At a glance
First identify the specific measure and its legal basis. This determines who should receive your submission and which documents it needs.
In this article 2 min read
Why the law number matters
The Bank of Russia distinguishes anti-money laundering measures under Federal Law No. 115-FZ from protection against fraudulent transfers under Federal Law No. 161-FZ. The regulator states that clients must be informed of the specific legal basis for a restriction and the procedure for further action. A general explanation that “security was triggered” is insufficient to determine the subject of a submission. [1]
Clarify exactly what is restricted
Record the action you can observe: a particular transfer cannot be made, the app is unavailable, card use has been suspended or an account-opening refusal has been received. Keep the complete message. Do not replace the bank's wording with your own assumption about the reason: several different events may occur during the same period.
Prepare a short request for clarification
State the notification date and the transaction in question. Ask the bank to specify the type of restriction, the legal provision applied, the document submission procedure and how to lodge an enquiry. Keep evidence that you submitted the request. This is a practical way to collect initial information, rather than a universal appeal form for every situation.
A separate case: records in the database under Federal Law No. 161-FZ
There is a specific application procedure for challenging the inclusion of account or payment details in the Bank of Russia database. The regulator's official page describes applying through the servicing bank or directly to the Bank of Russia. This is a separate procedure; a package explaining business activities does not automatically replace such an application. [2]
What the document examination covers
The review compares notifications, the chronology of events, the statement and correspondence. The result shows which circumstances have been established, what is missing and which issue should be addressed next. If several restrictions apply at the same time, each is identified separately so that documents about one transaction are not lost in the overall correspondence.
| Situation | What to retain | What to clarify |
|---|---|---|
| A transfer is not being executed | The payment instruction and transaction message | The basis and status of the specific transfer |
| The app or card is unavailable | The notification and restriction date | Which service channel is restricted |
| The database under Federal Law No. 161-FZ is mentioned | The bank's complete response | The procedure for applying to have information removed |
Official sources
- Bank of Russia: disclosure of restriction reasons and the distinction between Federal Laws No. 115-FZ and No. 161-FZ ↗
- Bank of Russia: applications for removal of information from the database under Federal Law No. 161-FZ ↗
Sources checked on 24 October 2026. Practical recommendations on preparing materials are provided by the AML Expert editorial team. The procedure for a specific case depends on the documents and the applicable basis.