17 September 2025

Financial Marketplaces and Platforms in Russia: Legal Regulation of Transactions and Client Rights

September 17, 2025

BRACE Law Firm ©

Executing financial transactions on financial platforms is the process of concluding contracts (purchasing bonds, obtaining loans, etc.) on specialized internet resources that provide access to various financial services and products from different providers, such as banks and insurance companies.

Financial platforms (the "financial marketplaces") aggregate financial service providers and consumers, allowing clients to compare offers, submit applications, and execute products online without the need to visit offices in person.

What are the Advantages of Financial Platforms in Executing Transactions?

The advantages of financial marketplaces include:

Convenience, as all services are in one place, and there is no need to visit bank or insurance company offices;
The ability to compare offers from different organizations to select the most favorable terms;
Accessibility from any location with an internet connection.

Financial platforms help consumers compare offers from many sellers, select suitable terms, and conclude transactions with a financial organization or issuer remotely, regardless of the parties' location, 24/7. The operator of a financial platform (the "OFP") ensures the platform's operation.

Legal Regulation of Transactions on Financial Marketplaces

The legal framework for executing financial transactions using financial platforms is established by Federal Law No. 211-FZ dated July 20, 2020, On the Execution of Financial Transactions Using a Financial Platform (the "Law on Financial Platforms", the "Law on Financial Marketplaces").

The Law on Financial Marketplaces defines a financial platform as an information system that facilitates interaction between financial organizations or issuers and financial service recipients via the internet to enable financial transactions, access to which is provided by an OFP. An Operator of a Financial Platform is a legal entity organized as a joint-stock company that provides services related to enabling financial transactions between financial organizations or issuers and financial service recipients using a financial platform, and which is included by the Bank of Russia in the register of financial platform operators. The OFP is not a party to the financial transactions executed using the financial platform. As of September 16, 2025, the register of financial platform operators includes 12 companies.

Financial organizations, in turn, are credit organizations and non-credit financial organizations that have acceded to the OFP service agreement for the purpose of executing financial transactions with financial service recipients, including on behalf of issuers.

Financial Transactions on Financial Marketplaces

Under the Law on Financial Platforms, financial transactions are transactions executed between financial organizations or issuers and financial service recipients using a financial platform for the provision of banking services, insurance services, services in the securities market, transactions with financial instruments, transactions to secure the performance of credit (loan) obligations, and other transactions for the provision of financial services provided for by the financial platform rules, with the exception of bank account (deposit) agreements concluded in connection with the entrepreneurial activities of financial service recipients.

Information regarding financial transactions executed using a financial platform shall not (Article 14 of the Law on Financial Marketplaces):

Mislead financial service recipients;
Contain false information, including information regarding a financial organization's right to execute a financial transaction if the said organization lacks the necessary licenses, permits, or accreditations, or if such organization is not included in the relevant register;
Contain guarantees or promises of future performance (investment yield), including those based on actual past performance, if such performance (investment yield) cannot be determined at the time the relevant contract is concluded.

Information about a financial transaction executed using a financial platform must contain details regarding all possible expenses of the financial service recipient in connection with the execution of such a transaction.

When an OFP posts information about financial transactions by comparing the terms of such transactions, any direct or indirect influence of the remuneration received by the OFP or other conflicts of interest on the list of compared transactions and the results of such comparison must be excluded.

The procedure for executing financial transactions on financial platforms includes registration on the platform and client identification, selection of a financial product or service, conclusion of a contract with a financial organization, performance of the transaction itself, and receipt of supporting documents. All of this occurs online without the need to visit branches of banks or other financial institutions.

The following parties may act in financial transactions with securities between financial service recipients, on one side, and, on the other side:

Persons obligated under such securities;
Issuers of securities (with respect to securities issued by such issuers);
Financial organizations holding a license to carry out dealer activities that execute financial transactions based on their public announcement of sale prices for specific securities with an obligation to sell such securities at the announced prices.

In financial transactions with securities admitted to organized trading, only financial service recipients, as well as bond issuers and persons acting on their behalf (with respect to bonds issued by such issuers), may act as purchasers of the securities.

