115-FZ
Russia's anti-money-laundering federal law "On countering the legalisation of criminal proceeds and the financing of terrorism", adopted 7 August 2001. The primary AML statute in Russia; banks freeze suspicious transactions under its authority.
Aliases: 115-fz, fz 115, russia aml law
115-FZ is Russia’s principal anti-money-laundering law. Its full title is “On Countering the Legalisation (Laundering) of Criminal Proceeds and the Financing of Terrorism”, adopted in August 2001. In practice it is the most widely known financial-regulation law in Russia because it is the basis on which banks freeze cards and refuse transactions.
What it covers
115-FZ requires financial institutions (banks, brokers, insurers, exchangers) and selected non-financial entities (notaries, real-estate agents, pawnshops, lottery operators) to:
- Identify the client above certain transaction thresholds (KYC).
- Retain operation records for at least five years.
- Report suspicious operations to Rosfinmonitoring (Russia’s FIU).
- Apply the terrorist-financing list maintained by Rosfinmonitoring — freeze funds of listed persons.
- Use a risk-based approach — deeper checks on operations exhibiting laundering indicators.
Headline thresholds
Indicative numbers from 115-FZ (subject to revision):
- 600 000 RUB — mandatory control of cash operations.
- 1 000 000 RUB — real-estate operations.
- 5 000 000 RUB — lottery payouts.
The exact current thresholds live in the law’s text and CBR instructions and are updated periodically.
Crypto angle
115-FZ does not mention cryptocurrencies directly — it predates them. But crypto trading falls under it indirectly via the bank that carries the ruble side: if a client repeatedly buys crypto through P2P, the bank may classify the activity as “suspicious” and freeze the card under article 7 (right to refuse a transaction).
After 259-FZ on digital financial assets came into force, parts of crypto operations got their own regime, but they still fall under 115-FZ via CASP-equivalent providers.
”Frozen under 115-FZ”
The most common complaint: a bank froze a card citing 115-FZ. The mechanics:
- The bank’s algorithm classified operations as suspicious.
- The bank requested source-of-funds documentation.
- If documentation is missing or raises further questions, card operations are paused.
- To unfreeze, the client provides statements, contracts, and written explanations.
It is not a criminal case — it is an administrative check, and most cases are resolved by supplying documents.
This is general information for an international audience, not legal advice; specifics depend on the situation and the law evolves.