What’s This Letter
EN
Read my letter

Bank · Russia

A Russian bank's demand under 115-FZ

This is not an audit and not a penalty. The bank is discharging a control duty the law puts on it and wants documents about your transactions. The deadline here is set by the bank, not by the statute — and until the documents arrive there is nothing to count from.

How serious: needs actionAlso called: запрос по 115-ФЗ, требование банка о документах, блокировка по 115-ФЗ, запрос комплаенса

Article 7(14) of Federal Law 115-FZ obliges a customer to give the bank the documents and information the bank needs to comply with that law. That provision is what the demand rests on.

The law sets no deadline for the customer: the account agreement and the bank's internal rules do. So the date is in the demand itself, not in the statute.

The law does set a deadline for the bank. Article 7(13.4) requires it to consider the documents within seven working days and say whether the grounds for refusal are cleared. Those seven days run from the day the documents are submitted.

Who sends it

A bank or another organisation carrying out transactions with money, under the control duty Federal Law 115-FZ places on it. Not a state body and not a court: a private organisation discharging a public duty.

A message in the online bank or a letter citing Federal Law 115-FZ and article 7(14); a list of documents and explanations wanted about particular transactions; a date the bank has set; and often a note that remote access is limited until the answer arrives.

The deadline

срок устанавливает банк — закон его не задаёт

The bank sets the deadline, not the law. Article 7(14) creates the duty to produce documents but names no date for the customer — that is in the account agreement and the bank's internal rules, so the demand itself is what to read. The statutory clock belongs to the bank: seven working days to consider what was submitted (article 7(13.4)), counted from the day of submission.

If you do nothing

With no answer the bank has no basis to lift anything. It may refuse to carry out an operation and refuse to open an account, and remote access stays limited. The rehabilitation route in article 7(13.4) is started by documents; without them there is nothing to consider.

How it escalates

  1. 01The bank may refuse to carry out the operation and refuse to conclude a bank account agreement under Federal Law 115-FZ.
  2. 02Remote access stays limited, and payments go only on paper at a branch, if the bank allows that.
  3. 03The rehabilitation route does not start: the seven working days of article 7(13.4) run from the day documents are submitted, and there are none.
  4. 04The interdepartmental commission at the Bank of Russia can be approached only after the bank has said the grounds for refusal cannot be cleared on what was submitted.

Your options, procedurally

  • Send the documents and explanations the bank asked for, by the date it set.
  • Ask the bank for the reason for the refusal or the limitation — the Bank of Russia advises giving it in enough detail for the customer to use the rehabilitation route.
  • Complete the set where the bank has said what is missing.
  • Apply to the interdepartmental commission at the Bank of Russia, after the bank reports that the grounds cannot be cleared.
  • Move the banking elsewhere, remembering that the refusal stays in the system and a new bank runs its own check.

How to respond

What follows is procedure: what to enclose, where to send it, and which date the clock runs from. Whether the limitation is justified is a separate question, and not one this page answers.

Response types

  • Send the documentsПредставление запрошенных документов и пояснений · 115-ФЗ ст. 7 п. 14
  • Ask for more timeПросьба о продлении срока представления документов
  • Apply to the Bank of Russia commissionЗаявление в межведомственную комиссию при Банке России · 115-ФЗ ст. 7 п. 13.4, ст. 7.8

Where and how

  • The online bank or its app — the bank records the date and issues a reference; upload files rather than typing into a chat.
  • Registered post with acknowledgement of receipt and an inventory of contents, where the date has to be provable.
  • Ordinary post, which proves nothing.
  • The bank's telephone — useful to learn which documents are wanted; a call submits nothing.

What to attach

  • Contracts and primary documents for the transactions named.
  • Evidence of the source of funds, where the bank asks about it.
  • Tax filings or proof of payment, where the demand concerns them.
  • A copy of the demand itself.

What makes it count

What matters is the day the documents reach the bank: the seven working days for considering them run from it. The deadline for answering the demand was set by the bank under the agreement, so read the demand and keep proof of sending.

Common questions

How long do I have?

As long as the bank said. The law obliges you to produce the documents but sets no deadline for the customer — the agreement and the bank's internal rules do. The date in the demand is the answer.

What are the seven working days people mention?

They are the bank's, not yours. Article 7(13.4) requires the bank to consider what was submitted within seven working days and report whether the grounds for refusal are cleared. They run from the day of submission.

Can I complain to the Bank of Russia straight away?

The interdepartmental commission takes the case after the bank has considered the documents and reported that the grounds cannot be cleared. Documents to the bank first; the commission after.

Is it easier to open an account elsewhere?

The refusal stays in the system and a new bank runs its own check. Changing banks does not replace producing the documents and does not undo the decision already taken.

Sources

Facts verified against the sources below on 10 September 2026.