At a glance
Start with the questions in the request, describe the actual activity and connect the affected payments to performance of the transactions. Show discrepancies and missing materials separately.
In this article 3 min read
Start with the specific questions in the request
Copy the bank's questions into a working list, preserving the original wording and numbers. For each question, state which information is already available, which documents support it and what needs clarification. A general company description may provide a useful introduction, but it does not automatically explain every transaction. If the request concerns a selected period or particular counterparties, define those boundaries at the start of the work.
Describe how revenue actually arises
Explain in sequence what the business offers, who orders its goods or services, how the obligation is performed and when payment arises. Use information from actual processes: accepting orders, procurement, performing work, delivering the result and settlement. Include information on employees, equipment, contractors or leases insofar as it relates to the question. A universal checklist for every company does not replace a description of the particular activity.
Show the chain from transaction to payment
A useful working record links the obligation, evidence of performance and movement of funds. For example: a coded transaction number, contract, acceptance certificate or other relevant document, statement entry and explanation. If an amount has several components, prepare a document-based breakdown. Keep the original payment purpose separate from your explanation. This lets the reader check the substance of the asserted connection, rather than merely matching words.
Identify transactions needing a separate explanation
Refunds, loans, transfers between one's own accounts, partial payments and fee deductions reflect different circumstances. They cannot mechanically be described with the single phrase “payment for services”. First establish what follows from the statement and documents provided. If the transaction's classification is unclear, record the question and list the materials required. An unsupported explanation should not be presented as an established fact.
Compare explanations with figures and dates
Before submission, check the parties' details, period, amounts and document numbers. Examine differences between the transaction date and account posting date separately. Where several currencies are involved, identify each entry's currency and the conversion basis, if conversion is within scope. A similar amount alone does not establish a connection between two transfers. Corrections in the working table must leave a way to return to the original entry.
Assemble a clear response package
The final package may include a short activity description, explanations addressing the request point by point, a register of affected transactions and an attachment inventory. Each document receives a stable code; repeated references point to the same material. Incomplete portions and circumstances that cannot be confirmed are marked separately. The scope of individual preparation is agreed before work begins. At AML Expert, document analysis and draft explanations for the bank start at 79 000 ₽; an initial discussion of up to 15 minutes is free.
| Element | What to record |
|---|---|
| Question in the request | Number and original wording |
| Transaction | Date, amount, currency and coded entry reference |
| Document | Material code and page or row |
| Explanation | Nature of the connection and basis for the finding |
| Gap | What is missing and what needs clarification |