Account Blocking Under 115-FZ: Why a Bank Blocks a Company and How to Lift the Restrictions

“My account was blocked under 115-FZ” is a phrase behind which, in practice, there is one of several different measures: the bank may refuse a single transaction, terminate the account agreement, suspend a transaction for five business days, or fully stop debits from the account if both the bank and the Bank of Russia have independently placed the company in the high-risk group. Each measure has its own ground, its own appeal procedure, and its own time limit. Let’s look at which measure the bank applied in a specific case, what the company is entitled to do in response, and how the two appeal routes differ — through the bank itself and through the interdepartmental commission under the Bank of Russia.

115-FZ Has No Word for “Blocking” — There Are Six Different Measures

The word «блокировка» (“blocking” in the everyday sense) does not appear in Federal Law No. 115-FZ “On Combating the Legalization (Laundering) of Proceeds from Crime and the Financing of Terrorism.” The root «блокир-» almost always occurs in the pair «замораживание (блокирование)», “freezing (blocking)” — this is how two terms of Article 3 are named, for different objects (the full wording is in the box below).

Freezing (blocking) is a measure against three different circles of persons: those included in the list of persons involved in terrorism or extremist activity; those in respect of whom a decision to freeze has been made by a separate interdepartmental coordinating body for combating the financing of terrorism — not to be confused with the interdepartmental commission under the Bank of Russia discussed in this article; and those included in the UN Security Council lists linked to terrorist organizations and terrorists or to the proliferation of weapons of mass destruction. None of these measures concerns most companies.

What is colloquially called “the bank blocked the account” the law describes in other words and through at least six different measures, each with its own ground, its own procedure, and its own time limit:

Next — each measure separately: who applies it, under what condition, and how the company can have it lifted.

Refusal of a Transaction, Refusal to Open an Account, and Termination of the Agreement

The most common measure is refusal to carry out a transaction under Article 7(11): the bank is entitled to refuse, including on the customer’s instruction, if, as a result of internal control, the bank has suspicions that the transaction is related to the legalization of proceeds or the financing of terrorism. The decision is made by the head of the organization or persons specially authorized by the head — not by an ordinary teller.

Separately from refusal of a transaction, the law gives the bank the right to refuse to conclude an account agreement and to terminate an agreement already concluded (Article 7(5.2)). The condition for refusing an account is the same suspicion as for refusing a transaction. The condition for termination is two or more decisions to refuse a transaction within a calendar year.

Both of these measures — refusal of an account and termination — share a common exception: the bank is not entitled to apply them either to a customer who is an individual or to a customer that is a legal entity or individual entrepreneur (IP) whom the bank itself has placed in the low-risk group. For a customer in the low-risk group, refusal of an account and termination on this ground are closed.

None of refusal of a transaction, refusal of an account, or termination of the agreement is called “blocking” by the law — and none of them entails the bank’s civil liability for the fact of refusal itself (Article 7(12), Article 7(5.2), paragraph 4).

The third measure on the same ground is refusal to accept for service (Article 7(2.2)): here the bank is required to refuse, not merely entitled, and only in one case — if mandatory identification of the customer has not been carried out. If identification is not required by law at all, this obligation does not apply at all (Article 7(2.2), paragraph 2).

Suspension: Five Business Days at the Bank, Up to 30 Days at Rosfinmonitoring

Suspension is a measure separate from refusal, and it has two levels.

The bank itself suspends for five business days (Article 7(10)), but only a transaction in which one of the parties is a person directly linked to a freeze that has already been announced: a legal entity directly or indirectly owned by or controlled by a person on the list, or a person acting on its behalf or at its direction, or an individual in the specific cases of Article 6(2.4)(3) and Article 7.4(4), paragraph 1. Crediting money to the account is not covered by this suspension — only debits and outgoing transactions are suspended.

If the Federal Financial Monitoring Service (Rosfinmonitoring) has not issued its own order within these five business days, the bank is required to resume the transaction — the suspension is not extended automatically (Article 7(10)).

