At a glance
An application to have details removed from the database under Federal Law No. 161-FZ and explanations of the source of funds address different issues. Start preparing with the bank's complete notification.
In this article 3 min read
Establish which measure the bank reported
The Bank of Russia explains that the bases for restrictions under Federal Laws No. 115-FZ and No. 161-FZ must be distinguished. If the response mentions the regulator's database of transfers made without the client's voluntary consent, identify that wording separately. Record the message date, bank name and unavailable service channel. If the explanation is general, first ask for clarification of the reason. The word “security” alone does not determine the subject of an application. [1]
Choose an official submission channel
The Bank of Russia's official page allows applications through the servicing bank or the regulator's Internet Reception. Applying independently through the website requires the applicant to authenticate through Gosuslugi. Check the fields in the current form for your category: individual, individual entrepreneur or organisation. Payment and identification details are entered through the designated official channel; an initial conversation with the service provider only requires a description of the situation. [2]
Build a chronology instead of keeping disconnected messages
Prepare a short sequence of events: when the transaction occurred, when the notification arrived, which questions you sent and what you received in response. Save every message in full. Beside each event, identify the file, page or enquiry number. If information in different responses conflicts, show both wordings and dates. This organisation helps separate an established circumstance from an assumption about the reason for restrictions.
Link transaction descriptions to documents
Prepare a separate list of the transactions concerned: date, amount, coded account reference, counterparty and the document establishing the payment basis. Do not retrospectively add to the original payment purpose. Keep explanations in a separate column and state the materials on which they are based. If a statement is incomplete or a document is missing, state this expressly. Uploading every available file in bulk usually makes relevant information harder to find.
Distinguish the review period from its outcome
The official page specifies a Bank of Russia application review period of 15 working days from registration. This concerns consideration of the application and does not imply a predetermined decision. Retain the registration details and response received. Further review follows its content: which circumstances were considered, which documents were taken into account and which questions remain. A service provider's promise that restrictions will be removed by a particular date does not replace a decision by the authorised recipient. [2]
Determine whether separate paid work is needed
You may submit the official application yourself. Individual assistance may be needed to compare notifications, reconstruct a chronology, examine transactions and prepare an agreed set of explanations. Up to 15 minutes discussing your task with AML Expert is free. A written review starts at 49 000 ₽; the documents, questions and deliverable scope are specified separately in the assignment. Preparing a subsequent application or a new support stage is agreed separately.
Official sources
- Bank of Russia: disclosure of restriction reasons under Federal Laws No. 115-FZ and No. 161-FZ ↗
- Bank of Russia: removal of details 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.