Money sent to a foreign partner simply does not reach. A few hours later, a call or letter from the bank with the subject "Explanations of the operation are required." The payment has been frozen indefinitely.
This is not a technical glitch or a manager's mistake. The bank's internal mechanism, the bank's foreign economic activity compliance, has been fully operational. Its main task is not to protect your business, but the bank itself from regulatory risks. Understanding this is the first step to learning how to pass these checks without loss.
Why your bank is so afraid: a look from the other side
To understand how to pass the checks, you first need to look beyond the barricades.
For any bank, your foreign trade transaction is a high—risk area. Any operation that the regulator (represented by the Central Bank) considers suspicious may result in a huge fine or even revocation of the license for the bank.
Therefore, every compliance officer whose work is regulated by Law 115-FZ of the Foreign Economic Activity, looks at your deal as a potential threat. He must make sure that your money is not financing something illegal or a scheme to circumvent sanctions. By understanding their fear, you will understand what documents they need and why they are requesting them.
Friend or foe: what markers does the bank use to scan your transaction
To put it simply, checking currency transactions is scanning a transaction in three main directions.
- Who are you? Your business profile is being analyzed. How long have you been on the market, what kind of turnover do you have, and are such payments typical for you? A sudden and inexplicable increase in turnover is always a red flag for the monitoring system.
- Who are you paying? Your counterparty is being checked. A partner from an offshore jurisdiction? This is an almost automatic stop for deep inspection. Is he on the sanctions list? Does it have the signs of a one-day company?
- What are you paying for? The very essence of the transaction is being studied. The contract should be clear, and the amount should be adequate for the market. Paying for "marketing research" for $100,000 without a detailed contract and certificates is a direct way to delay payment abroad.
How to pass the check the first time: a practical checklist
The successful verification of currency transactions did not turn into a problem, it was necessary to act proactively. Here are some simple rules.
- Collect the "transaction passport".
Keep a single package ready: a contract, an invoice, a specification or a waybill. If the bank requests the documents, you can send them within an hour instead of searching through different folders.
- Write a clear purpose of the payment. A bad example: "Payment on account 45-B". A good example: "Payment for industrial pumps (HS code...) under contract No. 123 dated 09/15/2025, invoice No. 45-B". The more details there are, the fewer reasons the bank has for questions.
- Check the partner before the transaction. Before you get your hands on it, check the counterparty through open registries. Make sure that this is not a company that was registered a week ago.
- Do not split payments. An attempt to split a large payment into several small ones in order to escape control is clearly visible to the system and is always interpreted as suspicious activity.
Respond to the bank quickly.
When a bank requests documents for currency control, the worst thing that can be done is to remain silent or respond after two days. A quick and complete response shows your transparency and willingness to cooperate.
Ultimately, transparency and training are not additional work, but a prerequisite for normal work in international trade.
Inna Zaporozhtseva
