The Bank of Russia has sent out to credit institutions a new form for reporting on money transfers between individuals. It follows from it that the Central Bank will request information about all p2p transactions (from an individual to an individual), including the personal data of senders and recipients of funds.

This follows multiple laws passed this year to bypass any legal limits for total tracking, a sit required court orders before.

According to Oleg Mashtalyar, Deputy Chairman of the Board of Sovcombank, the Bank of Russia will begin risk-oriented monitoring of p2p transfers from January 2022. "The Central Bank has notified that it plans to periodically request information on p2p transfers using this form from 2022," added a QIWI representative.

What data are of interest to the Central Bank:

As follows from the document, the report should include all incoming and outgoing money transfers between individuals, which are carried out according to the following scenarios:

• from card to card;
• from account to account;
• from an electronic wallet to an electronic wallet, from a card to a wallet and vice versa;
• from the subscriber's account of the telecom operator to the wallet or card and vice versa;
• payments through the Fast Payment System;
• cross-border transfers of funds by individuals;
• money transfers without opening an account, including through payment terminals of paying agents;
• transfers of an individual between their own accounts within the same credit institution;
• transfers through money transfer systems, for example, Western Union, CONTACT, etc.

The p2p operations do not include the transfer of funds to deposit accounts, accounts for repayment of loans, brokerage / investment accounts, commissions of credit institutions for servicing, as well as transfers in favor of legal entities and individual entrepreneurs, the Central Bank explained.

Information on each transaction must contain the card numbers of the sender and recipient of funds, bank data, a unique client ID (issued by a credit institution), the purpose of payment, the amount of funds transferred, the date and time of the transfer, the country code of the sender and recipient, etc. Issuing banks, acquiring banks, banks providing Internet services for p2p transfers, as well as shops and legal entities, if they provide online services for transfers, etc. will have to report.

Requests will be generated for all money transfers for a certain period. In some cases, the Central Bank may request information on individual transactions. For example, data on specific cards or specific individuals (ID, passport, TIN, telephone).

The new reporting form was developed after the publication of methodological recommendations (16-МР), which the Central Bank issued in early September. In them, the regulator identified the signs of cards and electronic wallets for accepting payments to illegal online casinos, organizers of financial pyramids, forex dealers and cryptocurrency exchangers (cards are issued to individuals, and payments to illegal businesses are made as p2p transfers) ... Banks are advised to track such cards and wallets and block transactions on them. The Central Bank attributed several "anomalies" to the signs by which it is possible to identify suspicious payment instruments, among them the following:

• An unusually large number of counterparties - individuals as both payers and recipients of funds. For example, more than ten per day and more than 50 per month.
• An unusually large number of operations for crediting and debiting funds, carried out with individuals. For example, more than 30 operations per day.
• Significant volumes of transactions for writing off and crediting funds between individuals. For example, more than 100 thousand rubles. per day, more than 1 million rubles. per month.
• To the card or wallet, transactions for payment for goods and services are not carried out.