ING in Russia

ING in Russia

Suspicious transactions

All transaction executed by licensed financial institutions are subject to the instructions by the Central Bank of the Russian Federation on suspicious transactions. The following is a summary of such transactions.

General suspicious situations related to all types of operations

  • Absence of economic basis or obvious reason for the deal (operation).
  • Non-standard or unusually complicated settlements or investment instructions for the operations (deals) different from the common practice of a particular client or different from the market practice.
  • Unreasonable haste in conducting an operation (deal).
  • Significant increase in volume or frequency of client's operation (deal) both in total and in separate deals (operations).
  • Incomplete or deliberately false identification of partners, clients and other participants in the operation (deal) prior to its execution.
  • The client submits little information, possibly false, which cannot be checked or refuses to submit the information required for the account opening.
  • Failure to declare and transfer of unlawfully received funds.
  • Frequent changes of the company's founders and name.


Clients' accounts and monetary operations

A transaction can be treated as suspicious and thus requiring special attention from the bank's side if the amount of such one-time or single transaction (executed within a month) is equal or exceeds the equivalent of USD 10,000 for private individuals and is equal or exceeds the equivalent of USD 10 million for legal entities.

  • Debiting and crediting of an account when it is not justified by the nature of the legal entity's business.
  • Crediting of an account, which was not used or insignificantly used with a further instruction to make a cash paying.
  • Crediting (or debiting) an account with the funds received from a legal entity which is located or holds an account with a bank registered in the regions (including offshore and free economic zones, as well as regions with unstable political and economic situation or connected with drugs production) with which the entity does not have stable commercial contacts.
  • Funds transactions not associated with a client's type of activity or standard market practice.


Fund transfers

  • Last minute changes in the payment/delivery instructions in the name of a third party not specified in the supporting documents.
  • Making changes to the pre-agreed scheme of operations (deal) immediately before the starting day, especially related to the funds transfer destination or other property involved into the operation (deal).


Loan operations 

  • Client's readiness to receive a loan at any interest rate.
  • A loan application against pledge of a saving certificate.
  • Incoming payments in FCY to a legal entity's account under foreign trade contracts for a commercial loan for the execution of the obligations, which are not actually fulfilled by this legal entity.


Purchases of monetary instruments and operations with securities 

  • An offer of an unusually high commission for the intermediary services in the securities transactions.
  • A one-time order to buy and to sell the securities at the prices significantly deviating from the current market prices, and other deals connected with prices manipulation on the securities market.
  • Operations under which the same financial instrument (securities) is sold many times and then purchased back from the same counterparty.
  • Operations with a holder securities not placed in the depository.
  • Safekeeping of the securities under the circumstances evidencing that these operations (deals) are not connected with the client's activity, its income and status.