Key Provisions
The Federal Financial Monitoring Service (Order No. 333, 23 December, 2024) imposes a broader set of responsibilities on notaries. Previously routine transactions now require comprehensive verification of the parties' identities, authority, and financial standing. They are also expected to identify any potentially suspicious elements — such as concealed gifts or family arrangements — and examine the source of funds for transactions involving substantial sums or unusual circumstances.
Failure to meet these requirements can result in notaries refusing to certify the transaction and reporting the case to the Federal Financial Monitoring Service.
These rules extend to the withdrawal of LLC participants — a process that previously saw less scrutiny. Notaries must now confirm the legitimacy of each withdrawal, ensuring it is not used to hide illicit activities or sidestep regulations.
Implications for Businesses
Businesses should adopt a proactive approach:
- Comprehensive Financial Documentation: Prepare thorough records to validate the lawful origin of funds for all parties.
- Advance Preparation: Anticipate additional checks by notaries and allocate time for the required verifications.
- Compliance Strategy: Stay aligned with evolving regulations to avoid transaction delays, rejections, or potential legal repercussions.
Ultimately, these measures aim to enhance transparency and curb illicit financial activities in the Russian LLC market. Ensuring your internal processes and documentation are robust will be key to navigating the new requirements smoothly.
If you have concerns or need tailored guidance on these changes, Solstico Legal is here to help.