Russian Legislation Update - 3 – 23 March 2014

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In This Issue:

- Banking

- Anti-Money Laundering

- Electric Power/Renewables

- Excerpt from Banking:

On 5 December 2013 the Bank of Russia issued Instruction No. 147-I “On the Procedure for Inspecting Credit Organizations (Their Branches) by Authorized Representatives of the Bank of Russia.”

The Instruction was registered with the Ministry of Justice on 21 February 2014.

Instruction No. 147-I represents an updated version of Instruction No. 105-I.

It provides, among other things, for the procedures of submission by an inspected bank of documents in electronic format, and also provides for the possibility of requesting information (to check the data obtained from the bank) from other banks that are not clients or correspondents of the bank. The bank’s manager is to provide an inspection act to the board of directors no later than 10 business days after its examination (as opposed to 15 days previously).

The Instruction will enter into force on 24 March 2014.

On 25 February 2014 the Bank of Russia issued Instruction No. 149-I “On Organization of Inspections by the Bank of Russia.”

Instruction No. 149-I represents an updated version of Instruction No. 108-I.

It provides, among other things, that specialized inspections (i.e. inspections with respect to a particular area of a bank’s business – compliance with the mandatory reserves’ requirements, asset compliance, cash operations, and operations with cash foreign currencies and checks) are to be conducted within up to 20 business days. It also expands the list of grounds for conducting unscheduled inspections by adding “changes in the business prospects” of the bank, including its exposure to risks and control quality.

The Instruction will enter into force on 24 March 2014.

Please see full update below for more information.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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