Translation. Region: Russian Federation –
Source: Central Bank of Russia
An important disclaimer is at the bottom of this article.
Active market cleansing is a thing of the past, but the institution of business reputation is still very relevant today.
Since 2022, the Central Bank of the Russian Federation has stopped publishing information on its website that could lead to sanctions. However, it plans to end this pause and require financial institutions to disclose qualitative characteristics of their ownership structure based on anonymous criteria. The regulator promises that the new disclosure format will not allow the identification of the organizations' owners, but is prepared to fine-tune its approach if necessary. Lyudmila Tyazhelnikova, Director of the Bank of Russia's Department for Admission and Termination of Financial Institutions, discussed in an interview with Interfax what other legislative changes the Central Bank is preparing regarding information disclosure and the institution of business reputation for financiers.
For almost three years now, banks have not disclosed information about their beneficiaries due to the risk of sanctions, which often seems non-transparent to market participants. Most banks in the system are already under severe restrictions. Is there any discussion about the possibility of banks disclosing their shareholders in their financial statements or on their websites?
As a reminder, in 2022, the Bank of Russia authorized banks and other financial institutions not to disclose information sensitive to sanctions risks, including ownership structure and management information. This wasn't a ban; some organizations continue to publish this information, but they are few. For example, out of 352 active credit institutions, only 3 banks disclose their ownership structure—less than 1%. Among microfinance companies, 28% continue to disclose information, 12% of management companies, 8% of insurers, and 6% of non-state pension funds (NSPFs). The option to withhold ownership structure will remain in effect next year. However, recognizing that the market requires high-quality information about the ownership structures of its participants, we proposed the concept of anonymized disclosure, without specific details about individuals and their stakes. In the summer, we conducted a survey involving over 400 organizations and also held preliminary discussions with market participants about our approach.
What are we proposing? We intend to discontinue the publication of data identifying ownership structure participants. However, we plan to disclose information that essentially qualitatively characterizes the ownership structure, using a set of criteria we have defined in consultation with the market. This approach is planned for disclosing data on banks, non-state pension funds, insurance and management companies, and microfinance companies. It is important to note that the Bank of Russia will continue to receive information on ownership structure in the same format and will continue to exercise oversight and regulatory functions over ownership structure participants.
– What criteria do you propose to include in the disclosure form?
– There are 12 criteria. This is a list of facts characterizing the participants in the ownership structures, the relationships between them in terms of control or influence over the financial institution, their business reputation and financial position. For example, the criteria include: "The presence of persons who control and/or significantly influence the financial institution," "The presence in the ownership structure of persons to whom the Bank of Russia has issued orders in connection with the recognition of their business reputation and/or financial position as unsatisfactory," "The presence in the ownership structure of hostile non-residents," "The presence of a transaction to acquire shares (interests) in a financial institution carried out without the statutory consent of the Bank of Russia," "The presence in the ownership structure of persons whose license has been revoked (cancelled) by the Bank of Russia or who have been excluded from the register." Responses to the criteria can be "yes," "no," or "not applicable." Thus, each market participant will have their own unique set of answers, which will then be published. Moreover, if a market participant does not wish to disclose information about itself in such an anonymous format, it can return to full disclosure, as was the case before 2022.
– So, banks and non-profit organizations won't have the option of disclosing nothing at all, as they do now? Will you either disclose in this format or return to full disclosure?
Yes, that's right. Either the participant discloses information based on the criteria we propose or reverts to full disclosure, as was the case previously. We decided to fill out the anonymized ownership structure disclosure form ourselves, based on the data we have received from financial market participants and additional information held by the Bank of Russia. After receiving the financial institution's consent for such approval, we allow 20 days to two months. The disclosure form with the completed market participant information will then be published on the Bank of Russia's website.
– Is there a risk that this form will still allow the identification of organization owners?
"There is no such risk. When we discussed our approaches with the market, a number of organizations expressed concerns about this possibility. We created such forms of anonymized structures for each market participant who approached us and presented them with the results. I can say that the market participants were satisfied with the qualitative characteristics, and their concerns were allayed."
In our communications with the market, we also asked for an assessment of the identification risks. As a result, we concluded that identifying the owners of organizations during information disclosure based on anonymized criteria is impossible. However, since this is a completely new approach, a new disclosure format, everyone will need to get used to it—both market participants and third parties, such as investors, experts, journalists, and anyone interested in the ownership structure of market participants. I don't rule out the possibility that, given the experience of using this new format, we will see the need to fine-tune our approaches.
