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Architecture for interaction between funds, banks and personal accounting domains.
Sistema_fondov_Lichnye_i_imennye_fondy_i_banki.pptx
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EQUILIBRIUM · FUND SYSTEM · ECO-PPA · SPECZASHCHITA · SFERA · ARCHIVE OF HERITAGE
Author: Sokolov Sergey Leonidovich · 29 August 2026
Status: author's project hypothesis for legal, banking and expert verification
02 / MANUAL SOLUTION
Allow 90-day design pilot
Check the legal shell, roles, banking gateways, registers and evidence cycle - without public fundraising and without starting banking activities.
Main thesis
It is not money that creates a fund. The fund creates rules that link purpose, law, capital, decision and proof.
| Parameter | Proposal |
|---|---|
| Subject | The system of management of separate capital and name programs on top of existing accounts, contracts and licensed providers. |
| Timeframe | 90 calendar days; design, prototype and dry runs. |
| Mode | Read-only and shadow mode: the platform does not accept money, does not open accounts and does not initiate automatic transfers. |
| Cases | One reference personal fund, one name program and two model projects ECO-PPA. |
| Withdrawal | Legal card, fund passport, six registers, banking RFI, evidence package and GO/CONDITIONAL GO/NO-GO solution. |
Recommended solution
Approve the design perimeter; allow real cash flows only by a separate solution after legal, tax, AML/KYC and bank statements.
03 / PROBLEM AND THESIS
Accounts show money, but do not explain its mandate
A family, benefactor, institution, or project may have assets and contracts, but without a common model, it is difficult to prove purpose, authority, limitations, outcome, and continuity.
- Break 1. The purpose of the owner is not always fixed as an enforceable mandate with prohibitions and a deadline.
- Break 2. Accounts, securities, rights, obligations and projects are conducted in different systems.
- Break 3. A “name fund” can be a name without a clear legal shell.
- Break 4. A user's "personal bank" is easily mistaken for a credit institution.
- Break 5. The executor, the manager of capital and the verifier of the result may coincide.
- Break 6. After the change of generations, the foundations of decisions, rights, versions and knowledge are lost.
System response
The federal layer of mandates and separate capital: each fund retains its own shell and accounts, and the overall architecture links rights, decisions, projects, evidence and the Heritage Archive.
04 / TERMS MAP
Five concepts should not be confused
| Concept | Contents | A hard border |
|---|---|---|
| Personal financial contour | Objectives, accounts, assets, liabilities, insurance and investment products of an individual or family. | Not a legal entity or a bank. |
| Personal Fund | A separate legal shell for the transferred property, goals and rights of beneficiaries. | The design is confirmed for a specific jurisdiction. |
| Name Fund | A foundation or program associated with the name of a person, family, territory, institution, or idea. | The name does not replace the legal shell. |
| Bank / custodian / manager | Licensed entities for accounts, settlements, storage and asset management. | They only operate within the permitted limits. |
| "Personal Bank" | Cabinet of capital: review, budgets, limits, forecasts and instructions to providers. | It does not accept deposits, lend or store client assets on its own behalf. |
Public name
“Personal bank” is only a project metaphor. Public name and advertising require separate legal verification; "Personal Treasury" or "Capital Cabinet" is preferred.
05 / PRINCIPLES AND INVARIANTS
The system starts with prohibitions, not functions.
1. Separateness: Assets, liabilities, and decisions of different funds do not mix.
2. Legal rights arise from the law, constituent documents and treaties, and not from the interface.
3. Licensed contour. accounts, payments, storage and investment services are performed by authorized organizations.
4. A person makes a decision. EQUILIBRIUM calculates scenarios, but does not receive the right to transfer funds.
5. Role-sharing: The initiator, approver, payer, executor, and validator do not form one uncontrollable center.
6. Proof before the tranche. the conditions of the result and acceptance documents are approved in advance.
7. Traceability. each significant decision has an author, authority, date, version, and basis.
8. Continuity The Heritage Archive preserves the context, rights, evidence and lessons for the next cycle.
Invariant
The internal register is a management reflection. A legal document defines the right; a bank or custodian statement confirms the asset; an independent document confirms the result.
