METHODOLOGICAL RECOMMENDATIONS OF THE BANK OF RUSSIA NO. 1-MR OF MAY 20, 2026 CONCERNING DETERMINATION OF THE SOURCES OF ORIGIN OF CREDIT INSTITUTIONS' CUSTOMERS' FUNDS TO STRENGTHEN CONTROL OVER CASH TRANSACTIONS
As part of supervision of credit institutions by the Bank of Russia, it has revealed an increase in the amount of cash transactions carried out through credit institutions, the possible real goals of which are the legalisation (laundering) of proceeds from crime and other illegal purposes.
The Financial Action Task Force (FATF) Recommendations pay increased attention to customer due diligence measures (hereinafter referred to as CDD), including the identification of information about the source of funds in individual cases 1.
In accordance with the FATF Recommendations 2 some of the CDD measures that shall be taken by financial institutions are to conduct an ongoing due diligence of business relationships and a thorough analysis of transactions made within such relationships to ensure that the transactions are consistent with the financial institution's information about the client, its business activities and the nature of risks, including when necessary about the source of funds. In so doing, it is noted that there are circumstances characterised by a higher risk of money laundering or terrorist financing and requiring the adoption of enhanced CDD measures. In this context, the intensive use of cash settlements is identified as one example of potentially high-risk factors associated with a client 3. If there is an increased risk of legalising (laundering) proceeds from crime or financing terrorism, financial institutions are required to take enhanced CDD measures in accordance with the identified risks. One example of enhanced CDD measures that can be applied by financial institutions to business relationships characterised by increased risk is to obtain information about the source of funds or the source of the client's wealth 4.
I. In accordance with these Methodological Recommendations, in order to improve the effectiveness of the Russian anti-legalisation system and counter illegal financial transactions with cash, the Bank of Russia recommends that credit institutions analyse customer transactions on a daily basis, paying special attention to the following:
1. The presence of one of the following characteristics in relation to the operations of individual clients:
significant amount of cash deposits to an individual client's account (e.g., in the total amount of at least five million roubles within 30 days) and a high proportion of such transactions (e.g., at least 70% of the client's credit turnover excluding transfers of own funds), followed by their expenditure over a short period of time (e.g., within 10 days) by making significant transfers abroad (e.g., in the total amount of at least 70% of the amount of cash deposited);
a large number of operations for depositing significant amounts of cash into the account of an individual client (e.g., at least 10 operations, each of which is worth at least 100 thousand roubles within 30 days), followed by their spending over a short period of time (e.g., within 10 days) by making a significant amount (e.g., in the total amount of at least 70% of the amount of cash deposited) of transfers abroad;
a significant amount of transactions of a customer, an individual who is a payer, for transferring funds without opening a bank account by providing cash for crediting to the bank account of a legal entity (e.g., in the total amount of at least five million roubles within 30 days), if the credit institution has reason to believe that the actual purpose of the transaction by the individual is a payment under a contract for a third legal entity (e.g., a payment by an individual for a non-resident in favour of a Russian legal entity).
These criteria shall not apply to individual clients in respect of whom the credit institution has documented information about the financial situation, business reputation and sources of origin of funds and/or other property of such clients.
It is recommended that credit institutions review the total and participatory values of these transactions at least once every three months and update them if necessary.
2. The presence of one of the following characteristics in relation to the operations of clients - legal entities or individual entrepreneurs:
depositing cash in an amount equal to or exceeding 30 million roubles to the account of a client who is a non-resident legal entity within 30 days;
depositing cash to the account of a client who is a resident legal entity or an individual entrepreneur within 30 days in an amount equal to or exceeding 30 million roubles, provided that this amount significantly exceeds the average monthly turnover on the accounts of this client who is a legal entity or an individual entrepreneur for the previous three months;
depositing cash to the account of a client who is a resident legal entity or an individual entrepreneur within 30 days in an amount equal to or exceeding 30 million roubles, provided that previously transactions on the accounts of this client who is a legal entity or an individual entrepreneur were carried out primarily in non-cash form or carried out by a legal entity or an individual entrepreneur whose activity does not involve intensive use of cash payments.
