What does the Federal Tax Service know about your foreign accounts?

• The Federal Tax Service receives not a bank statement, but a standardized set of fields: owner, account location, year-end balance, and income amounts by category. Payment purposes and counterparties are not included in this set, hence the requests for clarification.
• It's not the exchange itself that has legal weight, but the Federal Tax Service's list. Currently, it includes 80 jurisdictions: 71 states and 9 territories.
• Effective December 22, 2025, the British Virgin Islands, Bermuda, Gibraltar, and the Turks and Caicos Islands were removed from the list. A report for the year of removal is submitted for all accounts in these jurisdictions, regardless of the amount.
• An account of a passive foreign company reveals the beneficial owner: the information goes to the controlling person, not just the company itself.
• A discrepancy between the received data and your reporting is an automatically triggered risk in the system. The inspector is involved after the risk has been identified.
• From April 1, 2026, quarterly reporting for companies and individual entrepreneurs will be calculated in working days, not calendar days, and will be processed in a new way when opening or closing an account within a quarter.

What's actually included in the exchange file

Let's start with a straightforward answer, as there's a lot of confusion surrounding this topic. The Federal Tax Service (FTS) sees four things in your foreign account: your identity—name, date of birth, address, and tax identification number; the account information—the name and identifier of the financial institution, account number; the amount in it at the end of the reporting year; and income amounts, broken down into broad categories—interest, dividends, other income, and, for brokerage accounts, also gross proceeds from the sale of assets. As part of the exchange, standardized data about the account holder, bank, and account number, balance, interest, and other income is transferred annually. This exchange applies to accounts of both individuals and legal entities, as well as data on controlling persons of passive foreign companies. What's not included in the file: payment purposes, counterparty names, monthly dynamics, and scanned copies of contracts. It's this gap that the FTS addresses with its requests.

Field Set and Its Blind Spots

The difference between "seeing balance" and "seeing movement" is huge in practice. If an account balance is 40,000 euros on December 31st, and 5,000 euros a year ago, the exchange will show both figures and the income category, but it won't explain the source of the difference: whether you sold an apartment, received a loan from a partner, transferred your own money from a Russian bank, or earned money from consulting. All four scenarios have different tax consequences, and you are responsible for confirming the correct one.

Therefore, real protection is built not on hoping the data won't reach you, but on a documentary trail. A sales contract, a payment order from a Russian account, a loan receipt, an invoice—all of this should be collected at the time of the transaction, not two years later, when the bank has already changed its compliance officer and is taking months to respond to inquiries.

Closing an account doesn't erase the trail

A common misconception: if you close an account, the issue is resolved. The standard is structured differently. An account closed during the reporting year still appears in the financial institution's reports as closed. Moreover, the absence of a balance at the end of the year does not mean the absence of a line item in the file: income categories for the holding period are exchanged.
Changing banks within a single jurisdiction works similarly. Transferring a portfolio from one broker to another creates two entries instead of one and, as a rule, increases, not decreases, visibility.

A passive company reveals the beneficial owner

For owners of corporate structures, this is a key element. The financial institution classifies the account holder: an active company reports on its own, while a passive company reports together with its controlling parties. A passive structure is typically considered one in which more than half of its income or assets are investment-related: dividends, interest, royalties, rent, and securities appreciation.
A classic holding company in the Seychelles or Belize almost always falls into the passive category. This means that the file will show not an abstract legal entity, but a specific individual with a Russian tax identification number (TIN), and the account balance will be attributed to them in full, without dividing it into equity shares. Owners of structures in the UAE, Hong Kong, and Singapore encounter this regularly, and it's better to know your company's classification in advance than to learn it from an inspection request.

How data becomes a tax inspectorate request

There's a fairly clear procedure between the receipt of a file by the Federal Tax Service and the email in your personal account, and understanding its timing alleviates half the anxiety. Automatic exchange data arrives by the end of September of the year following the reporting year. This means that information for 2025 was entered into the system in the fall of 2026, and reached taxpayers in a wave of requests closer to winter and spring.

Identification and Reconciliation

The first step is linking a foreign record to a Russian taxpayer. The automatic identification rate has long since exceeded 90%, and it's growing: the Taxpayer Identification Number (TIN), passport information, and address you provided in the self-certification form when opening an account alleviate this.
The system then compares the received data with what you declared. The logic is described quite straightforwardly by service representatives: an identified individual is checked to determine whether they have declared the income and controlled foreign companies reported. If there is a discrepancy, a risk is triggered and a task is generated, which the inspector then follows. This isn't a manual search—it's an automated control procedure.

A Scale Worth Keeping in Mind

The numbers are useful for a sober assessment. The number of Russians with foreign bank accounts has grown from 539,000 to 700,000, and the number of accounts in countries with automatic exchange has exceeded 2 million, growing at a rate of 12% annually. Self-declaration of foreign accounts is growing by an average of 31% annually, and the number of declared controlled foreign companies has increased by 18% compared to 2021 levels.
The shift in focus is even more telling. Tax authorities have tightened their scrutiny of income in foreign accounts and are now working with taxpayers even with relatively small amounts that they previously overlooked: more data is analyzed, and audits take less time. The threshold below which they "won't notice" has virtually disappeared.

IT-OFFSHORE Expert Commentary

"Over the past three years, the nature of inquiries has changed dramatically. Previously, a letter from the tax office meant that you were being specifically targeted. Now, it's most often the result of a machine comparison of two data sets, and the content of the letter is predictable: confirm the nature of the income, explain the discrepancy with the declaration, and attach a statement. The practical conclusion is simple: the winner is the one who has collected documents in advance and has described the structure honestly. When working with clients, we always begin not with choosing a jurisdiction, but with a map: where you are a tax resident, what accounts you have opened, which company is active and which is passive, what was filed with the Federal Tax Service and when. This map takes up one page and mitigates more risks than any exotic ownership structure".

