Herald

Identification of Сounterparties by 115-FZ: Globas Сapabilities

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In the context of increasingly stringent requirements for business transparency, companies increasingly need to not just formally check their counterparties, but also understand with whom exactly they are building business relationships. Identification of clients and counterparties is becoming an important part of risk management, internal control, and business protection systems.
In a real-case scenario, this raises a number of questions: what information needs to be verified, how to identify beneficial owners, where to look for information on PEPs, sanctions restrictions, and other risk factors. Inconsistency of the sources and the need to compare large volumes of data significantly complicate such work and increase the likelihood of missing important information.
Identification of companies within the framework of the Law No. 115-FZ is a mandatory procedure for organizations working with clients and funds. The main goal is to prevent money laundering and terrorist financing. Despite the formal nature of the requirements, actually we are talking about a basic check: with whom exactly the business is being conducted and what risks this may entail.

Who needs to identify clients

The requirements of the Law No. 115-FZ apply not only to banks. The obligation to identify clients has been established for a wide range of organizations, including:
  • banking institutions and non-bank financial institutions
  • insurance companies
  • securities market professionals
  • leasing and factoring companies
  • organizations that carry out money transfers
  • a number of non-financial organizations, including in cases of providing intermediary services or working with large transactions
In other words, if a company is involved in financial transactions or could potentially be used to conduct questionable transactions, it is subject to compliance control requirements.

What identification involves

Identification is not only a collection of basic company details such as name, TIN and address. As a rule, it involves a deeper check, including several key areas.
1. Beneficial Owners Check
It is important to establish who ultimately controls the company and benefits from its activities. These may be individuals who directly or indirectly own shares in the business or exercise a decisive influence on decision-making.
2. Identification of Politically Exposed Persons (PEPs)
It is necessary to determine whether the owners, executives or other related persons are classified as politically exposed persons or are among their close relatives. Such individuals are considered to be in a high-risk category and are therefore subject to increased scrutiny.
3. Screening Against Sanctions Lists
The company, its owners and executives must be checked for inclusion on sanctions lists. Working with such counterparties can lead to serious legal, financial and operational consequences.
4. Assessment of Business Reputation and Risk Factors
In addition, companies analyze the presence of negative information, litigation, signs of bankruptcy, as well as other factors that may indicate the unreliability of a counterparty.
Together, this type of verification allows for a more complete understanding of a client or counterparty and reduces the likelihood of making risky decisions.

Role of regulators and compliance monitoring

Compliance with the requirements of the Law No. 115-FZ is under constant government control, primarily by Rosfinmonitoring (Federal Financial Monitoring Service). This body performs financial intelligence functions and coordinates the system of combating money laundering and terrorist financing.
Entities subject to the law are required to:
  • register the personal account on the Rosfinmonitoring portal
  • regularly update information about yourself
  • send information about suspicious transactions and clients
In particular, if entities refuse to provide services to a client due to identified risks, the relevant information may also be transferred to Rosfinmonitoring. This creates a unified data exchange system that allows for the identification and tracking of potentially risky transactions and market participants.

Why does business need it

At first glance, the requirements may be perceived as a formality, but in practice they are aimed at protecting the company itself. Verification of clients and counterparties allows you to:
  • reduce the risk of involvement in illegal schemes
  • avoid financial and reputational losses
  • build transparent and secure business processes
  • increase trust with partners, banks, and regulators
Having a well-established compliance control system is becoming an essential element of sustainable and responsible business operations.

Liability for non-compliance

Failure to comply with the Law No. 115-FZ may result in serious consequences. Among them:
  • fines and administrative liability
  • suspension of account transactions
  • license revocation (for regulated entities)
  • increased attention from regulatory authorities
  • reputational losses and loss of trust from partners
In some cases, violations may have more serious legal consequences if they involve participation in illegal activities.

Globas Solutions

In practice, compliance with the requirements of the Law No. 115-FZ is associated with a number of difficulties. There are no unified and comprehensive registers of politically exposed persons available to the public, sanctions lists are fragmented, and assessing business reputation and risk factors requires analyzing information from a large number of sources. As a result, companies are forced to collect, collate, and verify information themselves, which increases labor costs and creates the risk of missing important data.
Therefore, many subjects of the Law No. 115-FZ use specialized solutions. One of such solution is Globas.
Globas provides a set of tools for verifying and identifying clients and counterparties as part of compliance control:
1. Beneficial Owners Check
Globas helps to build an ownership structure and identify the ultimate owners of a company, including in the presence of complex corporate relationships.
2. Identification of Politically Exposed Persons
Globas implements verification of affiliation with Russian and foreign politically exposed persons. The system uses an extensive database, which allows you to identify such signs without manually searching through multiple sources.
3. Screening Against Sanctions Lists
The system enables automated verification against key sanctions lists, reducing the risk of interacting with contractors subject to restrictions.
4. Assessment of Risks and Business Reputation
Globas helps identify unreliability factors, analyze risks, and form a more holistic picture of the company, its owners, and associated parties.
Thus, using Globas brings an automation of a significant portion of compliance procedures, reduces the workload on employees, and improves the quality of client and counterparty verification.
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Herald

Financial analysis of companies from China, Hong Kong, the UAE, Turkey and India using Globas

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Under the conditions of reorientation of foreign economic relations to the East and South, Russian business increasingly contracts with companies from China, India, Turkey and the UAE. However, working with new jurisdictions also carries new risks: differences in reporting standards, non-transparency of ownership structures, legal and enforcement proceedings, as well as sanctioned counterparty and its owners. Analysis of a foreign company in such a situation becomes a critical element of the transaction.

