Rosfinmonitoring Order No. 333 of 23 December 2024 has been in effect since 31 January 2025. It defines the notarised transactions to which Article 7.1 of Federal Law No. 115-FZ applies. The list includes transfers for consideration of interests in Russian limited liability companies (OOOs) and a member’s declaration of withdrawal from the company. The order defines the transactions covered; the obligations themselves are established by law.

New obligations for notaries

In the cases prescribed by law, a notary identifies the client, their representative, the beneficiary and the beneficial owner, assesses the risk of suspicious transactions and records the required information. The scope of information requested depends on the applicable requirements and the circumstances of the transaction. Order No. 333 does not impose a universal obligation to conduct enhanced checks on the parties’ financial position in every transaction.

Refusing to perform a notarial act and reporting information to Rosfinmonitoring are separate actions. Where there are sufficient grounds to believe that the act could be used to launder criminal proceeds or finance terrorism, the notary may refuse to perform it. A documented refusal on this ground must be reported to Rosfinmonitoring no later than the following three working days.

Extending checks to members’ withdrawal

The new rules are significant because they cover not only sales of company interests but also members’ withdrawal from an OOO. A member’s declaration of withdrawal is included in the list under Order No. 333. Preparations for withdrawal must therefore take account of the statutory requirements for information about the client and the transaction.

Practical significance for business

For companies, the rules increase the work required at the preparatory stage of transactions:

  • Financial documents. The documents required should be agreed with the notary in advance; information on the source of funds should be prepared where necessary.
  • Timing. Additional requests may extend preparation, so transactions should be planned with sufficient time in reserve.
  • Compliance arrangements. Internal procedures should enable prompt and accurate responses to requests from notaries and supervisory authorities.

The precise nature of the notarial act, information about the parties and the ability to substantiate the circumstances of the transaction matter to its participants. Agreeing documents in advance helps organise preparation, but does not guarantee notarisation or replace the notary’s independent assessment.