We have publicly traded banks and non-profit organizations that have a free float. Will there be any special requirements for disclosing their ownership structure?
We believe it's inappropriate to reflect such specifics, given that, for example, public listings account for less than 3% of credit institutions. Listing information is publicly available and can be obtained independently by interested parties, and it doesn't create uncertainty regarding control or significant influence over financial institutions.
– Will the form be published on the pages of banks and non-financial organizations on the Central Bank website?
Previously, ownership structures were published on the Bank of Russia's website in our "Financial Market Access" section, under the "Ownership Structures of Financial Market Participants" subsection. We plan to publish the structure there in an anonymized format.
– How often will the form be updated?
– As soon as the Bank of Russia receives information about relevant changes in ownership structures.
– When will the new form for disclosing ownership structure come into effect?
We plan to develop and adopt the necessary regulations in 2026. I believe that, given our release-based approach to enacting these regulations, they will not come into force until April 1, 2027.
In recent years, fewer players have left the market. The Central Bank has been revoking licenses from banks and other financial market participants less frequently. How do you assess the current business reputation in the financial sector?
The concept of business reputation remains highly relevant today. While the process of actively purging the market of weak and unscrupulous players is a thing of the past, our database of individuals with unsatisfactory business reputations is still growing. The number of individuals in the "blacklist" has remained relatively stable for several years, standing at approximately 7,000 until 2023; currently, more than 9,600 people are included.
This dynamic is linked to the growing range of financial market participants whose managers and owners' business reputations are now being assessed. For example, in recent years, credit cooperatives, microcredit cooperatives, and pawnshops have been included in this process. For some participants, the number of business reputation assessment criteria has increased. For example, previously there were only three business reputation criteria for credit cooperative managers, but now there are 17.
In 2025, 1,143 individuals were included in the "black" database. The trend in previous years varied: in 2021, 1,611 individuals were included, which was due to new business reputation requirements for microcredit cooperatives and pawnshops. Approximately 700 individuals were included in each of the years 2022-2024. The increase in the number of individuals included in the database in 2025 was due to the exclusion from the register of a number of financial institutions, such as microcredit organizations, credit cooperatives, and pawnshops (31 microcredit organizations, 472 credit cooperatives, and 18 pawnshops) due to violations.
The number of individuals removed from the database has been steadily declining (1,757 in 2021, 1,089 in 2022, 374 in 2023, 156 in 2024, and 146 as of December 8 of this year). The main reason for removal is the expiration of the individual's time in the "black" database.
– Is there any way to find out if you’re in the database or not?
– Legislation provides for obtaining a certificate of the presence (absence) of information about an applicant in the database by submitting a written request to the Bank of Russia in the prescribed manner. Waiting for a response takes a certain amount of time. However, a more expeditious access to this information is available on the Unified Portal of State Services, where "Service for providing information on the presence (absence) of information about the applicant in the Bank of Russia databases"Responses arrive within minutes. Since the service's launch in 2018, approximately 203,000 requests have been registered on the Unified State Services Portal, with 6,700 of them receiving responses confirming the availability of information in the database. Some users request the site repeatedly.
You mentioned the Unified State Portal of Public Services (EPGU). Is it possible for financial market participants to interact with the Bank of Russia on other market access issues through this portal?
– Yes, of course. Currently, the Unified State Portal of Public Services offers five Bank of Russia services related to our department's activities. In 2017-2018, the first two services were published on the Unified State Portal of Public Services: the business reputation service, as I've already mentioned, andservice for providing information about financial market participantsIn 2025, three more new services were added to the Unified Public Services Portal, including the ability to send notifications of changes in the right to dispose of shares (interests) of a financial organization in a convenient electronic format, and also receive information aboutpresence/absence of information about oneself in the lists of controlling persons, which are maintained by the Bank of Russia.
We are always open to the market and interaction, so we are constantly improving our current services and looking towards developing the level of interaction in an electronic format.
– On what grounds do you currently primarily include people on the “blacklist”?
