At a glance
A transaction refusal, high ZSK risk and remote banking restriction each require a separate review. One complaint does not replace different procedures.
In this article 2 min read
Start by applying to the bank
The Bank of Russia describes rehabilitation following a refusal as providing information and documents to the bank for reconsideration of its decision. If the issue is not resolved at that level, an application to the Interdepartmental Commission is possible in cases provided by law. First establish exactly which decision was made and whether it falls within that procedure. [1]
Build a chronology for a single event
Identify separately the dates of the instruction, refusal notification, additional information request, explanations submitted and response received. If there are several refusals, create a separate record for each. This chronology allows verification of which documents related to a particular decision and which circumstances arose later.
Link each argument to an attachment
To explain a transaction, state its date and amount, actual substance, participants and underlying document. Prepare an attachment inventory and identify the pages. Corrections, incomplete information or contradictions in a document should be disclosed and examined, rather than hidden behind a general activity description.
Check the subject of an application to the MVK
The Bank of Russia's methodological recommendations separately list issues outside the MVK's remit, including a remote banking restriction itself and tariff disputes. Appealing a refusal requires a preliminary reconsideration stage. The choice of procedure is checked against the specific notification; the word “block” alone is not a reliable guide. [2]
Define the scope of support
A one-off package may include analysis of the notification, draft explanations and a document inventory. Preparing a subsequent application, reviewing a new refusal and court work are agreed separately. The written deliverable should show the actions performed and circumstances confirmed; the bank or commission's decision is not predetermined.
Official sources
- Bank of Russia: account restrictions and rehabilitation of entrepreneurs ↗
- 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.