Availability and specifics of financial statements by country

When working with foreign counterparties, it is important to take into account that the level of transparency of financial data varies significantly depending on the jurisdiction.
In a number of countries, financial statements are publicly available and can be obtained relatively quickly. In other jurisdictions, access to data is limited and obtaining information requires additional inquiries and analysis.
This means that:
  • a unified approach to checking companies does not work
  • data sources and depth of analysis are always country-specific
  • lack of financial data may itself be a risk factor

CountryAvailability of financial statements
ChinaFinancial statements are publicly available mainly only for listed companies. For private companies, information is limited and often requires an additional request.
Hong KongFinancial statements are available for publicly listed companies. For private companies, financial statements are not disclosed.
the UAEFinancial statements are not disclosed in the official sources.
TurkeyPublic companies disclose financial statements in full, but access to private companies' statements is limited.
IndiaOne of the most open systems - balance sheet and profit and loss statements are available even for small companies.

What to look for: key financials and indicators

When analyzing a foreign company, it is important not only to obtain financial statements, but also to interpret them correctly.
Key indicators:
  • revenue and profit dynamics - sharp fluctuations may indicate business instability
  • structure of assets and liabilities - high debt burden increases risks
  • liquidity - the company's ability to meet its obligations
  • losses over several accounting periods
When checking a foreign counterparty, it is important to use basic financial ratios.

IndicatorDescription
Current liquidityCurrent Ratio = Current Assets/Current Liabilities | Standard: >1.5 (the company can cover short-term debts) | Risk: <1 (solvency issues)
Solvency - debt burdenDebt to Equity Ratio = Total Debt/Equity | Standard: <2 (moderate debt burden) | Risk: >3 (high risk of bankruptcy)
ProfitabilityNet Profit Margin = Net Profit/Revenue × 100% | Standard: depends on the industry (2-5% for trade, 5-15% for manufacturing) | Risk: negative for several years in a row
EfficiencyROA (Return on Assets) = Net Income/Assets × 100% | ROE (Return on = Net Income/Equity × 100% | Risk: ROA <2%, ROE <5% for several years
Operational indicatorsRevenue Growth | Asset Turnover | Receivables Turnover
N.B.: the indicators themselves do not give a complete picture - the key importance is the dynamics for 2-3 years.

Signs of increased risk

Financial statements allow to identify typical signs of troubled companies.
Signs of fictitiousness:
  • high revenue with minimal assets
  • lack of fixed assets
  • lack of employees costs
  • significant receivables with no cash
Signs of financial problems:
  • negative equity
  • Current Ratio <1
  • debt growth faster than revenue
  • losses for several years in a row
Signs of manipulation:
  • sharp revenue growth without assets growth
  • profit with negative cash flow
  • inconsistency of financial and tax reporting
  • abnormal growth of accounts receivable
Such signals require additional check and adjustment of the terms of the transaction.
One of the common mistakes is the analysis of the last reporting period only.
In fact:
  • one year may be "artificially improved"
  • timelines may hide systemic problems
  • real risks are manifested in dynamics
N.B.: to analyze at least 2-3 years of financial data.

Practical use and complexities of manual analysis

Financial analysis allows you to:
  • assess the stability of the counterparty
  • identify signs of fictitiousness or shell company
  • determine the likelihood of bankruptcy
  • choose a secure work model (prepayment, postponement, scrapping the deal)
At the same time, in some cases (China, the UAE), financial information is limited - then it is necessary to use additional sources and verification tools.
Manual analysis of foreign companies requires:
  • access to various registers and sources
  • understanding of local legislation
  • translation and interpretation of financial statements.
In fact, this takes considerable time and does not always give a complete result.
The Information and Analytical system Globas provides comprehensive check of foreign companies, allowing you to compensate for the lack of open data, reduce risks in international activities and minimize the need for manual collection and analysis of information from various sources.

Instant search and reports for companies all over the world in Globas

In the context of growing international cooperation, it is especially important to quickly obtain reliable information about foreign counterparties.
A new service is available in Globas, which allows you to find foreign companies in no time and receive structured information on them.
The service provides access to the database of more than 380 million companies from 220+ countries and territories, which allows checking counterparties in almost any jurisdiction.
Depending on the country and availability of sources, the report may include:
  • name and registration data
  • contact details
  • management and shareholders
  • activities
  • subsidiaries and affiliated companies
  • financial statements
  • creditworthiness
  • media check
The scope and details of information depend on the jurisdiction, legal form, lifetime of the company and the specifics of data disclosure.
Key features of the service for searching and checking foreign companies:
  • speed of data receiving - from several minutes to 1–2 hours
  • format - structured report in PDF in Russian
  • global coverage - search for more than 380 million companies
  • convenience of work - ordering directly from the search results
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