Income and other payments on securities may be transferred by the person obligated under the securities or by a depository to a special account. The OFP is not limited in the number of special accounts it may open, but they must be opened only in credit organizations. The OFP has the right to open special accounts for the benefit of financial service consumers who do not participate in concluding the special account agreement. The special account regime allows for: crediting funds for the benefit of the consumer from their bank accounts or in connection with the performance by a financial organization or issuer of obligations under executed financial transactions; crediting funds for the benefit of the consumer upon the payment of income and other payments on securities acquired by such consumer using a financial platform; crediting funds for the benefit of the consumer in accordance with Federal Law No. 177-FZ dated December 23, 2003, On Insurance of Deposits in Banks of the Russian Federation; debiting funds for transfer to a bank account or payment of OFP remuneration, or pursuant to a court decision.

Stages of Executing Transactions on a Financial Marketplace

Executing transactions on a financial marketplace involves the following stages:

Registration and Identification. The user registers on the financial platform, providing necessary personal data, after which a client identification procedure is conducted to verify their identity.
Obtaining Access. The client gains access to a wide range of financial products from different banks and insurance companies, such as deposits, bonds, investment fund units, loans, or insurance.
Conclusion of a Contract. A contract can be concluded on the platform with a financial organization providing the selected services. The contract conclusion process occurs in electronic form.
Performance of the Transaction. After concluding the contract and fulfilling all necessary conditions, the financial transaction (e.g., opening a deposit, purchasing bonds, etc.) is performed.
Receipt of Documents. The client receives electronic supporting documents regarding the executed transaction.

A contract for the benefit of a third party cannot be concluded using a financial platform, with the exception of insurance contracts, non-state pension provision contracts, and long-term savings contracts.

In the performance of monetary obligations arising from financial transactions, the funds of financial service recipients, including those credited to a special account, as well as funds due to financial service recipients under executed financial transactions, may not be credited to OFP accounts where its own funds are located.

Funds of a financial service recipient may be transferred using a financial platform only to the account of the financial organization or issuer with whom they executed the corresponding transaction, to the special account of the OFP, or to the bank account (deposit account) of the financial service recipient.

When performing operations under bank account agreements, the types of which are defined by the financial platform rules, or bank deposit agreements concluded using a financial platform, or when modifying or terminating such agreements without using a financial platform, the bank that is a participant in the financial platform shall immediately provide information to the OFP in the manner established by the platform rules.

When transferring securities to a financial service recipient to perform obligations under financial transactions, such securities may be credited only to the personal accounts (depository accounts) of the financial service recipient. Debiting securities from a personal account (depository account) may be carried out only if they are credited to other personal accounts or depository accounts of the financial service recipient (including through a nominee holder of securities) or if they are transferred to a financial organization or issuer for the purpose of performing obligations under financial transactions.

Service Agreement for Transactions on Financial Platforms

To execute transactions using a financial platform, a participant in such a transaction must be admitted to the platform's operations. Admission is possible upon concluding an agreement for the provision of services of the financial platform operator.

Under the service agreement, the OFP undertakes, in accordance with the financial platform rules, to provide services related to enabling financial platform participants to execute financial transactions using the financial platform. Under the agreement, the OFP may also provide platform participants with services for information support of interaction for the purpose of executing financial transactions in the manner provided for by the platform rules.

The conclusion of the service agreement is carried out through the accession of financial platform participants to the said agreement, the terms of which are provided for by the platform rules, in the manner established by the platform rules.

According to Article 4 of the Law on Financial Marketplaces, the service agreement must contain the following terms:

The rights and obligations of the OFP and the financial platform participants;
The procedure for interaction between the OFP and the platform participants when concluding the service agreement and executing financial transactions;
A requirement according to which the execution of financial transactions providing for the extension of the terms of the contracts on the basis of which these transactions are executed is not permitted without using the financial platform;
Other provisions.