"The main reason for inclusion in our database remains license revocation and exclusion from the registry. Market manipulation is also a ground for inclusion in our database, although such individuals are few in number. The number of individuals included in the database based on decisions by authorized bodies has increased, for example, court decisions on intentional/fictitious bankruptcy, conviction for causing damage to an organization, personal bankruptcy, and other negative circumstances. Interestingly, there are still those who provide us with a fake higher education diploma for qualification assessment. Such cases are currently occurring, and unfortunately, they are not isolated (for example, in 2023 there were 85 such individuals, in 2024 – 47, and in 2025 – 26).
– Is this a relatively new trend or have you encountered this before?
This criterion was introduced for banks in 2014 and expanded to all financial institutions in 2018. The discovery of a significant number of inaccurate educational information is partly due to the expansion of the range of individuals we check for eligibility. The Bank of Russia has all the tools to assess the accuracy of the information provided, such as exchanging information with federal databases of various agencies to verify higher education and required work experience. Most often, these are individuals who had not previously applied to us for qualification assessment and who worked in positions where we do not verify educational information. For example, we do not verify the education of board members. But then someone decides to become, say, deputy chairman of a bank. They may have extensive experience and think they will pass the check. They present a diploma, we examine it, and it is fake. This applies to diplomas issued in the 1990s—what are called "diplomas bought in a subway underpass." We don't see any counterfeit diplomas issued in the modern education system. Consequently, individuals with counterfeit diplomas are immediately added to the "black" database, as they knowingly submitted false information to the Central Bank.
– Are amendments being prepared to improve the criteria for the business reputation of bank top management?
Yes, such amendments are currently being prepared for discussion in the second reading and apply to more than just banks. The bill, which we call "Business Reputation 2.0," proposes clarifying and unifying certain requirements for officials and owners of credit institutions, insurance companies, non-state pension funds, management companies, microfinance organizations, professional securities market participants, payment processors, and consumer credit cooperatives.
For example, the following criteria for an unsatisfactory business reputation are being introduced: the presence of information about a person on the list of organizations and individuals provided for by AML/CFT legislation, regarding whom there is information about their involvement in extremist activity or terrorism; the presence of a decision to freeze (block) funds or other property of a person, adopted by the authorized body implementing functions to counter the financing of terrorism.
The criterion related to bringing a person to administrative responsibility more than three times within one year in the field of entrepreneurial activity or in the field of finance, taxes and fees, insurance, or the securities market is abolished, since it does not indicate a real threat to the interests of the financial organization and its creditors, clients, and the violations, as a rule, are of the same type.
At the same time, the criteria of business reputation are supplemented by facts of bringing a person to justice for his participation in the creation of financial pyramids.
Among the key amendments for the second reading are the introduction of requirements for the deputy sole executive body for information security in credit institutions, insurance organizations, management companies, non-state pension funds, and microfinance companies (except for microfinance companies that form the support infrastructure for small and medium-sized businesses) into relevant laws. Requirements are established for the qualifications and business reputation of such an official, and, importantly, the requirement that they be Russian citizens. The criteria for business reputation are the same as for other officials of a financial institution. Qualification requirements are determined based on the professional standard "Information Security Specialist in the Credit and Financial Sector."
– Will the requirement to have a deputy chairman for information security be established only for systemically important banks or for all credit institutions?
– It is proposed to introduce this regulation for all credit institutions at the same time, as well as for a number of financial institutions that I mentioned earlier.
– From what year should bank boards be appointed with deputy chairmen for information security?
The bill clarifies the requirements for the deputy head responsible for information security, while the requirement for such individuals in organizations was established by the presidential decree "On additional measures to ensure information security in the Russian Federation" of May 1, 2022. We expect the bill to be adopted during the spring session of 2026.
– What other changes are you preparing in this draft amendments?
– Qualification requirements for managers and chief accountants of financial institution branches are being eliminated. With the growth of digitalization and centralization, the importance of branches is diminishing, and market participants are approaching the Bank of Russia with a proposal to lower these requirements. At the same time, the requirement for higher education for board members of non-state pension funds and management companies is being eliminated.
– Why, according to the Central Bank, is higher education not a criterion for the business reputation of board members?
Experience shows that, as a rule, board members of financial institutions have a higher education. This requirement was previously lifted for insurance companies, but it was never introduced for credit institutions. Therefore, the abolition of this requirement for board members of non-state pension funds and management companies is aimed at aligning approaches with other financial market participants, reducing the regulatory burden on the market, and will not entail additional risks for the financial institution's operations.
