On July 31, 2017, the Russian Government adopted Resolution No.913, determining rules for legal entities submitting data on their beneficiaries and measures taken to establish such data upon requests of the Federal Tax Service, Federal Financial Monitoring Service and their territorial bodies (hereinafter the “authorized bodies”).¹

According to this Government Resolution, if a request is received from the authorized bodies, a legal entity should submit data on beneficiaries within 5 business days from the day of receiving the request.

It should be noted that if after the data submission a legal entity finds any errors in the submitted data, such legal entity has the right to submit updated data to the authorized body within 3 business days from the day the error is detected.

Data on beneficiaries may be submitted in electronic format or in hard copy.

When the legal entity submits the data on beneficiaries in electronic format, it should submit such data in one of the following ways:

• Via communication channels through an operator;

• On optical or digital data medium with a hard copy cover letter.

Moreover, Government Resolution No.913 defines cases when an authorized body has the right to reject an email with data on beneficiaries, such as non‑compliance with the structure or format specified in the Resolution, the absence of an authorized person’s signature, a damaged data storage device, etc.

If a legal entity receives a notification on rejection of its email, it should eliminate the causes of the rejection and resubmit its email with data on beneficiaries within 3 business days.

Furthermore, the Resolution defines a procedure of interaction between the Federal Tax Service and the Federal Financial Monitoring Service on issues of submitting enquiries and receiving data on beneficiaries of legal entities.

The Resolution takes effect starting August 18, 2017. 

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¹ Please be reminded that legal entities must disclose data on their beneficiaries under Clause 6 Article 6.1 of Federal Law No.115-FZ “On combatting money laundering and terrorism financing” dated August 7, 2001.

Dmitry Churin   Principal Associate   St. Petersburg   Теl.: +7 (812) 346 79 90

Ekaterina Chernenkova   Associate   St. Petersburg   Теl.: +7 (812) 346 79 90

Additional notes

Should any questions arise in connection with the above or if you need any additional materials, please contact Dmitry Churin or Ekaterina Chernenkova, Office of Capital Legal Services.

This Information letter keeps the clients of Capital Legal Services and other interested parties abreast of information that may, to any extent, affect their activity or cater to their particular interests. The opinions and commentaries expressed in this information letter shall not be deemed as legal opinions and do not cancel the need to obtain legal advice or legal opinion on separate issues. 

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