After that, the decision is made by Rosfinmonitoring, and here there are two different time limits depending on the ground:

• based on information about a transaction suspended by the bank — an order for a period of up to 30 days (Article 8(3));
• on its own initiative, when there are sufficient grounds to believe that the funds were obtained by criminal means — a decision for a period of no more than 10 days; if the ground is information from a competent authority of a foreign state, a period of up to 30 days (Article 8(10) and (13)), and only within the amount presumably obtained by criminal means (Article 8(11)). Rosfinmonitoring is required to inform the company of the grounds for such a suspension within three business days after the company’s application (Article 8(16)).

When the Account Really Stops Working: High Risk at Both the Bank and the Bank of Russia

Closest to the everyday understanding of “the account is blocked” are the measures of Article 7.7(5). This is the strictest measure of all, and it has a compound condition of three parts at once:

1. the bank uses the Bank of Russia’s information on risk groups (Article 7.6(1), paragraph 2) — using this information is voluntary for the bank, and even when using it, the bank is entitled to rely on it only as an additional factor in its own assessment of the customer’s risk, not as a ready-made decision;
2. the customer has been placed in the high-risk group both by the bank itself and, independently of it, by the Bank of Russia;
3. the customer is a legal entity or IP registered under Russian law, except credit institutions, branches of foreign banks, state bodies, and local self-government bodies.

This mechanism does not concern individuals at all — neither customers who are citizens nor accounts opened in the name of an individual.

If all three conditions coincide, the bank (Article 7.7(5)):

• does not carry out debits from the account or reduce the electronic money balance, does not let transfers through the Faster Payments System (SBP), and does not issue cash;
• does not pay out the balance upon termination of the agreement;
• stops the use of the electronic means of payment linked to the customer.

At the same time, the company can still carry out a closed list of transactions even under high risk (Article 7.7(6)): payment of taxes, fees, and insurance contributions; salaries to employees — but not above the amount for the previous month; payments under labor guarantees, alimony, compensation for harm to life and health; payments under a credit agreement concluded before the measures were applied; for an IP — up to ₽30,000 per month for themselves and for each family member living with them who has no independent source of income; transactions in bankruptcy and liquidation procedures — within these procedures.

The bank is required to inform both the Bank of Russia and the customer itself of the application of the measures no later than five business days (Article 7.7(8)) — indicating the criteria for placement in the high-risk group and the right to apply to the interdepartmental commission.

Separately, the law protects customers from the reverse situation — a refusal to make a transfer to a recipient who has already been checked (Article 7.7(2)):

If both conditions coincide, the bank is not entitled to refuse the transfer.

The exception is the same suspicion under internal control: the bank is entitled to refuse, but not to a state body or a local self-government body — the exception does not extend to them. For a customer it has refused, the bank is required to change the risk level no later than the business day following the day of refusal (Article 7.7(2), paragraph 4).

Time Limits a Company Should Know: Five, Seven, Fifteen, Twenty Business Days

Different time limits apply in situations of different nature, and they must not be confused:

• 5 business days — the bank is required to inform the customer of the date and reason for refusing a transaction, refusing an account, or terminating the agreement (Article 7(13.1-1)); the same period applies to notification of the application of the measures of Article 7.7(5) (Article 7.7(8));
• 7 business days — the bank is required to review the documents the customer has provided to rebut the refusal and to report whether the grounds have been eliminated or not (Article 7(13.4)). This provision concerns refusal of a transaction and refusal of an account — termination of the agreement is not mentioned in it;
• 15 business days — the period within which the Bank of Russia is required to consider an application for review of a high risk level and report its decision, if the measures of Article 7.7(5) have not yet been applied to the company (Article 7.8(1.1)) — this is a separate, earlier route, available before the account has actually stopped working;
• 20 business days — the maximum period for the interdepartmental commission under the Bank of Russia to consider an application, counted from the day of the application (Article 7(13.5));
• 6 months — the period within which an application can be submitted to the commission regarding the measures of Article 7.7(5) — separate from the 20-day consideration period, this is the period for submission (Article 7.8(1)).

