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A bank account in the region and payments with Russia: preparing for bank checks and sanctions analysis

When banks in the region turn clients away, the reason is usually not a statutory ban but the risk appetite of the bank and its correspondents: clients with Russian beneficial owners face enhanced due diligence. We screen the company, its owners, partners and banks against sanctions lists in advance, put together a clear package for the bank and plan payments so that the project has a fallback route.

Call: +7 (499) 460-63-47
Format
Remotely; specific bank requirements are confirmed through a local specialist

What is happening

A subsidiary in Chile has been registered, but for several weeks the bank has kept asking for documents on beneficial owners and the source of funds, and payments to suppliers are on hold.

A Brazilian buyer is ready to pay in US dollars, but the Russian exporter is worried that a US correspondent bank will hold up the payment.

A company plans to supply goods to Cuba and wants to know in which currency and through which banks payments are possible at all.

What the law says

  • US dollar payments pass through correspondent banks in the United States and are subject to the requirements of the US Treasury's Office of Foreign Assets Control (OFAC).
  • Foreign financial institutions face the risk of US secondary sanctions for transactions involving Russia's military-industrial sector (US Executive Order 14024 as amended by Executive Order 14114 of 22 December 2023). This is why banks in the region look closely at the goods, the counterparty and the purpose of the payment.
  • Separate US sanctions programmes apply to Cuba, Venezuela and Nicaragua; dollar and euro payments to these countries are complicated regardless of any Russian involvement.
  • A Russian company must notify the tax authority of opening an account with a foreign bank no later than one month afterwards (Article 12(2) of Federal Law No. 173-FZ of 10 December 2003 on Currency Regulation and Currency Control); reporting on such accounts is covered by our currency control service.

What we do

  • We screen the company, beneficial owners, managers, counterparties and banks against the OFAC SDN list and EU, UK and local lists before approaching the bank.
  • We assess whether the transaction touches sectors that raise secondary sanctions risk and how this will affect the bank's position.
  • We prepare a know-your-customer (KYC) package: ownership chart, source of funds, business plan, contracts and a letter explaining the business purpose.
  • We agree the document list with a local specialist to match the specific bank's requirements and arrange translation; translation into Portuguese is done with the help of a translator.
  • We plan payments: currency, correspondent bank, main and backup bank, and what to do if a payment is delayed.
  • We help respond to further requests from the bank.
  • On request, we monitor sanctions list changes affecting your counterparties and banks.

What we will need from you

  • Constitutional documents and the ownership chart up to the ultimate beneficial owners.
  • A description of your business, goods and main counterparties.
  • Evidence of the source of funds: financial statements, contracts, bank statements.
  • A list of banks you already work with or are talking to.

HOW THE WORK IS BUILT

How the work is built

Screening

Shareholders, counterparties and banks checked against sanctions lists.

before approaching the bank

Risk assessment

Findings on the transaction and currency, recommendations on the payment structure.

depends on the task

Bank package

Documents, translations, business purpose letter.

as the bank requires

Bank review

Responses to requests, additional documents.

the bank decides

Payments

Main and backup payment routes, tracking of sanctions changes.

depends on the task

QUESTIONS

Frequent questions

Do you guarantee the account will be opened?

No. The bank decides under its own risk policy and may later review the relationship. We improve the odds with a complete, clear document package and risks identified in advance.

Why does a bank in Mexico care about US sanctions?

Banks in the region access the dollar through US correspondents and value those relationships. So they screen clients and transactions against US, EU and UK lists, not just local ones.

Can we settle in roubles or national currencies?

Such settlements do happen in practice, but availability depends on specific banks and changes over time. We choose the route for each transaction and always build in a fallback.

Will you help us get around sanctions?

No. We do not design sanctions evasion schemes: once exposed, they lead to frozen funds and personal risk for managers. Our job is a lawful payment structure and a transparent package for the bank.

NEXT STEP

Let us discuss your situation

The consultation is free of charge when an engagement agreement is signed: on it we say what has to be done and by when.

Call: +7 (499) 460-63-47