, para. 1, art. 7 of 115‑FZ). Removed list entries are returned separately, so a repeat check shows both the customer’s appearance on the list and their removal. The decision to lift measures is made by a responsible employee of your organisation.
No. NeuroVision returns the result of the check, while the freezing, the report to Rosfinmonitoring and the lifting of measures are carried out by your organisation. Through the API the result can be linked to your system so that the customer’s transactions are stopped until the responsible officer decides.
Keep the baseline result for each customer and the namesake marks in your own system, and compare each new response with the previous one: that way you see only a new match or a status change. If a list entry has changed, a pair closed earlier must be re-checked.
Yes. Each customer goes in a separate request, so your system can send a base of any size in turn, split it into groups by risk level and set each its own set of checks and schedule. Confirm the request limits when you connect.
Customer monitoring answers the question “who is the customer now”: lists, sanctions, PEP, statuses. Transaction monitoring tracks what the customer does: amounts, counterparties, signs of unusual transactions, of which suspicious ones are reported to Rosfinmonitoring no later than three working days. Transactions are handled by KYT, and transfers made without the customer’s consent by fraud monitoring.
Keep the results of repeat checks, matches and decisions in your system’s log with run dates and sources. For a quarter, the data on customers checked and matches found is compiled from it. Your organisation submits the report itself through the Rosfinmonitoring personal account.
A check against the list and other Russian databases costs 5 ₽, international screening with sanctions and PEP — 36 ₽, per the price matrix. A quote for your base, set of checks and repeat frequency is available on request: leave a request and we will send a quote. The trial period is 1 month.
Tell us how many customers you serve and which lists matter to you — we will open trial access and send a quote.
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