How to Challenge the Decision: Two Different Routes Through One Commission

The law has two different appeal branches, and they have different grounds, different submission deadlines, and different sets of documents. Confusing them means losing time on an application sent to the wrong address.

The first branch — refusal of a transaction or of an account. First, the customer applies to the bank itself with documents rebutting the ground for refusal (Article 7(13.4), seven business days for the bank’s response). This step cannot be skipped by going straight to the commission: the right to apply to the interdepartmental commission arises only after the bank has expressly reported that it is impossible to eliminate the ground — this is a direct condition of Article 7(13.5), not a formality. After such a report, a customer of a bank supervised by the Bank of Russia is entitled to apply to the interdepartmental commission established under the Bank of Russia — consideration takes up to 20 business days, and the commission’s decision is binding on the bank (Article 7(13.6)). Before that, the commission is required to request a reasoned justification of the refusal from the bank — the customer’s application by itself does not automatically decide the matter in the customer’s favor.

The second branch — the measures of Article 7.7(5) in case of high risk. Here there is no need to apply to the bank: an application stating that there are no grounds for these measures is submitted directly to the same commission under the Bank of Russia, but with a separate list of documents and within six months of receiving information about the measures (Article 7.8). Separately, a company that the Bank of Russia has placed in the high-risk group, but to which the measures of Article 7.7(5) have not yet been applied, is entitled to challenge the placement in the risk group itself directly — by an application to the Bank of Russia, which is required to respond no later than 15 business days (Article 7.8(1.1)).

The composition of the commission — according to the law, not according to the description on the regulator’s website. The commission provided for by Article 7(13.5) includes representatives of the Bank of Russia and of the authorized body — this is the entire composition named by the provision itself. When applications under the second branch specifically (Article 7.8) are considered, representatives of the Federal Customs Service (FTS) take part — within the same multilateral cooperation agreement; the Commissioner for the Protection of Entrepreneurs’ Rights and associations of credit institutions are entitled to participate in the same procedure by joining the same agreement — for them this is a right, not a mandatory condition of consideration.

If the company did not apply to the commission within the established period, lost in court, or received a refusal from the commission and did not challenge it in court, the Bank of Russia is required to transfer information about the company to the body that maintains the register of legal entities and individual entrepreneurs for removal from the register (Article 7.8(4)) — that is, an unused right of appeal under the second branch ends with the compulsory removal of the company from the Unified State Register of Legal Entities (EGRUL) or the Unified State Register of Individual Entrepreneurs (EGRIP), not merely with the measures remaining in place.

The Bank of Russia itself runs the platform called “Know Your Customer”; this name does not appear in the text of 115-FZ — the law refers to the same mechanism as the Central Bank information provided for by Article 7.6(1), paragraph 2. How placement in risk zones on this platform works, and how to challenge the risk level specifically rather than the consequences for the account, is covered in the article “The Bank of Russia’s Know Your Customer Platform: What a Risk Zone Means for a Company”.

What to Do If the Bank Has Applied a Measure

What a Company Is Required to Provide to the Bank

Customers are required to provide the bank with the information needed to comply with the requirements of 115-FZ, including information on beneficiaries, founders, and beneficial owners (Article 7(14)). The law contains no closed list of documents the bank is entitled to request for this purpose — the specific content of the request is determined by the bank’s internal control rules, and these are not published.

This is not the same list as the one submitted to the interdepartmental commission: there, the company attaches documents in the form established by the Bank of Russia in a separate act (Article 7(13.5), paragraph 3) — a closed set of information and documents specifically for the application to the commission, not a list of what the bank is entitled to ask for in the course of servicing.

The Risk-Based Approach: How a Bank Arrives at a High-Risk Decision at All

The bank is required to place each customer in one of three risk groups — low, medium, or high — and to take measures to mitigate risk in accordance with its own internal control rules (Article 7(1)(3.1) and (3.2)). Separately and independently of the bank, the Bank of Russia places each legal entity and IP in one of the same three risk groups (Article 9.1 of Federal Law No. 86-FZ “On the Central Bank of the Russian Federation (Bank of Russia)”) — the criteria for this placement are not disclosed in the law itself; they are established by an act of the Bank of Russia.

