Clients of Tinkoff Bank began to receive letters with a request to clarify the nature of transactions related to the circulation of cryptocurrencies. This was announced by the founder of the “smart bank” InDeFi Sergey Mendeleev.
In the submitted letter, the client is asked to provide a number of documents, including:
- Proof of income (2-NDFL, 3-NDFL, etc.);
- Clarifications on the economic meaning of operations;
- Information whether crypto-exchange operations are carried out using the account (from what period; documents confirming the origin of the funds for which the cryptocurrency was originally purchased; documents confirming the payment of taxes; notarized screenshots from the personal account of cryptocurrency exchanges, allowing to uniquely identify the owner).
The representative of the bank in the comments confirmed that the documents can indeed be requested in accordance with the requirements of the law.
“We study transactions on clients’ accounts and, if we notice that some of them fall within the criteria described in the“ Methodological Recommendations on Increasing the Attention of Credit Institutions to Certain Operations of Individual Clients of September 06, 2021 No. 16-MR ”, we request documents for checks. We are obliged to pay attention to the methodological recommendations of the Central Bank in accordance with 115-FZ “, – wrote a representative of Tinkoff Bank.
This document provides the following criteria for identifying suspicious bank accounts of individuals:
- an unusually large number of counterparties – individuals, for example, more than 10 per day, more than 50 per month;
- an unusually large number of transactions for crediting and (or) writing off non-cash funds carried out with counterparties – individuals, for example, more than 30 transactions per day;
- significant volumes of transactions for writing off and (or) crediting non-cash funds between individuals, for example, more than 100 thousand rubles a day, more than 1 million rubles a month;
- a short period of time (one minute or less) between the crediting of funds and the debiting;
- within 12 hours (or more) one day, operations are carried out to enroll and (or) write off money;
- during the week, the average cash balance in the bank account at the end of the transaction day does not exceed 10% of the average daily volume of transactions on the bank account in the specified period;
- transactions to write off funds are characterized by the absence of payments in favor of legal entities and (or) individual entrepreneurs to ensure the life of an individual (for example, payment for utilities, communication services, other services, goods, works);
- coincidence of identification information about the device (for example, MAC address, digital fingerprint of the device, etc.) used by different individual clients for remote access to the credit institution’s money transfer services.
An account can be considered suspicious if it meets at least two of the listed criteria. If such accounts are identified, the bank should ensure increased attention to the customer’s transactions and conduct additional checks for money laundering.
Mendeleev himself claims that such letters have recently been sent to dozens of bank clients.