– Will higher education remain a mandatory requirement for bank board members?
We're discussing this issue with the market. Most agree that members of the executive bodies of financial institutions responsible for day-to-day operations should have a higher education.
Incidentally, we compiled a generalized profile of the sole executive body of a financial market participant (as of January 1, 2025), which shows that the majority hold a higher education in economics. Most executives are members of Generation X. The age of executives is generally between 40 and 60 years old, unchanged from January 1, 2022. The youngest executive is 31 years old. The length of tenure in this position at the same organization varied, ranging from up to two years to over 11 years. The most popular "financial" names among women are Olga and Elena, and among men, Andrey and Sergey.
Regarding the heads of systemically important banks, as of January 1, 2025, there were no women among them. In July of this year, a female candidate was approved for the position of head of a systemically important bank, and she currently leads it. Among all credit institutions, women make up 32% of the sole executive bodies. Incidentally, the highest proportion of women among the top executives is in non-state pension funds (NSPFs) – 43%.
A bill is currently pending in the State Duma that would empower the Bank of Russia to maintain a unified register of financial market participants (URFMP). The document was passed in its first reading. What changes are planned for the second reading?
This bill is currently being actively prepared for its second reading. The key amendments, already adopted in the first reading, include the transition to a register-based model for admission for all financial market participants, as well as the elimination of paper-based licenses for credit institutions, non-state pension funds, and insurance companies. Once the law is passed, it will no longer be necessary to request information from each specialized registry; instead, it will be possible to obtain a single extract from the Unified State Register of Financial Markets (USRFM) for all types of activity.
The procedure for notifying the regulator of changes to a financial market participant's information (registry data, such as name, address, legal form), its officers, and ownership structure is being standardized. Currently, a participant engaged in multiple financial market activities must notify us of the same changes for each activity. In the future, a single notification containing the relevant information will be sufficient.
The amendments for the second reading take into account proposals from financial market participants and interested government agencies, as well as changes to legislation that occurred after the first reading.
Specifically, it is envisaged that the aforementioned extract from the Unified State Register of Financial Markets (USRFM) will be obtained through the Gosuslugi website. The termination date for the right to operate in the financial market has also been clarified – this will be the moment the regulator discloses the relevant information on its official website. For example, when does a bank's operations cease if its license is revoked? In the Bank of Russia's informational announcements, we already indicate the time of information disclosure. This is especially important for exchange trading, settlements, and the determination of liabilities. The requirements for the submission of ownership structure information have been standardized, and information on new financial market participants, such as branches of foreign banks, indicator administrators, payment processors, and a number of others, has been included. If the law is passed during the spring session of 2026, the expected entry into force is March 2027. All of the Bank of Russia's IT components are ready to implement its provisions.
– Looking at the statistics, we can see a trend toward an increase in the issuance of RNKO licenses. What is the reason for this?
Indeed, 19 NPOs have been registered since the beginning of 2022, including 10 this year. The documents of another 10 NPOs are under review. We see that this type of activity is in demand among market participants. The growth in the number of NPOs is driven by both the changing geopolitical situation and the introduction of modern technologies for electronic payments and banking transactions.
– Are there any requests to obtain a full banking license?
– No. The market is saturated with these financial institutions. Currently, banks are increasingly seeking to expand their range of operations, obtaining licenses to accept deposits from individuals, and to conduct banking operations with precious metals and foreign currencies.
– How many bank shareholding deals has the Central Bank approved since 2022?
– A lot. There are 445 of them among credit institutions. And if we include all the financial institutions for which we issue approvals, that's 819. 2024 was a record year in this regard, with 267 approvals issued, 142 of which were to credit institutions. Results for 2025 are expected to be comparable to 2024.
– Are there any applications for branch registration from foreign banks?
No such applications have been received yet. This may be due to geopolitical risks and very conservative approaches to the potential opening of branches by foreign banks. Meanwhile, amendments to the relevant law are currently being prepared, providing for:
– reduction of the minimum security deposit from 1 billion rubles to 90 million rubles;
– expansion of the list of banking operations permitted for branches of foreign banks by granting the right to open and maintain bank accounts for individuals, open and maintain bank accounts for individuals and legal entities in precious metals, carry out transfers of funds on such accounts, as well as a list of transactions with precious metals that are not related to banking operations;
– an increase from 50% to 75% of the quota for the number of employees of a branch of a foreign bank who are foreign citizens and stateless persons;
– granting the right to a branch of a foreign bank to open internal structural divisions.
