01
The bank should fit the operating model
Compare geography, currencies, sectors, limits, digital banking and correspondent routes rather than the brand alone.
- Universal bank
- Broad products and stronger standardisation
- Regional bank
- Closer service but narrower geography or FX
- Non-bank institution
- Specific settlement or payment functions
- Personal account
- Residence, income, wealth and expected payments
- Licence
- Verify current status in the Bank of Russia register
02
KYC covers the company, people, business and money
The bank identifies representatives and UBOs and tests business purpose, source of funds and expected transactions.
- Corporate
- Charter, register extract, resolutions, licences and powers
- Ownership
- Chain to individuals with supporting documents
- Business
- Website, contracts, invoices, staff and premises
- Funds
- Capital, revenue, loan, investment or asset sale
- Operations
- Turnover, currencies, countries and payment purposes
03
Foreign trade connects the account to currency control
Before payment, review contract, currency, performance, transaction code, evidence and whether bank registration is required.
- Contract
- Parties, subject, amount, term, currency and settlement
- Registration
- Applicable thresholds and authorised-bank rules
- Evidence
- Invoice, acceptance, transport and customs records
- Special measures
- Check the rules in force on every payment date
- Liability
- Late or missing documents can create administrative risk
04
Monitoring continues after the account is opened
Actual payments should remain consistent with the onboarding profile; explain material changes before an unusual payment.
- Online banking
- Roles, limits, dual control and contingency
- AML queries
- Prompt evidence of economic purpose
- Cash
- Enhanced attention and documented rationale
- Taxes
- Consistency between turnover, returns and tax payments
- KYC refresh
- Update owners, director, address, business and licences