06 / PLACE IN THE GENERAL ECOSYSTEM
The system of funds connects the forecast with the legal decision on capital
| Contour | Function | Border |
|---|---|---|
| EQUILIBRIUM | Signals, scenarios, risk indicators, limits and forecast. | It does not manage assets. |
| Funds system | Mandates, rights, constraints, sources of capital and solutions. | They don’t accept client money on their balance. |
| ECO-PPA | Task, technology, cooperation, capital, contract, data and result. | Project and resource framework; not the executor. |
| SPECZASHCHITA | Cooperative assembly, execution, sustainability and logistics. | It does not confirm its own result alone. |
| SFERA | Initiatives, participants, knowledge, feedback and scaling. | It does not store assets and is not a regulator. |
| Heritage archive | Origin, Versions, Decisions, Evidence, and Continuity. | It does not store passwords, bank keys and excessive personal data. |
Formula
SIGNAL → MANDATE → CAPITAL → ECO-PPA → EXECUTION → VERIFICATION → ARCHIVE → NEW CYCLE
07 / SIX ARCHITECTURE WORDS
Each fund is a node of six mandatory layers
1. Will, purpose and rights. Founder or donor, mission, beneficiaries, permissible and prohibited use.
2. Legal shell and management. organization or program, charter, term, bodies, powers, conflicts, substitution and termination.
3. Assets and liabilities. source of property, legal owner, accounts, instruments, restrictions, reserves and liquidity.
4. Licensed infrastructure. bank, custodian, depository, broker, manager and payment provider - each within the authority.
5. Project outline. ECO-PPA, contracts, budgets, stages, tranches, executors and independent verification.
6. Evidence and heritage. decisions, statements, acts, measurements, reports, versions and archival packages.
End-to-end functions
Compliance, taxes, data protection, cybersecurity, auditing and analytics EQUILIBRIUM go through all six layers.
Formula
PURPOSE + FOOTBALL + BENEFICIARIES + ASSETS + DECISION RULES + LICENSE INFRASTRUCTURE + PROOF + ARCHIVE
08 / FUND ARCHETIES
The type of fund is defined by a task, not a beautiful name
| Archetype | Purpose | Key Control |
|---|---|---|
| Personal / Family | Preservation, use and continuity of capital. | Rights of beneficiaries and replacement of bodies. |
| Name | Support a mission related to a name, territory, or idea. | The name does not replace the legal status. |
| Endowment | Long-term funding of the mission through targeted capital. | Conservation of basic capital and spending policies. |
| Charitable / grant | Financing of recipients and socially useful programs. | Selection criteria and targeted use. |
| Project / Software | Separated capital under the result ECO-PPA. | Contract, stages, tranches and acceptance. |
| Standby | Liquidity and continuity of obligations. | Terms of use and restoration of the reserve. |
| Development / co-investment | Technology, entrepreneurship and cooperation. | Risk, evaluation and lack of promised returns. |
| "Heritage Archive" | Preservation, digitization, research and access. | Origin, access rights and long-term preservation. |
This is a functional typology. The legal form is selected separately for each jurisdiction, purpose, asset and membership.
09 / PERSONAL FINANCIAL CONTOUR
Prior to the establishment of the Fund, an honest personal balance is required
The Fund does not correct unclear property, undivided obligations or the absence of family rules.
Goals. living expenses, education, health, housing, entrepreneurship, charity and heritage.
Assets. accounts, deposits, securities, business shares, real estate, claims and intellectual property rights.
Obligations. loans, guarantees, taxes, maintenance of property, contractual and family obligations.
Reserves. operational, emergency, tax, project and hereditary.
Rights. owners, joint ownership, powers of attorney, will, marriage and corporate documents.
Providers. banks, brokers, insurers, managers, notaries, auditors and tax consultants.
Transition to Fund Criteria
The legal shell is justified if it solves the problem of management, mission protection, continuity or separation, which cannot be reliably solved only by contracts and personal accounts.
Border
A personal financial contour is a management model of a person or family. It is not a bank, fund or guarantee system.
10 / PERSONAL FUND AS A LEGAL HEAVEN
In Russia, a personal fund is not an account, but a separate non-profit organization
Verified legal guidance
The FTS describes the personal fund as a special form of NPO for the management of the founder's property in the interests of these persons; the constituent document is the charter. Specific conditions of establishment, composition of property, management, rights of beneficiaries and taxes are checked at the date of the transaction.
The starting threshold. on the date of preparation of the Civil Code provides for the transfer of property by the founder with a market value of at least 100 million rubles when creating a personal fund, except for the hereditary fund; the assessment and relevance of the norm are confirmed before the institution.
Transferred property must have an established owner, value, origin and legal regime; after the transfer, the mode of the selected shell is in effect.
Subsequent receipts. current law should not be described by the previous general prohibition on free transfers from third parties; the grounds, restrictions and tax consequences of each receipt are checked separately.
Management. charter and management conditions should describe the bodies, competence, prohibitions, substitution and procedure for changing documents.
Beneficiaries. fixed not only individuals or classes, but also the nature of the rights, conditions, terms, information and appeal.
Bank and assets. accounts are maintained by the bank; securities are taken into account by the authorized participant; investment service is provided within the license.
Continuity. scenarios of death, incapacity, conflict, lack of organ and termination of the fund are modeled in advance.
What not to promise
Automatic protection from creditors, tax neutrality, guaranteed safety of property, complete confidentiality or universal applicability of one design.