II. In accordance with these Methodological Recommendations, in order to minimise the risk of credit institutions being involved in transactions conducted by their clients, the actual purposes of which are the legalisation (laundering) of proceeds from crime and other illegal purposes, the Bank of Russia recommends that credit institutions:
1. When identifying the operations of clients with the bank that meet the specified criteria:
implement the right provided for in Subitem 1.1 of Item 1 of Article 7 of Federal Law No. 115-FZ of July 8, 2001 on Countering the Legalisation of Earnings Received in an Illegal Way (Money Laundering) (hereinafter - Federal Law No. 115-FZ) to determine the sources of origin of customers' cash;
review the assessment of the degree (level) of risk of the client committing suspicious transactions in the direction of its increase (medium or high degree (medium or high level) of risk);
consider the issue of classifying the client's operations or the totality of operations and/or actions of the client (his representative) related to their conduct as suspicious in order to promptly inform the authorised body about such operations in accordance with Item 3 of Article 7 of Federal Law No. 115-FZ;
consider the issue of implementation in relation to a transaction with cash, of the right provided for in Item 11 of Article 7 of Federal Law No. 115-FZ.
If a decision is made to classify a client's operation as suspicious, or if the client is not allowed to conduct an operation and information on such operation or refusal is sent to the authorised body, credit institutions are recommended to indicate the type code 1499 5, given in the Annex to the Regulations of the Bank of Russia No. 860-P 6, in the indicator "Additional Information" - capital letters of the Russian alphabet "NFL" (for individuals) and "NYuL" (for legal entities and individual entrepreneurs).
With respect to documents submitted by clients confirming the sources of origin of cash, a credit institution shall see that no doubts arise about their authenticity, and the documents themselves shall comply with the requirements for a specific type of documents established by the legislation of the Russian Federation and regulatory acts of the Bank of Russia (the presence of a seal, stamp and/or signature of an authorised official).
Credit institutions shall carry out proper study and analysis of documents submitted by clients for these purposes, avoiding a formal approach to their assessment.
2. When legal entities or individual entrepreneurs apply for the service, consider the following issues:
on requesting information (documents) from such a legal entity or individual entrepreneur attesting to the amount of cash transactions carried out by him earlier on accounts with other credit institutions, and/or cash or other documents provided for by Direction of the Bank of Russia's No. 3210-U of March 11, 2014 on the Procedure for the Conducting of Cash Operations by Legal Entities and the Simplified Procedure for the Conducting of Cash Operations by Individual Businessmen and Small Businesses, in addition to the information (documents), specified in Subitems 2.6 and 2.7 of Item 2 of Annex 2 to Regulations of the Bank of Russia No. 499-P of October 15, 2015 on Identification of Customers, Their Representatives, Beneficiaries and Beneficiary Owners by Credit Institutions for Countering the Legalisation (Laundering) of Illegally Gained Income and Financing of Terrorism;
on the implementation of the right provided for in Subitem 1.1 of Item 1 of Article 7 of Federal Law No. 115-FZ to determine the sources of origin of customer's funds, including cash.
If such a legal entity or individual entrepreneur submits information (documents) requested by a credit institution confirming the legality of the sources of its/his cash, this fact shall not be taken into account in an overriding way when assessing the degree (level) of risk of suspicious transactions by the client.
These Methodological Recommendations have been agreed with the Federal Financial Monitoring Service.
These Methodological Recommendations shall be posted on the official Internet site of the Bank of Russia.
1 Group for the development of financial measures to combat money laundering (Financial Action Task Force (FATF).
2 Item "d" of recommendation 10 "Customer due diligence".
3 Subitem "a" of Item 15 of the Explanatory Note on recommendation 10 "Customer due diligence".
4 Paragraph 20 of the Explanatory Note on Recommendation 10 "Customer due diligence".
5 Other signs indicating the possible legalisation (laundering) of criminally obtained income during cash transactions and money transfers.
6 Regulations of the Bank of Russia No. 860-P of June 18, 2025 on the Requirements for Internal Control Rules of a Credit Institution and a Branch of a Foreign Bank via Which the Foreign Bank Operates in the Russian Federation, for Countering Legalisation (Laundering) of Illegally Gained Income and the Financing of Terrorism and Extremism.
Deputy Chairperson of the Bank of Russia
