At a glance
Describe the bank's action literally: what is unavailable, which transaction received a response and which basis the bank cites.
In this article 2 min read
Separate the access channel from an individual transaction
The Bank of Russia's explanations consider remote service restrictions, card blocks and transaction suspensions in relation to their specific bases. The document describing the measure applied is important for the examination. Lack of access to the app alone does not establish the status of every account instruction. [1]
List the actions affected
State whether you can view statements, create instructions, sign payments and use the card. Do not test functionality by transferring to random accounts: existing messages and the bank's response are sufficient for an initial review. Clarify possible service channels with the bank in light of the specific measure.
Check whether there was a separate refusal
If the bank reported a transaction refusal, link the message to the instruction: number, date, amount, recipient and purpose. If there is no such message, do not retrospectively invent one in your description. You may ask the bank to clarify the instruction's status and the grounds for its decision.
Choose the appropriate subject for your submission
The Bank of Russia's official methodological recommendations state that a remote banking restriction alone cannot be appealed to the Interdepartmental Commission (MVK). The document package must therefore distinguish online banking correspondence from refusal materials, if a refusal actually occurred. This affects the content of subsequent documents. [2]
What a review can deliver
A written review may include an events table, notification list, established discrepancies and unanswered questions. It helps agree further work: preparing explanations, examining transactions or providing separate pre-trial support. The scope depends on the documents, rather than the problem's name in the initial message.
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: methodological recommendations on dealing with banks, rehabilitation section ↗
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.