Main sources: Federal Law No 287-FZ; GK RF; FNS materials. This section is not a legal opinion.
11 / NAMED FUND
Name creates mission; documents create rights
A separate organization. the name is included in the name of a legally established fund or other admissible NGO.
The program within the NPO. a nominal scholarship, grant line, museum, scientific, cultural or social program is conducted in a separate analytics.
The target capital. name and mission can be associated with a separate target capital of NGOs, subject to the relevant law.
Personal fund. name mission can be fixed in the purposes and rules of the personal fund, if the chosen design allows it.
Contractual program. for the pilot, a separate budget and rules are possible in the existing organization without a statement on the creation of a new legal entity.
Mandatory name verification
Consent and rights to the name, reputational restrictions, trademarks, personal data, rules of use after death and the procedure for withdrawal should be fixed separately.
Formula
NAME + MISSION + LEGAL ENVIRONMENT + RULES OF USE + RECOGNITION + CONTINUITY
12 / ENDAUMENT, CHARITY AND PROJECTS
One mission may require different legal and financial contours
| Contour | When appropriate | Cannot be substituted |
|---|---|---|
| Target capital of NGOs | Long-term funding for a specific non-profit mission. | Ordinary operating account or investment product without requirements 275-FZ. |
| Charitable program | Free assistance and socially useful activities. | Commercial investment, public contribution or hidden reward to the donor. |
| Project Fund ECO-PPA | Capital under measurable result, contract, stages and verification. | Bank, independent type of contract or guarantee of result. |
| Reserve | Covering a certain risk and continuity of obligations. | Free "wallet" without limits and rules of recovery. |
| Development Fund | Financing of technologies, business or cooperation through an acceptable shell. | Promised profitability and unlicensed management of other people’s assets. |
Project rule
If the economic function has become investment, banking, brokerage, payment or trust management, the name "fund" does not exempt from the appropriate regime and admission.
References: Federal Laws No. 7-FZ, No. 135-FZ and No. 275-FZ; each model is classified separately.
13 / PASSPORT FUND
Fifteen fields turn an idea into a manageable node
| Block | Mandatory content |
|---|---|
| Identity | ID, title, status, jurisdiction, version and date. |
| Mission | purpose, time, permissible and prohibited use. |
| Right | shell, constituent documents, owner of assets and restrictions. |
| Participants | founders, donors, beneficiaries, bodies that control persons. |
| Management | competence, quorum, veto, substitution, conflicts and related transactions. |
| Infrastructure | bank, custodian, manager, contracts, licenses and replacement plan. |
| Policies | distribution, liquidity, risk, investments, expenses and reserves. |
| Projects | admission criteria ECO-PPA, budget, tranches, result and verification. |
| Monitoring | reporting, auditing, complaints, incidents, reorganization and termination. |
| Data and archive | access, minimization, storage periods, versions and archive package. |
Passport Status
The passport does not replace the charter, contract, statement or bank document. It links official sources and records which version was the basis of the decision.
14 / BANK, CASTODIAN AND CONTROL
The Fund sets the mandate; licensed providers perform regulated functions
| Function | The Source of Truth | System control |
|---|---|---|
| Bank account and payment | Account agreement, order and bank statement. | Authority, limit, assignment, reconciliation and reconciliation. |
| Deposit / Deposit | Agreement and terms of the bank. | Term, liquidity, concentration and applicability of insurance protection. |
| Brokerage operation | Brokerage contract, order and report. | Investment policy, risk, commission and conflict of interest. |
| Accounting for securities | Depository or registry record. | Reconciliation of owner, quantity, encumbrances and storage chain. |
| Asset management | Contract with the authorized manager and report. | Mandate, limits, risk, cost and independent oversight. |
| Project payment | Contract, account, act and payment document. | Gateway ECO-PPA, stage, proof and no double payment. |
Provider's Criterion
The right to the relevant activity is checked by an official register; the contract describes the storage of assets, data, liability, termination and portability.
The Bank of Russia indicates that banking operations are carried out on the basis of a license; the rights of financial market participants are checked in the official service.
15 / "Personal Bank" AS INTERFACE
The capital office is a management cabin, not a credit institution
| Permissible in the interface | Unacceptable without special status |
|---|---|
| Summary read-only review of accounts and assets by allowed connections. | Accept deposits or money from an indefinite circle of persons. |
| Objectives, budgets, “envelopes”, reserves and cash flow forecasts. | Open bank accounts on behalf of the platform. |
| Limits, approval routes and commitment calendar. | To lend, exchange, store or manage assets on its own behalf. |
| Preparation of instructions to licensed providers and reconciliation of statements. | Represent the internal unit of account as a legal tender. |
| Portfolio ECO-PPA, documents, notifications and archive package. | Promise guaranteed returns, returns or insurance protection without a basis. |
Technical principle
The instruction becomes a payment order only after passing the powers and execution through the bank or other authorized circuit. No automatic money transfers on the signal of the analytical model.