The financial platform rules must contain:

Requirements for financial platform participants;
The types of financial transactions, the execution of which is carried out in accordance with the platform rules;
The procedure for the OFP to post information about financial transactions;
The procedure and timeframes for the OFP to consider appeals from financial service recipients related to their use of the financial platform;
Requirements for financial organizations regarding information protection and operational reliability when executing financial transactions;
A list of services provided to financial organizations by the OFP for the identification of the client (financial service recipient), the client's representative, the beneficiary, and the beneficial owner, as well as simplified client identification in accordance with Federal Law No. 115-FZ dated August 7, 2001, On Counteracting the Legalization (Laundering) of Criminally Obtained Incomes and the Financing of Terrorism;
The procedure for sending OFP instructions via the financial platform, the procedure and terms for accepting instructions for performance, and the procedure and timeframe for the OFP to confirm performance of the financial service recipient's instructions;
The procedure for performing financial service recipient instructions, including the timeframe for the OFP to send orders to a credit organization to perform operations on a special account based on the recipient's instruction. The timeframe for sending OFP orders to debit funds from a special account shall not exceed 1 business day from the moment of receiving the recipient's instruction, unless such instruction provides otherwise;
The procedure and timeframes for informing the financial service recipient about the balance of funds belonging to them on the special account (if any);
The procedure for providing information about the terms on which the financial transaction is executed by the recipient;
The procedure for providing financial service recipients with information about the deposit insurance system under bank account (deposit) agreements and the procedure for paying compensation under such agreements;
The procedure for filing applications with the State Corporation "Deposit Insurance Agency" regarding disagreement with the amount of deposit compensation and providing additional documents substantiating the recipient's claims;
The procedure for applying to the State Corporation "Deposit Insurance Agency" using the financial platform with a claim for deposit compensation upon the occurrence of an insured event.

Amendments to the financial platform rules take effect for platform participants no earlier than 5 business days after the disclosure of information regarding the same.

The agreement between the OFP and the financial service recipient, electronic document management agreements between the OFP, the recipient, and the financial organization or issuer, as well as other documents necessary to ensure their interaction when executing financial transactions, may be signed by the recipient in accordance with the platform rules using a handwritten signature or an electronic signature, including a simple electronic signature, the key for which was obtained by the recipient through personal appearance in accordance with the rules for using a simple electronic signature.[1]

Furthermore, the said documents may be signed using the following methods:

Using an enhanced qualified electronic signature;
Using an enhanced unqualified electronic signature, the key verification certificate of which is created and used in the infrastructure providing for the information and technological interaction of information systems used to provide state and municipal services in electronic form;
Using an enhanced unqualified electronic signature, the key verification certificate of which is created by the OFP's certification center and issued by it after the identification of the individual through personal appearance, and is used in the financial platform infrastructure in accordance with the platform rules.

Restrictions on Executing Financial Transactions on Financial Platforms

When executing financial transactions using a financial platform, restrictions on executing transactions with securities, concluding contracts that are derivative financial instruments, and executing other transactions on the securities market established by Federal Law No. 39-FZ dated April 22, 1996, On the Securities Market (the "Securities Market Law") must be observed.

The execution of transactions using a financial platform is not permitted if the claims associated with participation in such transactions are not subject to judicial protection, nor is the conclusion by a financial service recipient of contracts that are derivative financial instruments permitted.

This means that in the event of a dispute arising from such a transaction, the consumer will not be able to apply to a court to protect their rights. One example is the claims of citizens and legal entities associated with the organization of games and bets or participation in them, which, by virtue of Article 1062 of the Civil Code of the Russian Federation, are not subject to judicial protection.

The acquisition and alienation of securities intended for qualified investors, as well as the provision (acceptance) of the said securities as collateral for the performance of obligations, may be carried out only through brokers. Securities and derivative financial instruments intended for qualified investors may not be offered to an unlimited circle of persons, including through advertising, or to persons who are not qualified investors.

