1.  Please give details of any existing national legislation in your country that is specifically relevant regarding the obligations and limitations for LVMH shop assistants dealing with cash payments?
  2. Are there any changes or developments expected in the near future?
  3. Is there a maximum amount of cash a customer may use to purchase items in a store in your country? If yes, what is the amount?
  4.  Are there any limitations in your country with regard to the acceptance of denominations of [euro] banknotes?
  5.  Are there any rules in your country on partial and/or related cash payments and is it clear what can or will be seen as a partial and/or related payment?
  6.  Is there a duty to report to an authority if a customer would like to pay in cash above the maximum amount and/or with a denomination of a banknote which is forbidden?
  7.  What are the competent authorities which oversee the enforcement of the relevant legislation?
  8.  If there is a duty to report, what is the competent authority to report to and what are the relevant responsibilities of LVMH in that respect?
  9.  What sanctions do the authorities have at their disposal to make sure that companies comply with the rules?
  10.  Are there any other relevant developments or issues regarding this matter, of which LVMH should be aware (e.g. privacy issues)?

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Russia
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1. Please give details of any existing national legislation in your country that is specifically relevant regarding the obligations and limitations for LVMH shop assistants dealing with cash payments?

The relevant legislation in the Russian Federation is the federal law to prevent money laundering and terrorist financing (dated on 07.08.2001 Num. 115-FZ) (the “Federal Law”).

Unless specifically mentioned, the following limitations and restrictions apply to LVMH only in the case of the selling of jewellery. Sale of other goods (e.g. clothing, shoes, bags, accessories, watches, fragrances, home goods) not containing precious metals or stones is not subject to these limitations and restrictions.

2. Are there any changes or developments expected in the near future?

No changes are expected at the moment.

3. Is there a maximum amount of cash a customer may use to purchase items in a store in your country? If yes, what is the amount?

There is no restriction as such.

However, if the cash payment is made between two legal entities or between a legal entity and a registered entrepreneur, then the payment in cash is limited to RUB 100,000 (approx. EUR 1,100) per deal (or in a sequence of related deals). This limitation shall apply irrespective of the purchased items.

In addition, in the case of buying jewellery:

The limits are up to RUB 40,000 (approx. EUR 450) if paying by cash and up to RUB 200,000 (approx. EUR 2,200) if paying by card or e-wallet (no ID documents required).

Above the stated cap, the customer should provide the following:

  • Identification document (ID);
  • Tax number;
  • Information on place of residence or the location of stay;
  • Individual insurance account number (optional).

4. Are there any limitations in your country with regard to the acceptance of denominations of [euro] banknotes?

No, but a purchase can only be made in the national currency (Russian roubles).

There are no rules.

6. Is there a duty to report to an authority if a customer would like to pay in cash above the maximum amount and/or with a denomination of a banknote which is forbidden?

If the jewellery selling price is equal to or exceeds RUB 600,000 (approx. EUR 6,700), then the information on such a transaction (irrespective of the method of payment) must be transferred by the seller to the competent authority, the Federal Financial Monitoring Service.

7. What are the competent authorities which oversee the enforcement of the relevant legislation?

The Federal Financial Monitoring Service (in Russian, Rosfinmonitoring), including its interregional departments in nine federal districts, is the central institute in Russia responsible for preventing and combating money laundering and terrorist financing.

The Federal Assay Office, including its interregional departments in nine federal districts, specifically oversees the enforcement of the relevant legislation in jewellery trade and registers the respective sellers.

8. If there is a duty to report, what is the competent authority to report to and what are the relevant responsibilities of LVMH in that respect?

The competent authority to report to is the Federal Financial Monitoring Service. The responsibilities of the client when reporting are laid out in art. 7(1)(4) of the Federal Law.

The client shall provide the following information to the Federal Financial Monitoring Service within three business days after the relevant transaction:

  1. The nature, grounds, date and amount of the transaction;
  2. The identity and tax number of the customer, and information on the customer's place of residence or location of stay;
  3. The identity (and other information mentioned in item b above) of the beneficial owner(s) of the customer;
  4. The identity (and other information mentioned in item b above) of the authorised representative(s) of the customer.

9. What sanctions do the authorities have at their disposal to make sure that companies comply with the rules?

The following liabilities may be imposed for failure to comply with the Federal Law:

  1. Suspension or cancellation of the license issued for the respective activity (art. 13 of the Federal Law);
  2. Administrative fine of up to RUB 140,000 (approx. EUR 1,500) (for failure to register as the company selling the jewellery, art. 15.43 of the Russian Code of Administrative Offences) and up to RUB 1 million (approx. EUR 11,100) or suspension of business for up to 90 days (for violation of the requirements of the Federal Law, art. 15.27 of the Russian Code of Administrative Offences) and up to RUB 60 million (approx. EUR 666,700) (for terrorist financing support, art. 15.27.1 of the Russian Code of Administrative Offences);
  3. or natural persons found guilty, criminal liability of up to seven years of imprisonment (for money laundering, art. 174 and 174.1 of the Russian Criminal Code) and up to life imprisonment (for terrorist financing, art. 205.1 of the Russian Criminal Code).

10. Are there any other relevant developments or issues regarding this matter, of which LVMH should be aware (e.g. privacy issues)?

The company, whose business (e.g. jewellery sales) is regulated by the Federal Law, must prepare and adopt respective internal rules, appoint a person to take charge and implement other internal measures to prevent money laundering and terrorist financing.