16 / SOURCES OF TRUTH AND COMPARISON
Each fact has its own authoritative source.
Legal law, statute, organ decision, contract, power of attorney or judicial act.
Money in the account. Licensed bank statement.
Securities and other accounting rights. document of the depositary, registrar or other legal registry.
Management distribution. fund decision and recording in the system with the confirmed version.
Actual performance. contract, primary document, act, report and supporting materials.
Result. Pre-established methodology and independent conclusion.
History. Heritage archive with origin, versions, access rights and checksums.
Sverka
The internal record cannot correct the bank statement. The discrepancy creates an incident, the owner, a deadline, a compensating record, and a re-match.
Formula
LAW → DECISION → DISSEMINATION → FOREIGN LETTER → COMPARISON → PROOF → ARCHIVE
17 / CAPITAL CYCLE AND HOUSE
Capital moves only after seven consecutive checks
| Gateway | The control question | Withdrawal |
|---|---|---|
| G0. Source | Who is the owner and how is the origin of the asset confirmed? | The permitted source. |
| G1. Mandate | What are the envelopes, targets, beneficiaries and constraints? | Approved passport. |
| G2. Infrastructure | Where is the account or asset and who is entitled to the transaction? | Connected provider. |
| G3. Project | Is the passport ECO-PPA full and are the connections and risks disclosed? | Decision on admission. |
| G4. Commitment | Is there a contract, budget, limit and terms of the tranche? | Legal instruction. |
| G5. Result | Is the stage confirmed by independent evidence? | Reception or stop. |
| G6. Closure | How is the balance distributed, returned or reinvested? | Report and archive package. |
Formula
SOURCE → MANDATE → QUOTE → RESERVE → PROJECT → CONTRACT → TRANS → EXECUTION → VERIFICATION → DISTRIBUTION / RETURN → ARCHIVE
Stop-rule
If there is no mandatory document, authority or evidence, the cycle stops. The platform does not replace this gap with an automatic solution.
18 / PROJECTS ECO-PPA
ECO-PPA Transfers capital from intention to verifiable project
Formula
TASK + TECHNOLOGY + COOPERATION + CAPITAL + CONTRACT + DATA + RESULTS
Prior to solution. task owner, boundaries, baseline, alternatives, security, performers, budget, source and risk.
Prior to the contract. the powers of the parties, the subject, stages, price, data and IP rights, liability, stop conditions and dispute.
Up to the tranche. limit, calendar, account, confirmation of the previous stage, no conflict and the current authority.
After Execution. Act, evidence, independent verification, deviations, remainder, lesson and new version.
Before scaling. comparability of conditions, reproducibility of the result, stability of the economy and legality of the new perimeter.
Separation
ECO-PPA — passport and contractual-resource framework. SPECZASHCHITA Organize the execution. The independent subject confirms the result. The Funds System decides on the following capital.
19 / REGISTERS AND ARCHIVES
Six registers link law, money, project and result
| Register | Contents |
|---|---|
| R1. Participants and credentials | Personalities, roles, powers of attorney, deadlines, controlling persons and conflicts. |
| R2. Funds and mandates | Passports, goals, prohibitions, beneficiaries and rights. |
| R3. Assets and liabilities | Accounts, instruments, reserves, encumbrances, sources and external links. |
| R4. Projects and contracts | ECO-PPA, stages, budgets, tranches, counterparties and documents. |
| R5. Solutions, risks and incidents | Protocols, reconciliations, challenges, exclusions, warnings and corrections. |
| R6. Evidence and results | Statements, acts, measurements, conclusions, versions and verification status. |
Heritage archive
Receives signed and versioned snapshots of registers, evidence packages and access rules. It does not store bank passwords, private keys and personal data beyond a reasonable need.
Formula
OBJECT → SOURCE → Versions → RIGHT OF ACCESS → DECISION → RESULTS → STORAGE TIME
20 / ROLES AND DIVISION OF CREDENTIALS
No participant controls the entire cycle.
| Role | Answers | Should not simultaneously |
|---|---|---|
| Founder / Donor | Mission, source of assets and basic mandate. | Perform and confirm the project. |
| Board / management body | Policies, Budget, Appointments, Exclusions and Oversight. | Make your own decisions without control. |
| Fund Administrator | Documents, calendar, registers and reports. | Become the owner of the platform assets. |
| Bank / custodian / manager | Operations and accounting within the contract and admission. | Substitute the mission and bodies of the fund. |
| Operator ECO-PPA | Passport, budget, contract and proof route. | Self-authorize the payment. |
| SPECZASHCHITA | Co-operation performance and acceptance materials. | To approve your own result alone. |
| Verifier / Auditor | Independent verification of results and control. | Have an uncontrollable material interest. |
| Archive Keeper | Versions, origin, access and preservation. | Change the content of the official source. |
The Conflict Rule
The related interest is disclosed prior to discussion. The participant does not receive materials beyond what is necessary and does not vote on an issue where his independence is violated.