Derivative financial instruments intended for qualified investors are, for example, such derivative financial instruments as an obligation arising from a forward contract providing for the obligation of one party to the contract to transfer securities, currency, or goods that are the underlying asset into the ownership of the other party no earlier than the third day after the day the contract is concluded, the obligation of the other party to accept and pay for such property, and an indication that the contract is a derivative financial instrument. [2]

Securities intended for qualified investors include the following securities: [3]

Securities, the issuer of which (the person obligated under which) is a person registered in a foreign state;
State securities of a foreign state;
Securities of international financial organizations;
Russian depository receipts that certify ownership rights to a specific number of the represented securities mentioned above.

In accordance with Article 51.2 of the Securities Market Law, qualified investors include, for example, professional participants in the securities market (clearing organizations, joint-stock investment funds, the Bank of Russia, the Deposit Insurance Agency, etc.).

An individual can become a qualified investor if, for example, they have work experience directly related to executing transactions with financial instruments, preparing individual investment recommendations, or managing risks associated with executing the said transactions in Russian and (or) foreign organizations. The duration of such experience must be at least 2 years if the Russian and (or) foreign organizations are qualified investors, and at least 3 years if the Russian and (or) foreign organization is not a qualified investor.[4]

Testing Before Executing Transactions on Financial Platforms

Enabling the execution of financial transactions for the acquisition of securities is permitted only if there is a positive testing result. The purpose of testing is to verify the client's knowledge and understanding of the financial service, and to assess their ability to make informed decisions, which is an important part of the "Know Your Customer" (KYC) process and the prevention of abuse. This may include assessing financial literacy, the risk profile, and the person's general awareness of financial products.

The main aspects of testing are:

Assessing financial literacy by verifying the client's level of knowledge in the field of financial products, services, and personal finance management;
Determining the risk profile, i.e., understanding how aware the client is of the risks associated with a specific financial service and how ready they are to accept them;
The client's understanding of the terms, fees, advantages, and disadvantages of the financial products and services they receive;
Excluding situations in which the client cannot make an informed decision due to a lack of knowledge or understanding;
Preventing instances of financial organizations using clients' lack of awareness to provide unfavorable or risky products.

Testing is conducted by the OFP in writing using electronic documents by obtaining the financial service recipient's answers to questions, the list of which is determined by the OFP in the financial platform rules. All testing questions must be drafted in such a way that the answers obtained can allow for an assessment of the knowledge of the person being tested, and testify that this person is able to evaluate risks taking into account the nature of the intended transactions. Testing is conducted free of charge.

A positive testing result for a financial service recipient is valid for 5 years from the day it was obtained or from the day the last financial transaction for the acquisition of securities for which testing was conducted was executed, depending on which event occurred later. During the validity period of a positive testing result, re-testing is not conducted. Re-testing is conducted free of charge.

The rules and procedure for conducting testing, the lists of testing questions, including the procedure for forming such lists depending on the transactions for which the testing is conducted, the procedure for determining a positive or negative testing result, the procedure for storing information on testing results, and the form and procedure for sending a notification of the testing result to the individual are established by the financial platform rules.

A financial service recipient is not provided with the opportunity to execute a transaction requiring testing in the event of the recipient's refusal to undergo testing or upon obtaining a negative testing result.

Testing is not required if the transaction is executed with respect to the following securities:

Securities included in the quotation lists of a stock exchange, with the exception of bonds;
Bonds of Russian issuers, provided that these bonds are issued in accordance with Russian legislation or the law of a foreign state that is a member of the Eurasian Economic Union or a member of the European Union, or in accordance with the law of the United Kingdom of Great Britain and Northern Ireland, provided that an international treaty on the avoidance of double taxation is concluded between such foreign state and Russia. Furthermore, such bonds, their issuer, or the person who provided collateral for the bonds must have a credit rating no lower than the level established by the Board of Directors of the Bank of Russia;[5]
Bonds of foreign issuers, provided that the issuer is a foreign state or a foreign organization with its place of establishment in a foreign state that is a member of the Eurasian Economic Union or a member of the European Union, or with its place of establishment in the United Kingdom of Great Britain and Northern Ireland, provided that an international treaty on the avoidance of double taxation is concluded between such foreign state and Russia. Also, the performance of obligations under such bonds must be secured by or carried out at the expense of a Russian legal entity that has a credit rating no lower than the level established by the Board of Directors of the Bank of Russia;
Investment units of open-ended and interval mutual investment funds, exchange-traded mutual investment funds, as well as investment units of closed-ended mutual investment funds that meet the requirements provided for by a Bank of Russia regulation;[6]
State securities of Russia or a Russian constituent entity;
Shares of a foreign issuer not included in the quotation lists of an exchange, or other securities of a foreign issuer certifying rights with respect to such shares, provided that the said shares are included in the calculation of at least one of the indices, the list of which is established by the Board of Directors of the Bank of Russia,[7] and the client, who is an individual, is provided with information regarding the tax rate and the procedure for paying taxes with respect to income from such securities.

