What Financial Monitoring Is
Since 2001, Federal Law No. 115-FZ “On Countering the Legalisation (Laundering) of Criminally Obtained Proceeds” has been in force in Russia. It requires banks, notaries, and estate agents to report suspicious financial transactions to the Federal Financial Monitoring Service (Rosfinmonitoring) — including real estate transactions.
Real estate transactions valued at 5,000,000 rubles or more are subject to mandatory monitoring — information is automatically transmitted to Rosfinmonitoring.
Suspicious transactions (regardless of amount) may also be referred for monitoring.
What Rosfinmonitoring Monitors
The system looks for signs of possible money laundering:
- A contract price below market value. Understatement of the price is a classic indicator of a “grey” transaction.
- The source of the purchase funds. Where did the buyer’s money come from? A large cash sum will attract scrutiny.
- Identification of the parties. The buyer and seller must be unambiguously identified; transactions involving persons on sanctions lists are blocked.
- Complex resale chains. Property that has changed hands several times in a short period raises suspicion.
What the Estate Agent Is Obliged to Check
Since 2021, estate agents (real estate agencies) have been included in the list of organisations covered by Law No. 115-FZ. An estate agent is obliged to:
- identify the client’s identity (passport, TIN),
- request information on the source of funds for large transactions,
- decline to proceed with the transaction if the client appears on a Rosfinmonitoring list,
- notify Rosfinmonitoring when suspicious transactions are identified.
How to Prepare for the Transaction
Document the source of funds. If buying with cash, have evidence of their lawful origin: a bank statement, a loan agreement, documents from the sale of previous property.
Do not understate the price in the contract. Stating the market price protects both parties: if the transaction is unwound, the buyer recovers the amount actually paid.
Vet the counterparty. Verify that the seller or buyer does not appear on sanctions lists and is not recorded in open databases as a debtor or a person with restricted rights.
Use a notary. Notarial certification of the transaction adds a layer of verification and reduces the risk of scrutiny by Rosfinmonitoring.
Read Also
- New Real Estate Transaction Safety Mechanisms in 2026
- Russian Supreme Court Review 2026: 5 Key Positions on Real Estate Transactions
Planning a major real estate transaction and want to avoid problems with the bank or financial monitoring? Contact us for legal transaction support — we will review the documents and structure the transaction in accordance with the law’s requirements.