21 / REWARDERS AND CONTINUATIONS
Beneficiary is not a line in the register, but a carrier of a certain right or expectation
Identification. person, class, organization or mission; in legal entities and complex structures, actual control is analyzed.
The nature of the right: unconditional, conditional, discretionary, urgent, inherited or terminated - according to applicable law and documents.
Informing. what information, with what frequency and to what extent the beneficiary receives.
Complaint and dispute. channel of appeal, independent review, timing, interim measures and archive of the decision.
Vulnerable persons. representation, pressure protection, conflict verification and proportional disclosure.
Continuity. organ replacement, death, incapacity, prolonged absence and transfer of provider functions.
Termination. Fulfillment of obligations, distribution of balance, closing of accounts, storage of documents and final report.
International benchmark
FATF recommends seeing not only the formal founder, but also individuals actually controlling the design, as well as roles affecting the purpose, veto, and distribution.
22 / DISTRIBUTION, LIQUIDITY AND RISK
Politicians translate mandate into measurable constraints
| Policy | Minimum rules |
|---|---|
| Distribution | goals, recipients, conditions, limits, frequency, priorities and prohibitions. |
| Liquidity | commitment calendar, minimum reserve, stress scenarios and recovery plan. |
| Investment | Permissible instruments, horizon, risk, diversification, commissions and responsible person. |
| Concentration | limits on the bank, the manager, the issuer, the asset, the currency, the project and the related party. |
| Expenditure | administration, audit, management, storage, projects and disclosure of total value. |
| Asset valuation | method, price source, frequency, independence and dealing with illiquidity. |
| Reserves | type, size, replenishment, bases of use and restoration. |
| Deviations | who permits, for how long, what proof and how the exception is closed. |
Limitation
The material does not contain promises of profitability, guarantees of return of capital or a statement of no risk. Any investment outline requires a separate qualification and an agreement with the authorized participant.
23 / RISKS, COMPLAINS AND DATA
Critical risks have a stop signal, not just an assessment
| Risk | Basic control | Stop signal |
|---|---|---|
| Substitution of licensed activities | Map of functions, names and tolerances. | The platform must store or attract customer money. |
| Unclear property | Passport of the asset, law and origin. | The owner or nature of the right is not established. |
| Mixing of assets | Separate accounts and regular reconciliations. | The discrepancy with the external statement is not eliminated. |
| Conflict of interest | Disclosure, disqualification and independent approval. | The hidden side. |
| AML/KYC and sanction risk | Risk-based participant and flow testing. | Substantial discrepancy between source and control. |
| Data and Cyber Security | Minimization, access, log, encryption and response. | Critical leakage or loss of access control. |
| Cross-border | Matrix of jurisdictions, taxes, currency and reporting requirements. | The stream has no confirmed mode. |
| Loss of management | Replacement, continuity and plan of the provider. | There is no workable decision body. |
Separate AML-function of the personal fund
From 30 December 2024 executive bodies of personal funds, except hereditary, are included in the special contour of duties under article 7.1 No 115-FZ. The architecture should provide for its own internal control rules, identification and interaction with Rosfinmonitoring - not only KYC banks.
Launch Rule
Taxes, AML/KYC, personal data, currency regime, reporting, protection of beneficiaries and applicability of guarantees are checked for each shell, account and operation separately.
24 / PILOT AND SOLUTION CRITERIA
90 days - Proven solution, not before financial launch
| Timeframe | Stage | Verified result |
|---|---|---|
| 1–15 | Perimeter | Terms, Prohibited Functions, Jurisdiction, Shells, Roles, and Metrics. |
| 16–30 | Normative model | Foundation passport, governance, conflict, providers, data, and threat model. |
| 31–55 | Prototype | Six registers, read-only cabinet, ECO-PPA and export to the Heritage Archive. |
| 56–75 | Dry Runs | Contribution, distribution, tranche, failure, conflict, provider replacement and incident. |
| 76–90 | Independent verification | Legal, tax, AML/KYC and information security conclusions; reconciliation; cost; GO / conditions / NO-GO. |
GO
The legal perimeter is confirmed; the functions are assigned to authorized providers; the rights and sources of assets are clear; the chain "source → solution → transaction → result → archive" is reproduced; role-sharing and data protection work.
NO-GO
Unlicensed transactions are needed; assets cannot be separated; rights or source are not established; hidden guarantee of profitability is required; one participant controls the entire cycle; critical risks of data or jurisdiction are not eliminated.