Testing is also not required if the transaction amount exceeds the amount established by a Bank of Russia regulation. Until December 31, 2024, this amount was 6 million rubles; from January 1, 2025, it is 12 million rubles; and from January 1, 2026, it is 24 million rubles. [8]

We draw your attention to the fact that in the event of an OFP's violation of the requirements regarding testing, it is obliged to compensate the financial service recipient for actual damage caused.

Requirements for Operators of Financial Platforms

Requirements for financial platform operators are provided for by Articles 8–10 of the Law on Financial Marketplaces. The minimum amount of an OFP's own funds must be 100 million rubles. An OFP does not have the right to combine its activities with the activities of a credit organization and a credit history bureau, or a non-credit financial organization, with the exception of the activities of a trade organizer, depository, specialized depository, registrar, investment platform operator, operator of an information system in which digital financial assets are issued, and a digital financial asset exchange operator.

The financial platform operator is obliged to organize and carry out internal control. To organize and carry out internal control, a controller is appointed or a separate structural unit (internal control service) is formed, and an internal control procedure is approved. The controller or the head of the internal control service is appointed to the position and dismissed from the position by the sole executive body of the financial platform operator. The controller or the head of the internal control service is accountable to the sole executive body of the financial platform operator. The controller or the head of the internal control service cannot be a person who carries out the functions of the sole executive body of the OFP or the head of a structural unit created to carry out the activities of the OFP (in the event of combination with other types of activities of financial organizations).

The OFP is also obliged to organize a risk management system. The OFP is obliged to approve a document or documents defining the risk management rules and to appoint an official responsible for organizing the system for managing these risks, or to form a separate structural unit. The risk management rules must define measures aimed at reducing these risks, including risks associated with combining the activities of the OFP with other types of activities, measures to ensure the uninterrupted operation of hardware and software, and measures taken by the OFP in instances of non-standard situations that may impede the normal exercise of its activities, aimed at ensuring the continuity of such activities.

An OFP combining its activities with other types of activities is obliged to take measures established by its document or documents aimed at identifying a conflict of interest associated with such combination, preventing the negative consequences of the said conflict of interest, expressed in the violation of the rights and legitimate interests of financial service recipients, minimizing the risk of these consequences, and in the event that the measures taken by the OFP to prevent the negative consequences of a conflict of interest are insufficient to avoid the risk of their occurrence, it is obliged to disclose information about the identified conflict of interest and the measures taken to minimize the risk of its negative consequences.

The OFP is obliged to take measures to store information and documents associated with the exercise of the OFP's activities and the execution of financial transactions.

The OFP must have, on the basis of ownership or another legal basis, primary and backup complexes of hardware and software necessary for the provision of services and ensuring its uninterrupted activity and data preservation, including through the creation of backup copies. The said complexes of hardware and software must be located on the territory of Russia.

How to Obtain the Status of a Financial Platform Operator?

A legal entity acquires OFP status from the day the Bank of Russia includes information about it in the register of financial platform operators. As noted above, as of September 16, 2025, 12 organizations are registered in the register: [9]

Public Joint-Stock Company "Moscow Exchange MICEX-RTS";
Joint-Stock Company VTB Registrar;
Joint-Stock Company "Financial Marketplace Sravni.ru";
Joint-Stock Company "Open Financial Marketplace";
Joint-Stock Company "Banki.ru Marketplace";
Joint-Stock Company "Finfort MP";
Joint-Stock Company "Financial Platform";
Joint-Stock Company "Vanta";
Joint-Stock Company "Unified Financial Solutions";
Joint-Stock Company "Universal Financial Technologies";
Joint-Stock Company "Avito Finance";
Joint-Stock Company "T-OFP".

