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pc nid 91537 Mar 27, 2026 arahman@vixio.com Russia The central Bank of Russian Federation horizon scanning
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Russia's Central Bank Recommends Proactive Approach for Notifying Customers of Transaction Restrictions

On [date], the Central Bank of Russia (Bank of Russia) issued an information letter to credit institutions and banking associations recommending a proactive approach when informing customers about transaction restrictions and limitations on remote account access. The Bank of Russia conducted monitoring of credit institutions' practices regarding customer notification when operations are refused, restricted, or when electronic payment methods and remote banking services are limited under Federal Law No. 115-FZ (on combating money laundering and terrorism financing) and Federal Law No. 161-FZ (on the national payment system). While most credit institutions generally follow previously published guidance from August 26, 2025, the Bank of Russia identified inconsistencies in how institutions inform and support customers during these processes, creating difficulties for customers seeking clarification on applied restrictions or refusals. To standardise practices and enhance transparency, the Bank of Russia recommends that credit institutions proactively: notify customers through remote banking channels and SMS about restrictions or operation refusals, including reasons and applicable legal bases; inform customers of their right to submit documents or information disputing the restriction; maintain customer access to communications through remote banking systems even when electronic payment restrictions are in place; and provide customers with links to Bank of Russia resources explaining the process for exclusion from the Bank of Russia's database of unauthorised fund transfer attempts. Additionally, when customers challenge restrictions or refusals, institutions should explain appeal procedures, including the right to petition the interdepartmental commission established at the Bank of Russia under Article 7(13.5) of Federal Law No. 115-FZ. The recommendations apply to all credit institutions and banking associations operating in Russia. REFERENCES: Central Bank of Russia Information Letter on Proactive Notification of Transaction Restrictions (2025)

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Russia's Central Bank Recommends Proactive Approach for Notifying Customers of Transaction Restrictions

On [date], the Central Bank of Russia (Bank of Russia) issued an information letter to credit institutions and banking associations recommending a proactive approach when informing customers about transaction restrictions and limitations on remote account access. The Bank of Russia conducted monitoring of credit institutions' practices regarding customer notification when operations are refused, restricted, or when electronic payment methods and remote banking services are limited under Federal Law No. 115-FZ (on combating money laundering and terrorism financing) and Federal Law No. 161-FZ (on the national payment system). While most credit institutions generally follow previously published guidance from August 26, 2025, the Bank of Russia identified inconsistencies in how institutions inform and support customers during these processes, creating difficulties for customers seeking clarification on applied restrictions or refusals. To standardise practices and enhance transparency, the Bank of Russia recommends that credit institutions proactively: notify customers through remote banking channels and SMS about restrictions or operation refusals, including reasons and applicable legal bases; inform customers of their right to submit documents or information disputing the restriction; maintain customer access to communications through remote banking systems even when electronic payment restrictions are in place; and provide customers with links to Bank of Russia resources explaining the process for exclusion from the Bank of Russia's database of unauthorised fund transfer attempts. Additionally, when customers challenge restrictions or refusals, institutions should explain appeal procedures, including the right to petition the interdepartmental commission established at the Bank of Russia under Article 7(13.5) of Federal Law No. 115-FZ. The recommendations apply to all credit institutions and banking associations operating in Russia. REFERENCES: Central Bank of Russia Information Letter on Proactive Notification of Transaction Restrictions (2025)