Next Solution
Only after the conditional GO is the project of a limited 12-month pilot with one legal shell, partner bank or custodian, capital limits, independent control and a separate contractual package.
25 / RUSSIAN LEGAL SOURCES
Official Guidelines for the Russian Outline
The links are checked for the date of preparation. The consolidated version and the applicability of the rule are confirmed before each legally significant operation.
GK RF: Federal law from 01.07.2021 № 287-FZ About personal funds
Civil Code of the Russian Federation, current edition: provisions on personal funds
Federal law of 08.08.2024 № 237-FZ: Changes in personal fund assets
Federal law of 08.08.2024 № 251-FZ: Special rules for personal funds
Federal Tax Service of Russia: personal fund as a form of NGOs and the procedure for changing the charter
Federal Law No 7-FZ "About non-profit organizations"
Federal Law No 135-FZ "Charity and Volunteering"
Federal Law No 275-FZ About procedure for formation and use of target capital of NGOs
Bank of Russia: banks and licensed banking operations
Bank of Russia: verification of financial market participant
Bank of Russia: professional participants in the securities market
Federal Law No 115-FZ: AML/CFT and special responsibilities of personal funds
Bank of Russia: response on the application of AML/CFT requirements to personal funds
Deposit Insurance Agency: Questions and Answers
The Federal Tax Service’s materials and Bank of Russia’s responses help to interpret, but do not replace the text of the law and the individual conclusion.
26 / INTERNATIONAL PRINCIPLES AND STATUS
International sources are used as landmarks of architecture
Before the cross-border launch, the legal form, banking transactions, beneficial ownership, CRS, AML / KYC, taxes and data are checked for each jurisdiction.
FATF: Guidance on Beneficial Ownership of Legal Persons
FATF: Beneficial Ownership and Transparency of Legal Arrangements
G20/OECD Principles of Corporate Governance 2023
OECD: core principles for separation and governance of fund assets
Legal disclaimer
The document presents the author's concept of architecture and the pilot. It is not a legal, tax, investment or bank statement; it does not create rights to raise funds, issue money, accept deposits, manage other people's assets or promise profitability.
Version 1.0 · 29 August 2026 · Author: Sokolov Sergey Leonidovich
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Personal and personal funds on licensed banking infrastructure
The mandate is set by the fund.
Operations are performed by licensed participants.
The evidence preserves the Heritage Archive.
Sokolov Sergey Leonidovich
Accounts show money but do not explain mandate
THE PROBLEM
Fragmented contour
Unresolved issues
Who has the right to make a decision?
Remnant and Movement
QUOTE
For whom and under what conditions?
Obligation
AGREEMENT
What is the risk and what reserve is allowed?
internal classification
TABLE
Who is the one who confirms, confirms and confirms?
What will happen to conflict or continuity?
Evidence and Versions
Papka
Without a mandate, money can be accounted for correctly — and misused.
Sokolov Sergey Leonidovich
The solution now is a 90-day design pilot
REQUEST FOR SOLUTION
Perimeter
Terms, Prohibitions, Jurisdiction, Shells, and Participants.
Normative model
Fund passport, roles, policies, providers and data.
DAYS
Prototype
Six registers, read-only cabinet, ECO-PPA and archive package.
without attracting funds
without financial launch
Dry Runs
Deposit, tranche, rejection, conflict, incident and replacement of the provider.
Independent verification
Law, Taxes, AML/KYC, IS, Cost and GO/NO-GO.
Output: Proven GO, Conditional GO or NO-GO
Sokolov Sergey Leonidovich
Five concepts should not be confused
TERMS AND BORDERS
Management model of a person or family
PERSONAL FINANCIAL CONTOUR
separate legal shell; not an account and not a bank
PERSONAL FUND
mission and identity; the name does not create an OPF
NAMED FUND / PROGRAM
special regime of property of NGOs, not a separate legal entity
TARGET CAPITAL
Licensed accounts, payments and other transactions
BANKING CONTOUR
The word “fund” describes the idea only after checking the legal shell, the owner of the assets and the mode of operations.
Sokolov Sergey Leonidovich
The system of funds connects the forecast with the legal decision on capital
LOCATION IN THE ECOSYSTEM
EQUILIBRIUM
FUND SYSTEM
BANK / CASTODIAN
ECO-PPA
RESULT
Signal • Scenario • Risk
Mandate • law • budget
account • transaction • account
contract • stage • tranche
Act • Measurement • Acceptance
HERITAGE ARCHIVE
origin • version • access rights • proof • continuity
SFERA
initiatives • participants • knowledge • feedback • scaling
EQUILIBRIUM does not move money. The system of funds does not execute the project. The archive does not rewrite the source.
