Клиент под подозрением: как обойти ограничения НБУ

Украинцам стало сложнее совершать дорогие покупки.

В начале сентября в силу вступило постановление НБУ, согласно которому банки обязаны проверять происхождение денег у физических лиц и предпринимателей при любых крупных операциях с наличными – открытии счета, депозита, отправке перевода, покупке дорогостоящих товаров или услуг.

В зону риска попадают операции, которые не соответствуют финансовому состоянию клиента или сути его деятельности. Если банк посчитает операцию сомнительной или заподозрит клиента в отмывании доходов, ему придется подтвердить происхождение средств.

Банк самостоятельно проводит оценку рискованности операции, определяет сумму, которая может вызвать подозрения, и принимает решение о блокировке. Но надеяться на массвое попустительство банкиров не стоит. За нарушение правил финансового мониторинга и обслуживание рисковых операций банку грозят штрафные санкции – до 1% от уставного капитала.

Обойти нововведения, рассчитавшись с продавцом наличными, непросто. Украинцам запретили проводить наличные расчеты при покупке недвижимости или автомобиля стоимостью более 50 000 в присутствии нотариуса с начала 2017 года. Оплата таких покупок должна происходить исключительно по безналу.

Кого проверят банки

Запросить дополнительные данные банк теперь может у любого клиента – как у нового, так и у существующего. Исключение – физлица, у которых в банке уже открыты пенсионные, зарплатные счета или депозиты.

Банкиры признаются, что уже сейчас после вступления нововведений в силу при необходимости требуют у клиентов подтвердить происхождение средств при проведении операций с наличными. “Банк проводит подобную проверку, если финансовые возможности клиента не отвечают его доходам, информацию о которых он предоставил в опросном листе”, – говорит Сергей Дмитров, член правления, начальник управления финансового мониторинга банка Кредит Днепр.

Банк может запросить информацию о доходах не только при перечислении средств, но и при оформлении депозита. При этом, уверяют финансисты, с выдачей крупного депозита, который уже лежит в банке, проблем возникнуть не должно. “Банк должен изучить источник происхождения денежных средств до момента принятия депозита. Если он принял деньги у клиента, значит, он обязан выдать их в порядке и в сроки, указанные в договоре”, – поясняет Дмитров.

Безрисковые источники для банка – это зарплата, доход от продажи имущества, продукции или услуг, получение наследства, страховой суммы по договору страхования, выигрыш в лотерею, приобретение права на сокровище, а также другие выплаты в соответствии с условиями гражданско-правового договора.

“Документами, которые дают банку возможность сделать обоснованный вывод, могут быть налоговая декларация, копия декларации об имуществе, доходах, расходах и обязательствах из Единого государственного реестра деклараций, другие документы, подтверждающие источники происхождения собственных средств и активов”, – отмечает Ирина Пришляк, ведущий экономист отдела финмониторинга ОТП Банка.

Исключения из правил

Если клиенту не удалось убедить банк в прозрачности доходов, ему могут отказать в операции. Жертвами нововведений могут стать не только реальные участники схем по отмыванию денег, но и физлица, которые хранили сбережения вне банковской системы.

“Бывают ситуации, когда физлицо в силу определенных факторов потеряло постоянный источник доходов и вместе с тем имеет достаточно серьезные накопления, чтобы совершать дорогостоящие покупки. Трудности могут возникнуть, если весь период накопления деньги лежали дома, “под матрасом”, – говорит Дмитров.

Обойти требования НБУ и избежать проверки происхождения средств, например, при покупке недвижимости будет непросто.

“Поскольку нотариусы не требуют квитанцию из банка в подтверждение оплаты по договору, может возникнуть желание рассчитаться наличными, однако необходимо помнить, что нотариус является субъектом финансового мониторинга и обязан сообщать обо всех проведенных сделках дороже 150 000 в Государственную службу финмониторинга”, – объясняет советник налоговой практики юридической фирмы Ario Ольга Решетник.

Есть ли другие лазейки? Если у покупателя минимальная официальная зарплата, нет доходов от предпринимательской деятельности на сумму сделки и прочих официальных доходов, он может показать в банке документы об альтернативных поступлениях. “Как минимум можно подписать договор финансовой помощи, поскольку саму квитанцию о зачислении средств по такому договору банки не требуют”, – говорит Решетник.

“Внутренняя банковская анкета клиента содержит раздел о прочих источниках поступления средств на счета физических лиц. Такие источники поступлений, как финансовая помощь, доход от продажи ценных бумаг, доход от продажи или уступки права требования и поступления в виде займа, также являются легальными”, – подтверждает Александра Томашевская, налоговый консультант Киевского центра поддержки и развития бизнеса.

Чтобы не потерять клиентов, бизнесу приходится импровизировать. LIGA.net опросила представителей автосалонов, строительных компаний, как быть покупателям, у которых есть сложности с подтверждением происхождения денег. “Проще всего при заполнении заявки указать, что вы длительное время копили средства. Наши банки-партнеры принимают такие объяснения, если они касаются сумм менее 1 млн грн”, – рассказывает сотрудник автосалона по торговле японскими автомобилями. В том случае, если на протяжении последних пяти лет покупатель уже делал крупную покупку, ему рекомендуют взять беспроцентный кредит на два года. Погасить его можно досрочно без применения штрафных санкций.

Автодилеры называют и другие, более трудоемкие способы. Например, автомобиль можно приобрести на другое физическое или юридическое лицо и взять в пользование. Как вариант, можно “дробить” платежи до сумм, которые не подпадают под финансовый мониторинг. “Это может быть безналичный расчет со счетов, открытых в разных банках, на сумму не выше 149 999 грн, а также внесение наличных денег в разных отделениях банков суммой не выше 149 999 грн. При таком способе клиент платит за автомобиль частями в разные дни”, – сообщили в пресс-службе Еврокар.

Чтобы избежать усиленной проверки, клиентам также рекомендуют оплачивать покупку в банке, с которым непосредственно работает продавец. “Клиент может снять наличные деньги со счета банка, который отказал в проведении безналичного расчета, и пройти идентификацию в банке, который обслуживает автосалон”, – рекомендуют в Еврокар.

Строительные компании также готовы помогать клиентам. “Мы договорились с банками-партнерами и сами вносим деньги на счет в банк, а покупатель официально платит через нашу кассу. Никаких вопросов при этом не задают”, – говорит сотрудник крупной украинской компании-застройщика.

В банке, который выдает ипотечные кредиты сразу для нескольких компаний-застройщиков, LIGA.net рассказали, что не намерены передавать информацию о своих клиентах в службу финансового мониторинга. “Мы внимательно общаемся с клиентами и вносим в опросник всю информацию о заработной плате, продаже объектов, наследстве и прочем в анкету. Такие операции автоматически признаем безрисковыми и не предоставляем информацию в службу финмониторинга. Исключение – решение суда или требование правоохранительных органов, но таких заявлений нам пока не поступало”, – рассказали в банке на правах анонимности.

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