A message on Friday, 19:12
Denis imports lamps from China for restaurants: an LLC on the simplified tax system, a warehouse in Podolsk, eleven employees. On Friday at 19:12 a message arrived in his online banking chat: within three working days he was to explain the purpose of six months of transactions and attach contracts. A line below, the bank added that remote servicing was restricted.
Salaries and the warehouse rent went unpaid.
Denis spent the weekend opening an account at another bank. On Monday he sent his bank the company charter and a single sentence: “The company conducts lawful business; please lift the restrictions.” A week later the bank refused a payment to a packaging supplier, a week after that a transfer to Denis’s own sole proprietorship. Then a notice of termination of the contract arrived.
Denis’s business is genuine, yet almost every step he took made things worse. Let us look at where the turning points were.
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Who exactly restricted the account
Banks use the word “block” for different things. If the tax authority suspended the operations, that is an inspectorate decision under Article 76 of the Russian Tax Code, and it is lifted on the next working day after the cause is removed. We cover this in a separate analysis of account freezes by the Federal Tax Service.
Under Federal Law No. 115-FZ (Anti-Money Laundering Law) the decision rests with the bank itself: if it suspects money laundering, it may refuse a transaction or restrict online banking, and after two refusals in a year it may terminate the contract. On top of this sits the Bank of Russia’s “traffic light” system. A reference to Federal Law No. 161-FZ (National Payment System Law) on a personal card, by contrast, means the Bank of Russia’s anti-fraud database, which follows a different procedure.
Denis’s Friday was 115-FZ in its mildest form. There is a catch here: according to the Bank of Russia’s clarification, restricting online banking is not a refusal of a transaction, only a limit on the channel. A paper payment order could have been taken to a branch on Monday, and the salaries would most likely have gone out on time.
Five working days for reasons, seven for a reply
After refusing a transaction, the bank must tell the client within five working days the date and the reasons for its decision. The wording is formulaic, along the lines of “the transactions have no obvious economic sense”, but it is a clue. The client may bring documents that remove the suspicion, and the bank replies to them within seven working days (paragraph 13.4 of Article 7 of the law). The Bank of Russia calls this rehabilitation, and there may be several attempts.
What worried the bank in Denis’s case? Revenue from a marketplace and wholesale buyers arrived at the LLC and the same day went to his sole proprietorship as “repayment of a loan”. Taxes looked modest against the turnover, and over six months not a rouble left the company’s account to the supplier in China. For financial monitoring, that is the picture of a transit account.
The explanation was an ordinary one: Denis himself had lent the company the money for the first shipment, and he paid the factory personally by buying cryptocurrency. The bank could not learn this from the phrase “the activity is lawful”. A strong reply looks like a short note about the business, with supporting evidence. Denis’s package should have included:
- contracts with buyers and marketplace reports;
- the loan agreement and a statement showing how the money reached the company;
- the warehouse lease, the staffing table and the tax calculation;
- a written explanation of how, and through whom, the goods were paid for.
The last item is the most awkward. Frankly, paying for imports through a personal cryptocurrency purchase itself raises questions under currency control, and the wording is best settled in advance. But without it the gap in payments cannot be explained.
The Interdepartmental Commission, if the bank does not change its mind
If the bank stands by its position, the next level sits at the Bank of Russia. The Interdepartmental Commission (IDC) includes representatives of the Bank of Russia and Rosfinmonitoring (Federal Financial Monitoring Service); the application is filed through the Bank of Russia’s online reception or by letter. Review takes up to twenty working days, and the decision is binding on the bank.
Where a transaction has been refused, the Bank of Russia allows an application to the commission at any time. It is still unwise to delay: the account may be closed in the meantime.
A month before termination Denis finally turned to lawyers. The bank lifted one of the refusals after a second set of documents, and the other went to the commission. The payment had already lost its point, but the record of a refusal is visible to other banks. If the IDC sides with the client, the bank must notify Rosfinmonitoring that the grounds no longer apply.
Incidentally, a claim for losses from a failed delivery is almost pointless: the law exempts the bank from liability for a refusal under 115-FZ.
The Bank of Russia traffic light: green, amber and red risk groups
Since 1 July 2022 the Bank of Russia has itself assessed companies and sole proprietors on the “Know Your Customer” platform and passes the assessment to banks. It covers about 7.5 million legal entities and entrepreneurs; individuals and the self-employed are not affected. There are three groups: green, amber and red, that is, low, medium and high risk.
Low risk protects you if the bank rates the client the same way: such a company cannot be refused an account under 115-FZ or have its contract terminated because of two refusals, and its transfer to a low-risk recipient cannot simply be stopped.