Sokolov Sergey Leonidovich
Each fund is a node of six mandatory layers
ARCHITECTURE OF THE Knot
WILL, PURPOSE AND RIGHTS
Founder / Donor • Mission • Beneficiaries
CONTROL
AML/KYC
TAXES
DATA
KIBER
AUDIT
LEGAL SENSE
Charter • bodies • competence • succession
ASSETS AND COMMITMENTS
owner • accounts • tools • reserves
LICENSE INFRASTRUCTURE
Bank • Depositary • Broker • Managing Director
PROJECT CONTOUR
ECO-PPA • Contract • budget • Trench • acceptance
PROOF AND HERITAGE
Decisions • Statements • Acts • Version • Archive
Passing one layer turns the idea into an uncontrollable exception.
Sokolov Sergey Leonidovich
The type of fund is defined by the task, not the name
ARCHETIPS
ARCHETIP
TASK
KEY CONTROL
Personal / Family
Continuity of capital
rights and substitution of organs
Name
Mission Name or Territory
Name does not replace status
Endowment
Long-term mission
Mode 275-FZ and expenditure
Charitable
Publicly Helpful
Selection and targeted use
Project
Measurable result ECO-PPA
contract, tranches, acceptance
Standby
liquidity and continuity
Terms of Use and Recovery
Developments
Technology and Cooperation
Risk without promised return
The legal form is selected separately for each purpose, jurisdiction, asset and membership.
Sokolov Sergey Leonidovich
Personal fund manages continuity; personal - mission
TWO DIFFERENT VECTORS
PERSONAL FUND
NAMED FUND / PROGRAM
Legal Shell
Mission and Identity
- Separate unitary NPO; property belongs to the fund.
- When creating: property of the founder of 100 million ₽, Except the inheritance fund.
- The rights of beneficiaries, bodies and substitution scenarios are fixed by documents.
- With 30.12.2024 executive body, in addition to the hereditary fund, has its own AML-duties.
- There is no separate “name fund”.
- Possible: the name of the NGO, the program within the NGO, a separate target capital or a personal fund with a personal mission.
- The name requires consent, rules of use, reputational limitations and continuity.
- Accounts and contracts belong to the real organization, not the name of the program.
Checked on the date of establishment
Name creates mission; documents create rights
It is impossible to promise automatic protection of assets, tax neutrality or guaranteed safety.
Sokolov Sergey Leonidovich
The Bank performs operations, the system manages the mandate
LIMIT OF LICENSE
FUND SYSTEM
BANK / CASTODIAN / MANAGING
- Fund passport, mandate and beneficiaries
- Budgets, limits, reserves and calendar
- Route of approvals and preparation of instructions
- Read-only review of extracts and reconciliation
- ECO-PPA, documents, incidents and archive
- Opening and maintaining a bank account
- Payment and bank statement
- Brokerage operation and report
- Depository or registry account
- Asset management within the license
AUTHORIZED
INSTRUCTION
Stop: Accept deposits, open accounts with customers, store or transfer their money, promise guarantees or returns without status.
Secure name of the interface: "Capital Cabinet" or "Personal Treasury".
Sokolov Sergey Leonidovich
Capital passes seven locks G0-G6
CAPITAL CYCLE
SOURCE
MANDATE
INFRA
PROJECT
COMMITMENT
RESULT
CLOSING
owner and origin
shell, purpose, rights
Account and Authority
ECO-PPA and risks
contract, limit, tranche
independent proof
remainder, report, archive
SOURCE → MANDATE → QUOTE → RESERVE → PROJECT → CONTRACT → TRANS → VERIFICATION → ALLOCATION → ARCHIVE
There is no mandatory document, authority or proof - the cycle stops.
Sokolov Sergey Leonidovich
ECO-PPA turns capital into a verifiable project
PROJECT CONTOUR
TASK + TECHNOLOGY + COOPERATION + CAPITAL + CONTRACT + DATA + RESULTS
BEFORE DECISION
BEFORE THE TREATY
BEFORE TRANSHA
AFTER EXECUTIVE
owner of the task • baseline • alternatives • security • budget • risk
authority • Subject • Stages • price • Data and IP • Responsibility • Dispute
limit • calendar • invoice • previous stage • conflict • current power
act • actual data • independent verification • deviations • remainder • lesson
ECO-PPA — passport and contractual-resource framework. SPECZASHCHITA Organize the execution. The independent subject confirms the result. The system of funds decides what is next with the capital.
Sokolov Sergey Leonidovich
Six Registers and the Heritage Archive Preserve the Evidence Chain
DATA AND CONTINUITY
ATTENDANCE AND CREDENTIALS
FUNDS AND MANDATES
ARCHIVE
HERITAGE
ASSETS AND COMMITMENTS
PROJECTS AND CONTRACTS
Signed pictures
Versions and Origin
Access Rights
Control amounts
Storage time
SOLUTIONS, RISKS, INCIDENTS
PROOF AND RESULTS
OBJECT → SOURCE → Versions → RIGHT OF ACCESS → DECISION → RESULTS → STORAGE TIME
The archive does not store bank passwords and does not change the content of the official source.
