Russian Federation currency residency: responsibilities of a foreign account holder

• Every Russian citizen and every foreigner with a Russian residence permit is a currency resident of the Russian Federation. Relocation, a second passport, and non-tax resident status do not cancel this status.
• There are three obligations: notify the tax authorities of the opening, closing, or change of account details within one month, regularly submit a report on the movement of funds, and make only authorized deposits to the account.
• Effective December 22, 2025, the British Virgin Islands, Gibraltar, Bermuda, and the Turks and Caicos Islands were removed from the list of automatic currency exchange countries. Owners of personal accounts in these jurisdictions lost both the threshold exemption from reporting and the right to accept any income from non-residents.
• Effective April 1, 2026, companies and individual entrepreneurs must submit a quarterly report within 30 business days of the end of the quarter, and the obligation to report for foreign members of an international group has been limited to parent and authorized companies.
• The limit on foreign currency transfers for Russian citizens was lifted effective December 8, 2025. The ban for non-residents from unfriendly countries has been extended until December 7, 2026.
• Illegal transfers to a foreign account carry a fine of 20 to 40 percent of the transaction amount, and the statute of limitations for currency violations is two years, and for unfiled reports, it begins on the date of discovery.

If you are a Russian citizen, you are a currency resident of the Russian Federation—always, regardless of where you live or how long you have been away from the country. This status entails three specific obligations to the tax authorities: report your foreign account within one month of opening, regularly report its cash flow, and ensure that each deposit is included in the list permitted by law. Everything else—details, deadlines, and exceptions—determines whether your account ownership will be secure or devolve into a legal battle with the tax authorities.

Currency resident and tax resident: why are they constantly confused?

This confusion costs people more money than any complex scheme. Tax residency is calculated by days: if you spend 183 or more days in Russia in a calendar year, you are a tax resident; if you spend less, you are not. Currency residency is calculated by passport. A Russian citizen always remains a currency resident, even if they have lived in Dubai for the past 10 years and have not visited Russia.

Days abroad do not change status, but the scope of obligations

Part 8 of Article 12 of Federal Law No. 173-FZ exempts those who have spent more than 183 days outside of Russia in a calendar year from notification and reporting. Currency resident status is retained; only the obligation to disclose accounts for that specific year is lifted. The term "more than 183 days" means 184 days or more. Entry and exit days count toward the length of stay abroad, and must be confirmed with passport stamps, airline tickets, and immigration documents.

A year abroad, a year at home—and the obligations return

The exemption applies on a calendar-year basis, not forever. Anyone who spent 200 days abroad in 2025 without filing any reports, and then spent 150 days outside Russia in 2026, is required to notify all their foreign accounts, including those opened during the exemption years, and submit a report on the movement of funds by June 1, 2027. This is expressly stipulated in the law, and it is precisely this provision that trips up those who return to Russia after several years abroad.

A residence permit and a second passport do not cancel your status

Foreign citizenship and Russian citizenship exist in parallel: as long as a Russian passport is valid, foreign currency residency remains valid. The opposite is also true: a foreigner with a Russian residence permit becomes a Russian currency resident with all the same obligations. If you are considering changing your tax and personal jurisdiction, it makes sense to consider the consequences in advance, rather than after the fact; status options can be found in the Residence Permit section.

Account Notification: What is Considered a Foreign Account in 2026

The deadline is one month from the date of opening, closing, or changing the account details. Form KND 1120107 was approved by Federal Tax Service Order No. SD-7-14/349@ dated April 26, 2024, and is applicable from July 1, 2024. A separate form is used to change account details. The easiest way to submit is through your personal taxpayer account with an electronic signature; paper or registered mail are also acceptable. The notification is submitted once for each account; it does not replace or replace reporting.

Banks, brokers, wallets, and branches of Russian banks

Notification is required not only for bank accounts but also for accounts with other financial market organizations: brokers, depositories, insurers, and investment platforms. The key indicator is where the organization itself is registered, not whose capital it represents. An account with a Russian group's subsidiary bank abroad is a foreign account. However, an account with a foreign branch of an authorized Russian bank is not covered by Article 12 at all, as stated explicitly in Section 9.

