The data for a client file under 115‑FZ without manual entry: the passport and documents are read, the client is checked against the Rosfinmonitoring watchlist, sanctions and PEP lists, and the company and the other side of the deal by tax number. Before you draft the contract.
Data stored in Russia · Russian software registry no. 19972 · 115‑FZ and 152‑FZ
Advocates and those who provide legal services as a business are subjects of 115‑FZ under article 7.1, but only for certain client transactions. Below is when the law applies to you and what it requires.
NeuroVision supplies the data for screening the client. The internal control rules, the decision whether to take the client on, freezing and reports to Rosfinmonitoring are set and carried out by the lawyer.
Quarterly reconciliation of the whole client base against the watchlist, mandatory control and suspension of transactions do not apply to advocates and law firms — those are duties of the organisations under article 5.
115‑FZ art. 7.1(1) — if the lawyer prepares or carries out a transaction on behalf of or on the instructions of a client.
115‑FZ arts. 7 and 7.3 — to the extent set out in art. 7.1.
115‑FZ arts. 7 and 7.1; Government Decrees No. 1180 and No. 131.
In a legal practice, 115‑FZ compliance is usually run by the partner or an assistant, with no financial monitoring department. These are the tasks NeuroVision takes on.
The passport is read without manual entry and its validity checked against the Interior Ministry's database: an expired, replaced or lost document shows up before the first meeting about the deal.
Most often enabled:
By tax number: status in the state registers, signs of a shell company, account freezes, court cases and debts. The director and shareholders — with no namesakes and with a nominee check.
Most often enabled:
The client, their representative, the shareholders and the beneficial owner the client has named — against the terrorist and extremist list. The result, with the date of the check, goes into the client file.
Most often enabled:
International sanctions lists, politically exposed persons and their close associates, adverse coverage — for clients and beneficial owners, foreign ones especially.
Most often enabled:
The seller of a flat, the target company in a business purchase and their directors — bankruptcy, enforcement proceedings, commercial court cases and wanted lists, before the contract is signed.
Most often enabled:
Passports and documents from 195+ countries and territories are read without manual entry, and handwritten forms by your own form template. The scan is checked for forgery and traces of editing.
Most often enabled:
The buyer and the seller from their passports: validity, the watchlist, sanctions. The seller — bankruptcy and enforcement proceedings: a bankrupt's deal can be challenged. A corporate seller — by tax number.
The target company and its members by tax number: status, court cases, tax arrears, nominee directors. The buyer, the shareholders and the named beneficial owners — against the watchlist, sanctions and PEP lists.
Before you manage a client's funds — the passport, the watchlist, sanctions and PEP lists. When the information is updated, the same checks run again on the same data.
Which transactions call for a check is decided by article 7.1 and your internal control rules.
NeuroVision supplies the data for every deal.
The checks are launched from your CRM, your client spreadsheet or the NeuroVision console. The result arrives before you start drafting the deal documents.
The client sends a photograph of their passport or brings the document to the meeting. The fields are read without manual entry; for a company the tax number is enough — the director and shareholders are pulled from the register.
Passport validity, the Rosfinmonitoring watchlist, sanctions and PEP lists, the company's status, and the other side's bankruptcy and court cases — only what your internal control rules call for.
Every check returns «passed», «not passed» or «not enough data», with its source, date and the records found. The decision whether to take the client on and the reports to Rosfinmonitoring remain yours.
The list of transactions and duties is the same for an advocate and a law firm — article 7.1. What differs is supervision, legal professional privilege and liability.
| Criterion | An advocate | A law firm or a sole trader |
|---|---|---|
| When 115‑FZ applies | for the transactions in art. 7.1 | for the same transactions |
| Client checks and watchlists | yes | yes |
| AML/CFT supervision | the regional bar chamber | — |
| Registration with Rosfinmonitoring | not required | not required |
| The Rosfinmonitoring online portal | needed for reporting | needed for reporting |
| Reporting suspicions and replying to requests | except information covered by legal professional privilege | in full |
| Internal control rules | Decree No. 1180 | Decree No. 1180 |
| Liability | — | art. 15.27 of the Code of Administrative Offences; a sole trader is treated as a legal entity |
Every check is enabled separately and you pay for the requests performed. Descriptions, sources and response fields are in the API check catalogue.
The client under 115‑FZ
The client's document, the mandatory watchlist and the international lists.
Passports and documents from 195+ countries and territories are read without manual entry; the name in Latin script comes from the MRZ.
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 moreScreening against the list of people involved in extremist activity or terrorism. A mandatory check under 115-FZ.
5 ₽ / check
Learn moreScreening 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 moreInternational 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 moreA 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 moreThe client company and the target company
Status, signs of a shell company and the people behind it.
A company is checked against the state register of legal entities and a sole trader against the register of sole traders: whether it is active, whether it is being wound up, when it was registered, and who the director and shareholders are.
A flag that the person is listed as a nominee or serial company director.
5 ₽ / check
Learn moreA person's links to legal entities: where they are a shareholder or a director, and whether they hold sole trader status.