A legal entity intending to obtain OFP status submits the following documents to the Bank of Russia:

An application for the assignment of OFP status and a questionnaire, submitted in the form of an electronic document formed using software posted on the Bank of Russia's official website;
Copies of constituent documents;
Copies of documents on the election (appointment) of the sole executive body, their deputy, members of the collegial executive body, members of the board of directors (supervisory board), the chief accountant, their deputy, officials responsible for organizing the risk management system and internal control rules, as well as documents confirming their compliance with the established requirements (the "OFP Officials");
A document containing a calculation of the applicant's own funds, with the attachment of documents containing information about the composition, structure, and value of the property included in the calculation of own funds;
The financial platform rules;
A copy of the decision of the applicant's authorized body by which the financial platform rules were approved;
A document confirming the applicant's fulfillment of information protection requirements established by the Bank of Russia;
Documents containing information about the person who has the right, directly or indirectly (through persons under its control), independently or jointly with other persons associated with it by agreements on the trust management of property, and (or) simple partnership, and (or) assignment, and (or) a shareholder agreement, and (or) another agreement, the subject of which is the exercise of rights certified by shares of the financial platform operator, to dispose of 10 or more % of the votes corresponding to the voting shares constituting the charter capital of the financial platform operator.

The Bank of Russia conducts a verification of the applicant's compliance with established requirements and, if necessary, requests documents and (or) information from the applicant confirming the applicant's compliance with such requirements.

The Bank of Russia makes a decision on inclusion or refusal to include information about the applicant in the OFP register within a period not exceeding 30 business days from the date of submission of all required documents to the Bank of Russia. The Bank of Russia notifies the applicant of this within 3 business days from the day the information is included in the OFP register.

In the event of a decision to refuse, the Bank of Russia sends a notification to the applicant within 3 business days from the day such a decision is made, containing the ground for the refusal. The grounds for refusal are:

Non-submission or submission of an incomplete set of documents;
Submission of documents containing incomplete or unreliable information and (or) mutually exclusive provisions;
Non-compliance of documents with the requirements provided for by the Law on Financial Platforms and the regulations of the Bank of Russia adopted in accordance with it, including requirements for the content of the financial platform rules;
Non-compliance of the applicant, as well as its officials, with the requirements provided for by the Law on Financial Platforms and the regulations of the Bank of Russia adopted in accordance with it.

Removal from the Register of Financial Platform Operators

The grounds for the Bank of Russia's adoption of a decision to remove an OFP from the register are (Clause 14 of Article 11 of the Law on Financial Marketplaces):

An application for the termination of activities;
Repeated violation within one year of requirements provided for by the Law on Financial Marketplaces and (or) the regulations of the Bank of Russia adopted in accordance with it;
Repeated violation within one year of requirements provided for by Federal Law No. 115-FZ dated August 7, 2001, On Counteracting the Legalization (Laundering) of Criminally Obtained Incomes and the Financing of Terrorism, and (or) repeated violation within one year of the requirements of Bank of Russia regulations issued in accordance with the said Federal Law;
Revocation (cancellation) of a license for the exercise of a corresponding type of activity when combining the activities of an OFP with other types of activity, combination with which is permitted by the Law on Financial Marketplaces, if such revocation (cancellation) was not carried out upon the application of the licensee;
Liquidation or termination of activity as a result of reorganization;
The court's adoption of a decision recognizing the OFP as bankrupt;
The OFP's failure to exercise the corresponding type of activity for more than 18 months.

The removal of information about an OFP from the register entails the termination of its status. The legal entity is obliged to terminate the OFP's activity from the day specified in the Bank of Russia's decision. The decision to remove information from the register is made by the Bank of Russia in the manner and timeframe established by the Bank of Russia. [10] The ground for its adoption is specified in the corresponding decision. A decision to remove information from the OFP register can be made only on the condition of the absence of obligations to financial platform participants.