For a bank that is part of the anti-money-laundering system, this means that formal compliance of documents does not replace an assessment of the customer’s risk. The full circle of organizations that 115-FZ obliges to build such an assessment, and what exactly the law requires of them beyond working with a bank account, is covered in the article “115-FZ: What Businesses Are Required to Do and How to Meet the Law’s Requirements”. Part of the assessment itself is checking the source of the customer’s funds — more in the article “Source of Funds: What a Bank Is Entitled to Request and How to Confirm It”; another part is checking the customer itself against state databases — more in the materials on the AML check of an individual, and checking the company’s counterparty when opening an account or for a large transaction — in the materials on the KYB check. Companies outside the circle obligated by law strengthen such checks at their own discretion — why to do this and what it gives a business is covered in the article “KYC in 2026: Why Businesses Need to Strengthen Customer Verification”.

How This Differs From Blocking Under 161-FZ

115-FZ and Federal Law No. 161-FZ “On the National Payment System” regulate different situations. 161-FZ covers cases of money transfers without the customer’s consent — fraudulent transactions and attempts to withdraw funds through nominee accounts — not anti-money-laundering control. If a transaction or an account has been suspended specifically on the grounds of a transfer without the customer’s consent, rather than on suspicion of the legalization of proceeds, this is a different law and a different procedure for lifting the restrictions, covered in detail in the article “Blocking Under 161-FZ for Companies and Individual Entrepreneurs: What the Bank Suspends, How the Bank of Russia Database Works, and How to Get Out of It”.

FAQ

What Does “the Bank Blocked My Account Under 115-FZ” Mean?

Legally, it is any of several different measures, not one: refusal of a specific transaction, refusal to open an account or termination of the agreement, suspension for five business days, suspension by decision of Rosfinmonitoring, or — the strictest option — high-risk measures under Article 7.7(5), when the account stops accepting debits, SBP transfers, and cash withdrawals.

How Much Time Is There to Challenge the Bank's Refusal?

After a refusal of a transaction or of an account, Article 7(13.4) does not set a time limit within which the customer must submit documents to the bank itself — the bank has seven business days to respond. If the bank has not removed the ground, Article 7(13.5) likewise does not name a time limit for applying to the interdepartmental commission under the Bank of Russia; the commission's own consideration takes up to 20 business days. For high-risk measures under Article 7.7(5), a separate period for submitting an application applies — 6 months from the day information about the measures was received.

Can a Bank Block an IP's Account the Same Way as a Company's Account?

Yes, if the IP is registered under Russian law: the provisions of Article 7(5.2) and (11), as well as the measures of Article 7.7(5), expressly extend to individual entrepreneurs as well. The measures of Article 7.7(5) do not concern individuals without IP status at all.

Can Money Be Withdrawn From an Account to Which High-Risk Measures Have Been Applied?

Not fully, but a closed list of transactions is still permitted: payment of taxes and insurance contributions, salaries to employees within the previous month's amount, payments under labor guarantees, payments on loans concluded before the measures were applied, and for an IP — up to ₽30,000 per month for themselves and for each family member living with them without an independent source of income.

Which Commission Should One Apply To — at the Bank or at the Bank of Russia?

The interdepartmental commission that considers both types of applications is one — it is established under the Bank of Russia, not at the customer's bank. By law, it includes representatives of the Bank of Russia and of the authorized body; for applications regarding high-risk measures, representatives of the FTS also take part in the consideration, and the Commissioner for the Protection of Entrepreneurs' Rights and industry associations are entitled to join the same procedure at their own discretion.

What Happens If One Does Not Apply to the Commission in Time?

For the measures of Article 7.7(5), the consequence is not limited to the measures remaining in place: if the company did not submit an application within six months, lost in court, or did not challenge the commission's refusal, the Bank of Russia is required to transfer information about it to the body that maintains the register of legal entities and IPs for removal of the company from EGRUL or EGRIP.