– In 2022, the Central Bank of the Russian Federation launched a service for whistleblowers who can anonymously submit information about shadow controllers of financial institutionsIs this service in demand? Are there many messages, and were they useful to the Central Bank?
"As soon as we announced this service, we received 40 requests. Some of them were very helpful: we worked with financial institutions, and they made the necessary changes. After that, we didn't receive any more requests."
– Why?
"Because information about ownership structures is no longer public, and the service helps identify the "shadow controllers" of financial institutions. We want to return to this practice, expand this anonymous service on the Bank of Russia's website, and extend it to executives as well. For example, it's more obvious to an employee of a specific financial institution that the organization's processes are being "steered" not by the official manager, but, say, by an advisor. Or perhaps the manager never even comes to the office. We hope that such practices will become rare, if not nonexistent. Both we (the department – IF) and representatives of the Central Bank's supervisory divisions, by inviting financial institution executives to meetings, actively engage with top officials and resolve many emerging issues in close collaboration."
– What other bills related to controlling persons are being prepared for adoption?
The Bank of Russia's right to establish a list of "offshore zones" will be included in the regulation on a permanent basis. This list is used to assess the compliance of persons authorized to dispose of shares or stakes in banks and non-financial organizations. Currently, as a temporary measure, it is approved by a resolution of the Bank of Russia's Board of Directors. Previously, we relied on the Ministry of Finance's corresponding "blacklist" in our decisions. A bill has now been submitted to the State Duma stipulating that the Bank of Russia will establish its own list of countries and territories where legal entities and individuals with the appropriate citizenship (nationality) authorized to dispose of shares or stakes in banks and non-financial organizations cannot be registered.
– Does the Central Bank have plans to simplify the approval process for candidates for leadership positions?
We're developing a new service, ProFinKadry. We see a serious talent shortage in the financial market. Market representatives are constantly telling us about it. To find a suitable candidate for a vacancy, financial market participants can review up to 10 candidates.
Let me remind you that the Central Bank website is already working Business reputation and qualification assessment designer (KODRIK). This service helps preliminarily assess whether a candidate's work experience, education, and business reputation meet the established requirements of the financial market for candidates for specific positions. Anyone can independently verify themselves against a set of criteria.
We decided to go further and create another service. Unlike KODRIK, the ProFinKadry service will provide a personalized, rather than anonymized, assessment. It is intended that any candidate will be able to contact the Bank of Russia to request an assessment of their qualifications and business reputation for a specific position at a specific organization, or to learn which positions approved by the Bank of Russia they are eligible for. For example, if you are applying for a deputy chairman position at a certain bank, you can send us a request. Currently, candidate screening is handled by the employer, who spends resources and time on these procedures. We believe that candidates may benefit from contacting us regarding a specific vacancy or seeking professional advice, and we will provide them with information about which positions and financial institutions they are eligible for.
We plan for candidates to contact us and receive a certificate through their personal account or through Gosuslugi, and then be able to present the received document when applying for a job. This will be easier for employers than checking the documents themselves. I expect the service to launch in 2027.
What other services is the Central Bank developing to reduce the burden on market participants?
We've begun developing "out-of-the-box" solutions for registering or obtaining a license for the most in-demand types of financial institutions. For each type, we've described a standard set of required documents and added templates. For example, templates for business plans, charters, minutes of the general meeting of founders/resolutions of the sole founder, petitions, and minutes of the board of directors, where the organization can include its information. This will make life easier for market participants: it will help avoid common errors that we identify when they submit documents for review, and it will help save time during this process.
We have already published such “boxed solutions” for RNKO on the Bank of Russia website (OOO, JSC) insurance companies in the form of an LLC, investment advisors (for financial institutions), investment platform operators, payment acceptance operators (unitary enterprise, business entity), representatives of bondholders, management companies of specialized societiesThey are posted on the pages of the same name. in the admission procedures navigator on our website. And we'll continue to develop this area more and more, because it's in demand.
Interfax
Please note: This information is raw content obtained directly from the source. It represents an accurate account of the source's assertions and does not necessarily reflect the position of MIL-OSI or its clients.
