According to the normative act of the organization, who carry out transactions with cash (including SPC), are obliged to carry out the following measures against the legalization of proceeds:

  • identify prospective client before entering into a contract with it (for example,a natural person to get information about his name, date of birth, nationality, passport data, INN);
  • annually update information on each of their clients, and if in any doubt about the veracity of previously obtained data, it is necessary to update the information within 7 working days;
  • within 3 working days from the date of the transaction reported to the Federal Financial Monitoring Service information on transactions subject to mandatory control;
  • no later than one working day from the date of posting information on the Internet to block the funds belonging to a person who is included in the list of "extremists" and report it to the Federal Financial Monitoring Service;
  • 1 every 3 months to check their clients on their involvement in the "extremism" and to report on the audit of the authorized body;
  • at the request of the authorized body to provide information on transactions of customers.

However, many members of the private pension sector say that the application of the law № 115-FZ of this edition against NPF somewhat difficult.The main difficulty of the representatives of NPF duty caused annually update information about their customers.For customers NPF basically have no desire to be there every year to provide information, and interest or somehow force them to do so, as is the case with clients of credit institutions, it is practically impossible.

Annual sending letters requesting an update to all clients (some of NPF their number in the millions) may be too costly.And the result of such a distribution can be practically zero.It turns out that such an obligation for the NPF will only very costly formality.

representatives also complained NPF requirements of the law on mandatory customer identification only employees of the organization without the involvement of agents.For a small network of NPF does not allow them to operate in this mode.And many NPF in attracting customers just use the services of agents.After analyzing these arguments, the authorized body - the Federal Financial Monitoring Service has promised to soften the requirements of the law in relation to SPC.For example, since August 2014 NPF management companies are allowed to bring credit institutions to identify their customers.