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KYC for DFA operators and tokenisation platforms: investor identification before placement and payouts

A DFA operator places digital rights only with identified investors and does not keep anonymous accounts. We recognise the passport with no manual entry, check the face and the document for forgery, find the tax number and check the investor against the Rosfinmonitoring lists and sanctions, and the issuer — by tax number and beneficiaries. The test, the annual amount and the decision stay in your system.

DFA investor identification: passport, lists, sanctions and issuer check
from 29 ₽ document + liveness per KYC session
195+ countries and territories — investors' documents
36 ₽ international screening: sanctions and PEP
5 ₽ the issuer's tax number, list or beneficiary — per check
Passport without entry Document anti-fraud Liveness INN by passport Watchlists and sanctions Issuer by tax number

Russian software register No. 19972 · 152‑FZ

DFA operator under 282‑FZ and 115‑FZ: placement, transfers and the transition from 259‑FZ

From 1 September 2026 the issue, recording and circulation of digital financial assets are regulated by Law No. 282‑FZ “On Digital Currencies and Digital Rights”, and Law No. 283‑FZ added to 115‑FZ for operators: no anonymous accounts, with the payer and recipient data in every transfer.
Operators included in the register under Law No. 259‑FZ work under its rules while they bring their activities into compliance — no later than 1 September 2028.

  • Placement and recording

    282‑FZ, Part 13, 22 of Art. 6, Art. 17; 115‑FZ, para. 5.2-2 of Art. 7

    Investor KYC

    Identification

    • Digital rights are placed at identifier addresses only after identification under 115‑FZ
    • Digital accounts for anonymous persons or under a pseudonym are not kept

    Non-qualified investor

    • Without a positive test — a risk notice and a statement of risk acceptance
    • No more than 300 000 ₽ per calendar year for rights available after testing

    Closed issues

    • Rights intended for qualified investors are not credited to the account of a non-qualified investor
  • Transfers and payouts

    115‑FZ, Art. 7.2-1; 282‑FZ, Art. 27, 35, 36

    Rosfinmonitoring watchlists

    Transfer data

    • Over 60 000 ₽ — the payer's full name, account or identifier address, address, date of birth and tax number
    • Up to 60 000 ₽ — full name and account
    • Without the data the customer cannot dispose of digital rights

    Payouts

    • A payout on digital rights — to a recipient identified under 115‑FZ

    Analysis and list

    • Digital analysis of rights at addresses — before a deal or within three working days
    • A list of holders at the issuer's request — within 15 days
  • Register and transition period

    282‑FZ, Art. 49, 52, 53, 55; 283‑FZ, Art. 22, 23

    Remote identification

    Bank of Russia register

    • An information system operator is a business company from the register
    • A special officer for AML/CFT — under the Bank of Russia requirements
    • A repeated violation of Art. 6, 7, 7.3 and 7.5 of 115‑FZ within a year is a ground for exclusion from the register

    Operators under 259‑FZ

    • Work under the previous rules while they bring their activities into compliance — no later than 1 September 2028

    DFA exchange operators

    • Work under 259‑FZ until 1 March 2027

Information system operator, exchange operator, bank, issuer: who verifies a DFA investor

On the DFA market several participants see the investor at once: the platform, an agent bank, a broker and the issuer. The card shows whose duty it is and where NeuroVision helps.

  • Information system operator

    • The investor — by document and lists before placement at their address
    • An account with no anonymous persons or pseudonyms, data for transfers over 60 000 ₽
    • The payout recipient — identified under 115‑FZ
  • DFA exchange operator

    • Until 1 March 2027 — under the rules of 259‑FZ
    • The buyer and the seller on the secondary market — by document and lists
    • The check scenario does not depend on the register the operator will move to
  • A bank — placement operator or agent

    • The bank's customer is already identified — the test and the amount for a non-qualified investor are added
    • Lists and sanctions — on the same data, with no new form
    • A non-resident — international screening with PEP
  • A broker who sells DFA to customers

    • An order through a broker — the broker passes the payer's data to the operator
    • A customer with simplified identification — full identification by a session link
    • Digital currency broker — separate rules
  • Issuer and tokenisation platform

    • The issuing company — by tax number, director and beneficiaries before the decision on the issue
    • Investors in a closed issue — qualified ones or by the criteria of the decision on the issue
    • Tokenisation of monetary claims, goods and real estate — one KYC scenario
  • A DFA operator's workplace: a monitor with the register of issues and documents on the desk

An individual, a qualified investor, a company, a non-resident: what to collect before the first DFA application

The requirements for an investor depend on their status and on the decision on the issue. The test and the amount are calculated by your system, the investor data for them is supplied by the KYC session.