The red zone applies when high risk has been assigned by both the Bank of Russia and the servicing bank. Debits stop, cards and online banking are switched off, and the balance is not paid out when the account is closed. Taxes, salaries to existing employees within the previous month’s amount, and payments on old loans still go through. An entrepreneur is left up to RUB 30,000 a month for themselves and for each non-earning family member. The bank reports the measures within five working days.
From that moment a six-month period runs for applying to the IDC. If the deadline is missed, or the commission rules against you and the court does not help, the Bank of Russia passes the information to the Federal Tax Service, and the company is struck off the Unified State Register of Legal Entities, or the sole proprietor from the register of individual entrepreneurs. According to the Bank of Russia’s clarification, the director and any participant holding more than 50% are then barred for three years from registering new companies and sole proprietorships.
It is milder when only the Bank of Russia has assigned high risk and the bank has restricted nothing: then a review is requested from the Bank of Russia through its online reception, with a reply in fifteen working days. A check by taxpayer number (INN) is available on the Bank of Russia website.
The bank terminated the contract: what happens to the money
Two refusals of transactions in a calendar year give the bank the right to terminate the account contract, and Denis collected them in three weeks. On this ground the contract cannot be terminated with individuals or with clients the bank itself considers low-risk.
The contract is deemed terminated sixty days after notice, and until then only bank fees, payments to the budget and the return of the balance go through the account (Article 859 of the Russian Civil Code). The balance is paid out or transferred to another account within seven days of a written application. Without instructions from the client, after sixty days the money goes to a special account at the Bank of Russia, from which it is returned through the same bank.
Did the new account opened at the weekend help Denis? No. Banks report refusals to Rosfinmonitoring, the Bank of Russia passes this information to all banks, and they take it into account in assessing risk. A month later the second bank requested documents from Denis too.
Personal card, P2P and crypto exchange
The bank restricted Denis’s personal card as well. Over six months dozens of transfers from strangers and back passed through it: this is what buying USDT on a P2P platform looks like. The Bank of Russia’s 2021 recommendations mention “cryptocurrency exchangers” directly, and the examples of indicators include more than 10 counterparties or 30 transactions a day, and turnover above RUB 100,000 a day or RUB 1 million a month. The bank should be alerted when two or more indicators coincide.
A bank cannot terminate an account contract with an individual under 115-FZ, but it can refuse a transaction and restrict online banking. The appeal route is the same. An individual is helped by the trade history on the platform and an explanation of where the roubles came from. On the questions banks ask about transfers abroad, we wrote in the article on currency control for individuals.
If the notice mentions 161-FZ, your details have entered the Bank of Russia’s database of transfers made without the client’s consent. They can be removed through your own bank or the Bank of Russia’s online reception within fifteen working days, and meanwhile you can access your money at a branch with your passport.
The general backdrop has changed too. Since July 2025 Article 187 of the Russian Criminal Code has punished money mules: handing over your card for a reward carries up to three years’ imprisonment, and buying up other people’s cards up to six. And from 1 September 2026 Rosfinmonitoring receives data on transfers through the Faster Payments System (SBP) directly from NSPK.
When you cannot do without a lawyer
If the bank asks about a couple of transactions and the business is transparent, you can answer yourself, provided the reply is detailed and backed by documents. It is harder when there are already two refusals and a termination notice has arrived, or the company has been placed in the red group. Or when the history contains payments that are hard to explain without tax consequences.
In such cases we establish what the bank saw, prepare explanations with documents, and, if it refuses, go to the commission and the court. How our work on unblocking a current account is organised is described on a separate page. To prevent a repeat, you need compliance: a review of the payment pattern before the bank asks questions. We record the plan and the cost of the work in writing before we begin.
Frequently asked questions
How long does unblocking under 115-FZ take?+
There is no single deadline, but each stage has its own. The bank gives its reasons for refusal within five working days, replies to documents within seven, and the Interdepartmental Commission reviews an application within up to twenty working days.
Will an account at another bank help?+
Only briefly. All banks receive information on refusals through Rosfinmonitoring and the Bank of Russia, and high risk on the Bank of Russia platform is visible to any of them.
Can a bank close an individual’s account under 115-FZ?+
Not because of two refusals in a year: the law excludes individuals from that rule. But it may refuse a transaction and restrict online banking.
How can I find out whether a company is in the red group?+
The Bank of Russia website offers a free check by taxpayer number (INN). If the bank has applied restrictions, it will report them within five working days, and from the following day a six-month period runs for applying to the IDC.
Need an assessment of your situation?+
Send a request: a lawyer will review the bank’s notices and statements and tell you what stage the matter is at and which deadline must not be missed.