The Bank of Russia is obliged to notify the OFP of the adoption of the decision no later than 3 business days following the day the corresponding decision is made.

The Bank of Russia's decision to refuse to include information about a financial platform operator in the register of financial platform operators and to remove such information from this register can be appealed to a court within 3 months from the day the corresponding decision is made.

Liability of Financial Marketplaces

The liability of financial platforms is defined by the Federal Law on Financial Platforms. The main liability of an OFP lies in providing information about financial transactions and ensuring the interaction of all participants in the process.

The OFP is obliged to provide the financial transaction registrar (the "FTR") with information about bank deposits placed using the financial platform and about monetary operations under them, and information about the execution of other financial transactions and about operations under them using the financial platform. The OFP is obliged to ensure the reliability of the information provided by it to the FTR. The financial platform operator bears liability for losses caused as a result of non-performance or improper performance by it of the obligation to provide information to the FTR (Article 7).

In the event that the Bank of Russia identifies a violation of the requirements of the Federal Law on Financial Platforms, the Bank of Russia's regulations adopted in accordance with it, the financial platform rules, or the rights and legitimate interests of financial platform participants, or in the event that a threat to the rights and legitimate interests of financial platform participants exists, the Bank of Russia, in the manner established by it, has the right to restrict the financial platform operator's conduct of individual operations for a term not exceeding thirty business days from the date the Bank of Russia identifies the violation or threat. [11]

The OFP is obliged to submit to the Bank of Russia its annual accounting (financial) statements together with an audit report on them, and interim accounting (financial) statements for reporting periods determined by the Bank of Russia. The OFP is also obliged to submit reporting and other information to the Bank of Russia as provided for by the Federal Law on Financial Platforms (Article 17).

How to Protect Rights when Executing Transactions on Financial Platforms?

To protect rights in transactions on financial platforms, it is necessary to familiarize oneself with the terms of provision of services, use only verified platforms, and save all documents and correspondence, and in the event of problems, to apply to the platform operator, the financial ombudsman, the Bank of Russia, or Rospotrebnadzor, and if necessary, to file a lawsuit in court.

In accordance with Article 17.1 of the Law on Financial Platforms, the financial platform operator is obliged to consider an appeal from an individual or legal entity associated with the OFP's exercise of its activity within 15 business days from the day of the appeal's registration. The response to the appeal is sent to the applicant, depending on the method of the appeal's receipt, in writing to the email address or postal address specified in the appeal, or by the method provided for by the terms of the agreement concluded between the financial platform operator and the applicant. In the event that the applicant, when sending the appeal, specified a method for sending the response to the appeal in the form of an electronic document or on paper, the response to the appeal must be sent by the method specified in the appeal.

The response to the appeal must contain information about the results of an objective and comprehensive consideration of the appeal, be reasoned, and include references to the requirements of Russian legislation relevant to the issue being considered in the appeal, documents and (or) information associated with the consideration of the appeal, as well as to the factual circumstances of the issue being considered in the appeal.

A substantive response to an appeal is not given by an OFP in the following cases:

The appeal does not specify the address to which the response should be sent;
The appeal does not specify the surname (name) of the applicant;
The appeal contains obscene or offensive language, threats to the OFP's property, or threats to the life, health, and property of an OFP employee, as well as members of their family;
The text of the appeal is illegible;
The text of the appeal does not allow for its essence to be determined.