  • Non-qualified investor

    Passport, face, lists — in one session with no manual entry.

    Without a positive test — a risk notice, a statement of risk acceptance and no more than 300 000 ₽ a year.

    • Part 22 of Art. 6 of 282‑FZ
  • Qualified investor

    The same identification — status does not cancel 115‑FZ.

    Closed issues are available only to them; the status is confirmed in your system, the documents are recognised with no manual entry.

    • Part 8 of Art. 17 of 282‑FZ
  • A company investor

    A company — by tax number: status, director, founders and beneficiaries.

    Representative goes through their own KYC session, the authority under a power of attorney is confirmed by your employee.

    • Art. 7 of 115‑FZ
  • Non-resident

    Foreign national's passport from 195+ countries and territories, lists and international screening with PEP.

    The range of acquirers may be restricted by the decision on the issue.

    • Part 2 of Art. 7 of 282‑FZ
  • An investor with and without a tax number

    INN by passport — for a transfer over 60 000 ₽ and for a digital accounting contract.

    In other cases the tax number is entered in the form where available.

    • sub-para. 1 of para. 1 of Art. 7 of 115‑FZ
  • Payout recipient

    A payout on digital rights — only to an identified recipient.

    An heir or a new owner goes through a session by link before the first payout.

    • Art. 27 of 282‑FZ

DFA investor identification: three steps before placement

The investor goes through the widget in the platform's personal account, the rest goes through the API. A session with liveness takes from seconds to a minute.

Step 1

Passport and liveness in the investor's account

The investor photographs the passport and goes through liveness in a widget on the Web SDK — in a browser or in the WebView of the platform's app. The document type and country are determined automatically, the fields arrive in the form with no retyping, and a forgery or a photo of a screen is flagged at once.

An investor photographs a passport and goes through liveness in the account of a DFA platform
Step 2

Tax number, lists and sanctions

The tax number is found from the passport data, the investor is checked against the list of terrorists and extremists, the foreign agents register and sanctions lists; a non-resident — through international screening with PEP.

Tax number, Rosfinmonitoring lists and sanctions from the investor's passport data
Step 3

Admission to an application in your system

The results arrive in JSON by session identifier. The information system opens an account, requests a test or a risk statement and sends disputed investors to manual review.

An investor card in the information system with admission to an application

Nominee investors, other people's passports and getting around 300 000 ₽: why a DFA operator needs a live person behind every account

One extra passport — another 300 000 ₽ a year

The amount for a non-qualified investor is counted per person. Every extra passport is another 300 000 ₽ a year, and every nominee investor is someone else's money in the issue.

  • 01

    Getting around the amount through relatives

    An investor opens accounts on the passports of relatives to buy more rights without a test. Liveness and face-to-document comparison show that the person in front of the camera is not the passport owner.

  • 02

    A nominee investor

    An issue is bought up by front individuals for a fee — this is how an issuer fakes demand or brings in a third party's money. Lists and PEP — before placement, the investor's link to the issuer is checked by your system.

  • 03

    Bought and stolen passports

    Accounts are opened on lost documents to receive payouts in someone else's name. The validity of the passport against the Ministry of Internal Affairs database and document anti-fraud — before the first application.

  • 04

    A deepfake instead of a face

    Liveness is passed with a video recording or a substituted video stream. Liveness tells a live person from a photo, a screen, a mask and a deepfake in the same session.

  • 300 000 ₽ a year — rights after testing, without a positive test
  • 60 000 ₽ threshold of the full set of payer data in a transfer
  • 15 days the deadline for the list of holders at the issuer's request

DFA operator checklist: investor, issuer, address and payout

Four groups, eighteen lines — from investor admission to payout. The tag shows who closes the line: our check, your system or the Bank of Russia.

  • A Russian passport or a foreigner's document from 195+ countries and territories is recognised from a photo, the fields arrive in the form NeuroVision
  • A photo of a screen, a printout, a pasted-in photo and editing in an editor — before the account is opened NeuroVision
  • Liveness and the face matches the photo in the document NeuroVision
  • The validity of a Russian passport against the Ministry of Internal Affairs database and the tax number from the passport NeuroVision
  • Qualified investor status, a test or a statement of risk acceptance Your system

  • The list of terrorists and extremists and the foreign agents register NeuroVision
  • OFAC, EU, UK and UN sanctions lists NeuroVision
  • A non-resident and a large investor — international screening with PEP NeuroVision
  • A repeated check of the investor base when the lists are updated Your system
  • Qualification requirements for the special officer for AML/CFT Bank of Russia

  • An address in an external network for hybrid rights and withdrawal — checking rules before the operation Your system
  • Transaction monitoring: splitting, transit, linked accounts Your system
  • Payer and recipient data in a transfer of digital rights Your system
  • A payout only to an identified recipient Your system
  • NeuroVision — the line is closed by NeuroVision: document recognition, anti-fraud, liveness, tax number, lists, sanctions and issuer check
  • Your system — a line of your system: form, test, amount, admission and payout rules
  • Bank of Russia — the rule is set by the Bank of Russia

DFA issuer before the issue: company, director, beneficiaries and sanctions

  • Company

    Risk. An issue for a shell company or a company in liquidation — the payouts will not arrive, and the investors will come to the operator.

