Beneficiaries of Foreign Non-legal Entities have to be disclosed in accordance with a new law which came into effect as of January 2016: Federal Law of the Russian Federation of 30 December 2015 No.424-FZ “On Amendments to the Federal Law “On Counteraction of Legitimization (Laundering) of Proceeds of Crime and Financing of Terrorism”.
The law introduces amendments and additions to several articles (2 and 3) devoted to the scope and basic definitions; the article 7 devoted to duties of organizations engaged in transactions with funds or other property (credit organizations, insurers, leasing companies, pawn offices etc.) was also added.
The improvements are mainly related to the regulation of foreign non-legal entities (funds, partnerships, trust management and other similar entities of collective investments which are not legal entities according to international law) active in the territory of Russia.
A foreign non-legal entity doing or contemplating business in Russia has to disclose the following data: name, registration/tax numbers, location of its primary activity. For trusts and similar foreign entities the following data has also to be disclosed: owned property/property under management, surname, name (and patronymic if available), residential address or location of founders, trustee or trust administrator.
There is a ban for Russian credit organizations to open and maintain accounts or deposits for anonymous owners of foreign non-legal entities. Credit and other organizations engaged in transactions with funds or property will now have the right to refuse their services to these non-legal entities in the event of suspicious transactions aimed at legalization of criminal proceeds or terrorism financing.
Russian banks are now obliged to record data on all cases of refusal to enter into a contract or dissolution of contracts with such high-risk foreign clients and submit these data to the Federal Financial Monitoring Service (Rosfinmonitoring) of 
Russia. Rosfinmonitoring in its turn will forward this information to the regulator – Bank of Russia – which will inform other banks and financial market players.
Source: Credinform Russia
