New customer identification rules for currency exchange

Bank of Russia Regulation No. 499-P, dated 15 October 2015, ‘On the Identification by Credit Institutions of Customers, Customer Representatives, Beneficiaries and Beneficiary Owners in Order to Counter the Legalisation (Laundering) of Criminally Obtained Incomes and the Financing of Terrorism’ was approved in compliance with Federal Law No. 115-FZ, dated 7 August 2001.

The current legislation allows not to identify an individual purchasing or selling foreign currency in cash in the amount up to 15,000 rubles or its equivalent in the foreign currency. For larger amounts, identification shall be based on the customer’s ID.

The credit institution shall record the data received under identification in the form (file) it prepares in compliance with Bank of Russia Regulation No. 499-P by different means. This record can be made with the use of registers of operations with foreign currency in cash envisaged by the effective legislation. They shall be prepared by credit institutions and can include the individual’s data required for identification.

Thereby, individuals are not obliged by law to record their ID data in forms, questionnaires, etc. The Regulation does not impose additional obligations to identify customers other than those envisaged by the law ‘On Countering the Legalisation (Laundering) of Criminally Obtained Incomes and the Financing of Terrorism’ on credit institutions.

ID data of individuals shall be kept in the credit institution only during the period stipulated by law.