Sokolov Sergey Leonidovich
No participant controls the entire cycle.
DIVISION OF CREDENTIALS
PROBLEMS
PERFORMANCE
CONFIRMS
Founder / Donor
Bank / custodian / manager
Independent Verifier
Board / management body
Operator ECO-PPA
Auditor / Compliance
Funds system
SPECZASHCHITA
Archive Keeper
The contractor does not confirm its own result. The internal platform does not become the owner of the assets.
The conflict is revealed before the discussion; the participant is withdrawn if independence is violated.
Sokolov Sergey Leonidovich
Risks have stop signs, not just estimates
COMPLAINS AND DATA
RISK
STOP SIGNAL
Substitution of license
The platform needs to store customer money
Unclear property
The owner or nature of the right is not established
Mixing of assets
Difference with external statement is not eliminated
Conflict of interest
The Hidden Linked Side
AML/KYC and sanctions
Significantly unclear source or control
Data and cyber risk
Leakage or loss of access control
Cross-border
no confirmed flow mode
Specific oversight of a personal fund: since 30.12.2024, the executive body, except in the case of a hereditary fund, has its own obligations under Article 7.1 of No. 115-FZ — not only the bank’s KYC requirements.
Sokolov Sergey Leonidovich
90 days - proven GO, not before financial launch
NEXT DECISION
1–15
16–30
31–55
56–75
76–90
PERIMETER
MODEL
PROTOTIP
PROGONGS
VERIFICATION
terms • prohibitions • shell
Passport • Roles • Policy
registers • office • archive
tranche • failure • conflict
right • AML • IS • cost
unlicensed functions are required or the right is not established
perimeter is legal and the chain is replicable
gaps are limited, there are owners and deadlines
USL. GO
NO-GO
Approve the design pilot. Financial startup is a separate solution after a conditional or full GO.
Sokolov Sergey Leonidovich
Sources indicated in the presentation 24
- Project-bound AI-generated hero image; no external URL.
- Bank of Russia, banking operations and licensing — https://cbr.ru/admissionfinmarket/navigator/banks/
- Bank of Russia, banks and banking operations — https://cbr.ru/admissionfinmarket/navigator/banks/
- G20/OECD Principles of Corporate Governance 2023 — https://www.oecd.org/en/publications/g20-oecd-principles-of-corporate-governance-2023_ed750b30-en/full-report/component-8.html
- Bank of Russia, verification of financial market participants — https://cbr.ru/finorg/
- Civil Code of the Russian Federation, current edition — https://pravo.gov.ru/proxy/ips/?docbody=&nd=102033239
- Russian Federation Civil Code — https://pravo.gov.ru/proxy/ips/?docbody=&nd=102033239
- Federal Law No 275-FZ — https://www.pravo.gov.ru/proxy/ips/?docbody=&link_id=0&nd=102111248
- Bank of Russia, banking operations — https://cbr.ru/admissionfinmarket/navigator/banks/
- OECD, governance and separation of fund assets — https://legalinstruments.oecd.org/public/doc/344/fa84ef90-e2bd-4171-802a-b5c15aa3106d.html
- FATF, beneficial ownership of legal persons — https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Guidance-Beneficial-Ownership-Legal-Persons.html
- Federal Law No 7-FZ — https://pravo.gov.ru/proxy/ips/?docbody=&nd=102039064
- Federal Law No 135-FZ — https://pravo.gov.ru/proxy/ips/?docbody=&nd=102037027
- Federal Law No 287-FZ — https://publication.pravo.gov.ru/Document/View/0001202107010047
- Federal Law No 237-FZ — https://publication.pravo.gov.ru/Document/View/0001202408080033
- Federal Law No 251-FZ — https://kremlin.ru/acts/bank/50918
- Federal Tax Service of Russia, personal fund — https://www.nalog.gov.ru/rn37/news/activities_fts/16339647/
- Federal Law No 115-FZ — https://pravo.gov.ru/proxy/ips/?docbody=&nd=102072376
- Bank of Russia, banks — https://cbr.ru/admissionfinmarket/navigator/banks/
- Bank of Russia, verification of financial market participant — https://cbr.ru/finorg/
- Bank of Russia, professional participants — https://cbr.ru/admissionfinmarket/navigator/purcb/
- FATF, transparency of legal arrangements — https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Guidance-Beneficial-Ownership-Transparency-Legal-Arrangements.html
- Bank of Russia, response to the application of AML/CFT to personal funds — https://www.cbr.ru/Queries/UniDbQuery/File/104594/342/A
- FATF, beneficial ownership — https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Guidance-Beneficial-Ownership-Legal-Persons.html