    NeuroVision. Status, address, director and founders by tax number — 5 ₽ per register.

  • Director and signatory

    Risk. The decision on the issue is signed by the director with an enhanced qualified signature — a nominee director or a person from a list.

    NeuroVision. The director's passport — in their own KYC session, lists, wanted lists and bankruptcy — 5 ₽ each.

  • Beneficial owners

    Risk. Behind the issuer stands a person under sanctions or a politically exposed person.

    NeuroVision. Owners with a share of more than 25 % — against the Rosfinmonitoring list, sanctions and PEP, international screening — 36 ₽.

  • Payouts and issuer default

    Risk. The issuer does not transfer the payout or refuses to perform — the operator receives the refusal and answers to the investors.

    Your system. The rules of the issue and disclosure; we provide verified data on the company and the people behind it.

The issuer is checked before the decision on the issue is registered and again — before payouts. The decision to admit the issue to placement stays with the operator.

Repeated check of a DFA investor: payout, redemption, secondary deal, new lists

DFA live from placement to redemption — months and years. In that time the lists, the investor's documents and the rights holders themselves change.

  • List updates

    Rosfinmonitoring and the sanctions authorities update their lists. The investor base is rechecked against the new versions, matches go to manual review before the nearest payout.

  • Payout and change of details

    Before a large payout or after a change of details — a short session with liveness. This way a person with a stolen password cannot receive the payout.

  • A secondary deal

    Rights pass to a new owner at an exchange operator or by a deal between investors. The new holder goes through KYC before crediting, not after.

  • A change of passport and inheritance

    The investor changed their passport or surname, or the rights passed to an heir. The new document is recognised with no manual entry, the tax number and lists are checked again.

Checks for a DFA operator: catalogue and prices

Each check is enabled separately — by investor and issue type. Payment is for completed requests. All database checks are in the catalogue AML checks.

Document and face

Passport without manual entry, anti-fraud and live presence.

  • OCR · anti-fraud

    Russian passport recognition

    A Russian passport is recognised from a photo: the fields arrive as a JSON response to the platform.

    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
  • KYC

    Liveness and face-to-document comparison

    A check that a live person is in front of the camera, and a comparison of their face with the photo in the document.

    from 29 ₽ per session

    Learn more
  • 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

How much DFA investor identification costs

The price is per one KYC session of one investor and per each database check. No subscription fee, the more checks a year, the lower the price.

  • Document

    from 16 ₽ per session

    Calculate

    A Russian passport or a foreigner's document with no manual entry, anti-fraud: photo of a screen, printout, pasted-in photo, editing. An additional document — 10 ₽.

  • Most popular choice

    Document + liveness

    from 29 ₽ per session

    Enable

    Everything from “Document”, plus liveness, face-to-document comparison and deepfake detection. For opening an account and large payouts.

  • Lists, tax number and issuer

    5 ₽ per check

    Build a set

    Tax number from the passport, the list of terrorists and extremists, the foreign agents register, OFAC, EU, UK and UN sanctions, company, director and beneficiaries by tax number. International screening — 36 ₽.

One session — one person: a company representative goes through their own. At 10 000 checks a year the “Document” session costs 18 ₽ per the calculator. Calculator on the pricing page.

Connecting to a DFA platform: a widget in the investor's account, an API into the information system, a session link

The check is built in where the investor already works: registration, the personal account and the payout screen. The steps are switched on by the scenario rules — passport and liveness at account opening, a repeated liveness on a change of details.

SDK and widget

The Web SDK is embedded in the investor's personal account with one script or an npm package and works in a mobile browser and in WebView — including in the platform's mobile app. The logo, colours, texts and languages are configurable. Documentation

  • Web SDK
  • WebView
  • REST API
  • Session link

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 DFA operators and tokenisation platforms choose NeuroVision

An operator needs a provider that checks both the investor and the issuer — on the same data, with payment for completed checks.

Investor, issuer and lists — in one platform

Passport recognition, liveness, tax number, lists and a company check by tax number and beneficiaries work in one account. The investor's form is filled in with no manual entry.

There is no need to assemble a solution from several vendors and reconcile their responses.