The Federal Tax Service list weighs more than the exchange itself

There's a nuance here that almost all overview texts miss. For your responsibilities, the important question isn't "whether a specific country submitted a file this year," but rather "whether this country was on the Federal Tax Service list on the required date." The list is a regulatory document, and it functions as a switch for several modes at once.

Who's in and who's out

The current list was approved by Federal Tax Service Order No. ED-7-17/883@ dated October 14, 2025, and entered into force on December 22, 2025. It includes Kenya, Moldova, Mongolia, Papua New Guinea, Senegal, Thailand, Trinidad and Tobago, Uganda, and Saint Martin, while excluding Bermuda, the British Virgin Islands, Gibraltar, and the Turks and Caicos Islands. In total, the list contains 71 countries and nine territories.
EU countries were excluded earlier: 26 EU member states were excluded by the previous order for unilaterally ceasing exchanges with Russia. However, key destinations for Russian business remain on the list:the UAE, Turkey, China, Hong Kong, Singapore, Kazakhstan, Armenia, the Seychelles, and Panama.

The year of exclusion is subject to reporting

The most counterintuitive consequence of the list change was clarified in a letter from the Federal Tax Service. When a country is removed from the list, a report for the year of exclusion is submitted for all accounts in banks in that country, regardless of the turnover and balances at the end of the year. Individuals submit reports at the end of the year, so you should refer to the list current as of December 31 of the reporting year.
Let's translate this into actionable terms. If you have an account in the British Virgin Islands or Gibraltar, the 600,000 ruble threshold for 2025 no longer applies—a report is required for any balance, even zero. And this isn't a one-off: for 2026 and beyond, these jurisdictions also require reporting without a threshold.

The Currency Side and Its Current Interpretation

The list has traditionally also governed the legality of transfers: Part 5.2 of Article 12 of Federal Law No. 173-FZ allows resident individuals to receive funds from non-residents without restrictions into accounts in banks in EAEU countries and countries on the list. However, the current picture is more lenient than it is painted. The Bank of Russia has officially clarified that funds received from non-residents may be credited to foreign accounts and foreign electronic payment systems for any reason.
This clarification is based on the temporary regime of presidential decrees and should not be relied upon indefinitely. The safety net also remains: if funds are received into an account in a country without automatic exchange, they can be transferred to a Russian account within 45 days, and the fine under Article 15.25 of the Code of Administrative Offenses will not apply.

Reporting that is reconciled with the exchange

The exchange data itself does not create tax. Claims arise from a gap between what came from the foreign bank and what you submitted. Therefore, filing discipline is not bureaucracy, but a way to remove the opportunity for questions.

Deadlines that are most often missed

Notification of opening, closing or changing account details is submitted within 1 month. An annual report on cash flows and other financial assets of an individual must be submitted by June 1 of the following year. The exemption is valid if the bank is located in the EAEU country or in a country from the list and the amount of deposits for the year did not exceed 600,000 rubles, as well as if you spent more than 183 days outside Russia. Lack of movement on the account does not exempt you from reporting.
For companies and entrepreneurs, the regime has become noticeably more comfortable. Government Decree No. 305 dated March 24, 2026 established that quarterly reports are submitted within 30 working days after the end of the quarter, not calendar days, and clarified the procedure for accounts opened or closed within the quarter. It’s a small thing, but it removes regular delays during the May and January holidays.

The price of inattention

The amounts of fines on the accounts themselves are small: for failure to submit a notification, a citizen faces from 4,000 to 5,000 rubles, for violating the deadline for submitting a report - from 300 to 3,000 rubles, depending on the delay. Another thing is more dangerous: failure to submit a notification about a controlled foreign company costs 500,000 rubles for each company, and an illegal currency transaction costs from 20% to 40% of the amount.
If you are in Moscow, the entire cycle is closed remotely through the taxpayer’s personal account; you do not need to come to the inspectorate at the place of registration. We support clients from Moscow and the regions in the same format - preparing the kit, checking the translation of bank statements, submitting and responding to subsequent requests.

Where is transparency heading

The system is evolving, and it's worth planning the structure with a horizon of at least a couple of years. The updated version of the standard expands its scope: electronic money and central bank digital currencies will be covered by the CRS starting January 1, 2026.

Cryptoassets receive their own standard.

A separate mechanism for digital assets is being rolled out in parallel. The first reporting period for the Cryptoasset Reporting Standard began in 2026, the first automatic exchange is planned for 2027, and 48 jurisdictions, accounting for over 92% of global trading volume, have committed to implementation. Russia is not yet participating in this framework, but for owners of crypto projects and licensed platforms, this means one thing: exchange account anonymity is no longer a working assumption when designing the structure.

What to do about this today

The practical approach has not changed over the years: first, an honest inventory, then a decision. Check your tax residency status based on your actual residence, what accounts are opened in your name and in the names of your companies, what classification is assigned to each structure, and what was submitted to the Federal Tax Service and when. Discrepancies are almost always found, and they are almost always cheaper to voluntarily correct than to respond to a request.
Next, work on the architecture begins: where to keep operating accounts, which jurisdiction to choose for the holding company, whether a bank account is required in the company's country of incorporation, and whether a ready-made solution with an account makes sense or registering from scratch. There are no universal answers here—there are your business model, the geography of your counterparties, and the acceptable level of administrative burden. This is where we begin our discussion.