5 ₽ / check
Learn moreTax authority decisions suspending account operations: the date, the decision number and the reason for the freeze.
5 ₽ / check
Learn moreA history of disputes from the commercial court case file, bankruptcy cases included. Matching is done by tax number, so namesakes never reach the results.
5 ₽ / check
Learn moreAn individual's outstanding debt on taxes and payments administered by the tax service.
5 ₽ / check
Learn moreThe seller, the buyer, a party to the deal
Bankruptcy, debts, court cases and wanted lists, before signing.
A search of the federal bankruptcy register: personal bankruptcy cases filed and completed. By tax number the result is unambiguous.
5 ₽ / check
Learn moreActive enforcement proceedings from the bailiffs' database: the amounts owed, the claimants, the type of recovery and an estimate of how close the person is to bankruptcy given their total debts.
5 ₽ / check
Learn moreClaims, debt recovery and administrative offences — a search for proceedings in the courts of general jurisdiction.
5 ₽ / check
Learn moreA search for criminal cases across courts of general jurisdiction nationwide, the Moscow courts included. Results are split into exact matches on the full name and probable namesakes.
5 ₽ / check
Learn moreA 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 moreThe scan of the document is checked for forgery and traces of editing: fonts, fields, photographs taken off a screen.
Checks against databases and lists carry a fixed price per request, with no subscription fee. It suits a practice with ten deals a year as well as a firm with a stream of corporate clients.
5 ₽ per check
The Rosfinmonitoring watchlist, passport validity, sanctions lists, nominee director and the other side's bankruptcy — each on its own.
50 ₽ per package (3.125 ₽ per check)
16 checks from the passport of a client or a seller: passport validity, the watchlist, sanctions, wanted lists, debts, bankruptcy and court cases. Bought separately they cost 80 ₽.
36 ₽ per check
PEP lists, sanctions lists from more than 50 countries, regulatory actions and adverse media — for clients, beneficial owners and company directors.
Document recognition and anti-fraud are priced separately — we will quote for your volume.
A small practice gets by with one-off checks; a firm with a stream of clients uses the API from its CRM. Client data can stay inside your own perimeter.
Payment for the checks performed, with 24/7 support.
A lawyer needs a supplier that checks both the person and the company, understands 115‑FZ and does not charge a subscription for occasional deals.
A trading company with a clean history may have a bankrupt director or a shareholder on a sanctions list.
NeuroVision brings the passport, the watchlists, sanctions and the check by tax number into one answer — no checking the client in five services and copying the results into the form by hand.
A Skolkovo resident; the platform is entry no. 19972 in the Russian software registry.
115‑FZ, beneficial owners, politically exposed persons and company checks — on our blog.
Yes, but not always. Under article 7.1 the duties arise when an advocate or a firm prepares or carries out, on behalf of or on the instructions of a client, a real estate deal, manages the client's money, securities, accounts or property, forms companies, runs them or buys and sells them. You must then identify the client and the beneficial owner, check against the watchlist and keep internal control rules.
No. Identification is carried out by the lawyer under their own internal control rules. NeuroVision reads the documents and checks the client and the company against the databases, the watchlist, sanctions and PEP lists — you attach those results to the client file.
The list of transactions and duties is the same — article 7.1. But advocates are supervised on this point by the bar chambers, and neither reports of suspicion nor replies to Rosfinmonitoring requests extend to information covered by legal professional privilege.
No; the quarterly reconciliation is a duty of the organisations under article 5 and is not in the article 7.1 list. But if a client or their property appears on the watchlist, freezing measures must be taken within 24 hours of publication and reported to Rosfinmonitoring within one working day. Checking a client against the watchlist takes a single request.
Registration is mandatory for the organisations under article 5 that have no sectoral supervisor; the persons under article 7.1 do not go through it. An account on the Rosfinmonitoring website is needed, though: reports of suspicious transactions and of freezing are sent through it.
Under article 15.27 of the Code of Administrative Offences, breaches of internal control draw a warning or a fine of 50 000 to 100 000 ₽ for an organisation; failure to apply freezing measures draws 300 000 to 500 000 ₽ or suspension of activity for up to 60 days. A sole trader is liable as a legal entity.
By tax number — status, signs of a shell company, court cases, debts, and the director and shareholders from the state register. The beneficial owner you establish yourself from the client's documents, and NeuroVision checks the named persons against the watchlist, sanctions and PEP lists.
Partly. A check by tax number shows the shareholders from the state register, and compliance screening shows sanctions and PEP status. Whether the deal needs clearance under Presidential Decrees No. 81 and No. 618 is for the lawyer to decide: NeuroVision does not assess that.
Checks against databases and lists cost from 5 ₽, a package of 16 checks from a passport costs 50 ₽ and compliance screening 36 ₽. Document recognition and anti-fraud are quoted individually. Test access lasts 1 month.
Tell us which deals you advise on, how many clients a month you have and whether foreign clients and companies come up — we will assemble the set of checks 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 callThe company is included in the register of IT companies and the register of personal data operators of the Russian Ministry of Digital Development.
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