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The subject of this study is the legal relations arising from the interaction between the Federal Tax Service of Russia and the Federal Financial Monitoring Service (Rosfinmonitoring) in the identification, verification, and assessment of tax offenses and crimes. Particular attention is paid to the legal regime governing the use of financial monitoring data in tax control, the limits of interagency data exchange, the role of beneficial ownership information, and the specifics of controlling transactions involving digital currency and mining. The purpose of the study is to determine the conditions under which Rosfinmonitoring materials may be used in tax proceedings, to identify regulatory gaps, and to propose a legal model for their lawful and proper use in the course of tax control and in preparing decisions of tax authorities. The article also examines legislative changes adopted in 2024–2026 affecting digital currency, mining registries, and special tax reporting. The methodological framework of the study includes the formal legal and systemic methods, the analysis of judicial practice and law-application materials, as well as reference to OECD and FATF documents as international regulatory benchmarks. The scientific novelty of the study lies in substantiating a three-stage model for the use of Rosfinmonitoring data in the tax sphere: an analytical signal, procedural verification, and evidentiary synthesis. The article demonstrates that financial monitoring materials cannot be regarded as a self-sufficient basis for concluding that a tax offense or crime has been committed; however, they may lawfully serve as a basis for directing and deepening an audit, provided that they are subsequently assessed together with other evidence. The study concludes that it is necessary to clarify paragraph 3 of Article 82 of the Tax Code of the Russian Federation, to supplement Article 9 of Federal Law No. 115-FZ with a rule on the composition of the analytical package, and to introduce subordinate regulation governing the exchange of information on digital currency, mining, and high-risk transactions. The findings may be used in both lawmaking and law-enforcement practice.
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Mikhail Sergeevich Zhirkov (2026) studied this question.
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