The OFP is obliged to ensure the implementation of measures to identify operations aimed at executing financial transactions without the will of the financial platform participants, and to counteract the execution of such transactions. [12]

OFPs must send information to the Bank of Russia about all cases and (or) attempts to carry out operations for financial transactions without the participants' will upon the occurrence of the following events:

Receipt of a notification from a financial service consumer about the debiting of funds from a special account without their will;
Identification of cases and (or) attempts to perform operations for the debiting of funds from a special account without the consumer's will, including those performed as a result of unauthorized access to the OFP's information infrastructure facilities;
Receipt of notifications from financial platform participants about cases and (or) attempts to perform operations for financial transactions without the will of the financial platform participants;
Identification of computer attacks aimed at the information infrastructure facilities of the OFP and (or) the financial platform participants, which may lead to cases and (or) attempts to carry out operations for financial transactions without the will of the financial platform participants. [13]

Information about transactions executed on financial platforms is stored in the Unified Financial Transaction Registrar, created on the basis of the central depository. For example, the information on bank deposits held by the Unified Financial Transaction Registrar is considered reliable until otherwise proven in a court procedure. In the event of a discrepancy between the information held by the financial transaction registrar and the accounting records (records on a personal account or depository account), the accounting records have priority (Article 7).

A client can always request an extract from the FTR regarding the contracts concluded by them on different financial platforms through their profile on the "Gosuslugi" portal. An agreement between a client and a provider of financial products or services is, as a rule, concluded remotely without visiting the office of a bank or financial organization. The FTR bears liability for losses caused as a result of its violation of the obligation to provide access to information, the provision of unreliable and (or) misleading information, the unlawful disclosure or provision of information, or the distortion of received information.

______________________________

References

Decree of the Government of Russia No. 33 dated January 25, 2013, On the Use of a Simple Electronic Signature in the Provision of State and Municipal Services.
Ordinance of the Bank of Russia No. 3565-U dated February 16, 2015, On the Types of Derivative Financial Instruments.
Ordinance of the Bank of Russia No. 6885-U dated October 1, 2024, On Securities and Derivative Financial Instruments Intended for Qualified Investors.
Ordinance of the Bank of Russia No. 7060-U dated May 21, 2025, On the Requirements a Person Must Meet to be Recognized as a Qualified Investor, the Procedure for Recognizing a Person as a Qualified Investor, and the Procedure for Maintaining the Register of Persons Recognized as Qualified Investors.
Decision of the Board of Directors of the Bank of Russia dated February 14, 2025, On Establishing Credit Rating Levels for the Purpose of Applying Sub-paragraphs 2 and 3 of Paragraph 2 of Article 3.1 of Federal Law No. 39-FZ dated April 22, 1996, On the Securities Market.
Ordinance of the Bank of Russia No. 7007-U dated March 12, 2025, On Establishing Requirements for Investment Units of Closed-Ended Mutual Investment Funds for the Purpose of Applying Sub-paragraph 4 of Paragraph 2 of Article 3.1 of Federal Law No. 39-FZ dated April 22, 1996, On the Securities Market and Sub-paragraph 3 of Paragraph 1 of Article 21.1 of Federal Law No. 156-FZ dated November 29, 2001, On Investment Funds.
Decision of the Board of Directors of the Bank of Russia, On Establishing the List of Indices for the Purpose of Applying Paragraph 7 of Part 8 of Article 11 of Federal Law No. 192-FZ dated June 11, 2021, On Amending Certain Legislative Acts of the Russian Federation and Sub-paragraphs 6 and 7 of Paragraph 2 of Article 3.1 of Federal Law No. 39-FZ dated April 22, 1996, On the Securities Market.
Ordinance of the Bank of Russia No. 6771-U dated June 26, 2024, On Establishing the Transaction Amount for the Purpose of Applying Paragraph 2 of Part 9.2 of Article 5 of Federal Law No. 211-FZ dated July 20, 2020, On the Execution of Financial Transactions Using a Financial Platform.
Bank of Russia Website: https://www.cbr.ru/admissionfinmarket/navigator/ofp/.
Ordinance of the Bank of Russia No. 5661-U dated December 11, 2020, On the Procedure and Timeframes for the Bank of Russia to Decide on the Removal of Information Regarding a Financial Platform Operator from the Register of Financial Platform Operators.
Ordinance of the Bank of Russia No. 5761-U dated March 30, 2021, On the Procedure for the Bank of Russia to Restrict Specific Operations of a Financial Platform Operator.
Ordinance of the Bank of Russia No. 5662-U dated December 15, 2020.
Ibid.