Passport Liveness Tax number API

One platform

Document, liveness, tax number, lists and issuer check — through the Web SDK and the REST API, without several providers.

Liveness

A check that a live person is in front of the camera, not a photo, a screen or a mask.

Payment per check

From 5 ₽ per check, no subscription fee.

A Russian developer

Register of Russian software No. 19972; personal data — under 152‑FZ.

DFA operator glossary: digital rights, issuer, identifier address, testing

In brief, the concepts found in the law, in the information system rules and in the decision on the issue.

Digital financial assets
Digital rights — monetary claims, rights under securities, rights of participation in capital and others — that are issued in the operator's information system.
DFA
Hybrid digital rights
Digital rights that include both digital financial assets and utilitarian digital rights at the same time.
Hybrid tokens
Information system operator
A business company from the Bank of Russia register, in whose information system digital rights are issued and recorded.
DFA platform operator
DFA exchange operator
An organisation that makes deals with DFA or collects the parties' applications; under Law No. 259‑FZ it works until 1 March 2027.
DFA exchange operator
Issuer
A company that makes the decision on the issue of digital rights and answers for them to the holders.
Issuer
Decision on the issue
The issuer's document with the terms of the issue: the rights, the range of acquirers, the payout procedure; signed with the director's enhanced qualified signature.
Terms of issue
Identifier address
A unique sequence of characters at which digital rights are recorded in the information system.
Wallet address
Investor testing
A knowledge check of a non-qualified investor before buying rights available after testing.
Suitability test
Payer and recipient data
The data passed with a transfer of digital rights: full name and account, for amounts over 60 000 ₽ — address, date of birth, tax number.
Travel Rule
Asset tokenisation
An issue of digital rights certifying rights to a monetary claim, goods or another asset.
Tokenization

Frequently asked questions about KYC for DFA operators

Partly. The issue, recording and circulation of digital rights are now regulated by Law No. 282‑FZ “On Digital Currencies and Digital Rights”. Operators included in the register under 259‑FZ work under its rules while they bring their activities into compliance — no later than 1 September 2028, and DFA exchange operators — until 1 March 2027.

Yes. The operator places digital rights at identifier addresses only after identification under 115‑FZ and may not keep digital accounts for anonymous persons or persons under a pseudonym. Payouts on digital rights are also made to an identified recipient.

For rights available after testing, without a positive test the operator credits them after a risk notice and a statement of risk acceptance — no more than 300 000 ₽ per calendar year. The test and the tracking of the amount are done by your system, the identity check can be entrusted to NeuroVision.

The tax number is mandatory for a digital accounting contract, in other cases it is entered where available. For a transfer of digital rights over 60 000 ₽ the operator passes the payer's tax number, if there is one. NeuroVision finds the tax number from the passport data — 5 ₽ per check.

Over 60 000 ₽ — the full name, account or identifier address, address, date of birth and tax number of an individual payer; up to 60 000 ₽ — full name and account. If the data is missing, the operator rules out the customer's ability to dispose of digital rights.

The operator checks the decision on the issue for compliance with the law and answers to investors for payouts through its system. We check the company by tax number, the director and the beneficiaries with a share of more than 25 % — against lists, sanctions and PEP.

Liveness confirms that a live person is in front of the camera and that the face matches the photo in the passport. It tells a live person from a printout, a screen, a mask and a deepfake. This way one investor will not get around the amount using the passports of relatives.

No. We check the investor and the issuer and pass the results to your system. The decision on placement, refusal and reports to Rosfinmonitoring stay with your special officer.

Yes. We recognise passports of 195+ countries and territories and check the investor against sanctions and international screening with PEP. Whether a non-resident may buy a particular issue is determined by the decision on the issue.

Here — digital rights: placement, payouts and the issuer. An exchange and a digital currency broker live under other rules: there is no simplified identification, the tax number is mandatory, and the test and the limit are under Art. 31 of Law No. 282‑FZ.

Yes. The customer is sent a session link: passport, liveness and tax number — with no visit to the office, and for an order through a broker the broker passes the payer's data to the operator. Checks of a securities broker's customers — on the page for brokers and investment platforms.

Document with liveness — from 29 ₽ per session, tax number, lists and issuer checks — 5 ₽ each, international screening — 36 ₽. The test — in the test scenario of the personal account.

We will select checks for your DFA platform

Tell us who your investors and issuers are and how many issues you place. We will assemble a KYC scenario under 115‑FZ and 282‑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

Book a call

The company is included in the register of IT companies and the register of personal data operators of the Russian Ministry of Digital Development.

Address: Moscow, Presnenskaya Embankment 12 — Moscow City business centre, Federation Tower. Nearest metro stations: Delovoy Tsentr and Mezhdunarodnaya.