115-FZ and Account Restrictions: What to Prepare in Advance
Russian banks assess the overall business model, not an isolated payment. Documentation and economic substance must tell the same story.
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Practical guidance for Chinese manufacturers, owners and export executives.
Russian banks assess the overall business model, not an isolated payment. Documentation and economic substance must tell the same story.
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The Russian entity should protect the owner’s control over money, contracts, data and executive authority.
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Distance must not mean loss of control over corporate rights, accounts, contracts, customer data or key access.
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A director needs enough authority to operate, but critical decisions and assets require layered owner control.
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Contracts, customs documents, payments and accounting records must describe one consistent transaction.
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