E-wallets like PayPal, Wise, and Alipay operate under a different rule: no notification is required of their opening, but they must be reported if the equivalent of more than 600,000 rubles is credited to the wallet within a year. The difference is subtle, which is why wallets often end up with undisclosed accounts.

What to do if an account has been open for a long time and hasn't been declared

This situation is common and solvable. Late notification costs an individual 1,000-1,500 rubles, while failure to report at all costs 4,000-5,000 rubles. For companies, the figures are different: up to 100,000 rubles for late payment and up to 1,000,000 rubles for failure to report. Compared to 20-40 percent of each illegal transaction, this is a small amount, so independent disclosure is almost always cheaper than silence. It's important, however, not to submit documents haphazardly: first, build a picture for each account and each year, then submit the forms.

Cash Flow Report: Where is the Exemption Limit?

Individuals submit the report once a year, before June 1 of the year following the reporting year. Companies and sole proprietors submit quarterly. The exemption for individuals applies only if two conditions are met simultaneously: the account is opened with a bank in an EAEU country or a country on the automatic exchange list, and either the account turnover for the year did not exceed 600,000 rubles, or the account balance as of December 31 did not exceed 600,000 rubles without any deposits. A Kazakh or Armenian bank alone is not sufficient; the threshold is mandatory.

The list of automatic exchange countries has been reduced, and this changes the calculations

Order of the Federal Tax Service dated October 14, 2025 No. ED-7-17/883@ entered into force on December 22, 2025. The list includes Kenya, Moldova, Mongolia, Papua New Guinea, Senegal, Thailand, Trinidad and Tobago, Uganda, and Saint Martin. Bermuda, the British Virgin Islands, Gibraltar, and the Turks and Caicos Islands have been removed.

For the owner of a personal account in the BVI or Gibraltar, this has two consequences: the 600,000 ruble threshold for such an account no longer prevents reporting, and deposits from non-residents are again limited to the closed list in Part 5 of Article 12. Conversely, a Thai account has moved into a more favorable category—it can now accept any income from non-residents, including funds from the sale of real estate.

Expert opinion

"We ask clients to check the automatic exchange list not when opening an account, but before each major transaction and before each reporting season. The list is reviewed approximately once a year, and a jurisdiction may be omitted without any connection to your plans. The practical method is simple: each account has a short card with answers to two questions: whether the country is on the list on the date of a specific deposit, and whether the annual turnover is within 600,000 rubles. The card takes up five lines and covers most of the risks under Article 15.25 of the Code of Administrative Offenses of the Russian Federation. It's also worth remembering: turnover and balances are calculated separately for each account, not cumulatively across all of the person's accounts."

The rules for companies and individual entrepreneurs changed as of April 1, 2026

Government Resolution No. 305 of March 24, 2026, introduced three substantive changes to the procedure set out in Resolution No. 819. The deadline for submitting quarterly reports is now calculated in business days—30 business days after the end of the quarter, instead of the previous 30 calendar days. The procedure for accounts opened after the first of the quarter and closed within the quarter has been clarified: the report is submitted for the actual period of ownership. The scope of cases in which a Russian company reports for foreign participants in its international group has also been reduced—now the parent company or authorized participant does so, while reporting for foreign banks in the group is not required at all.

There are no threshold concessions for businesses: companies and individual entrepreneurs can submit reports for any foreign account, in any country, regardless of turnover, including zero. If an account is opened for operational purposes, it's best to factor this burden into the model in advance—along with the choice of bank and settlement structure, which we discuss in detail in the Banks and Processing section.

Permitted Transfers: Where Violations Most Often Occur

Reporting is discipline, but transfers are money. The fine for an illegal foreign exchange transaction ranges from 20 to 40 percent of the amount, and is assessed not on profit, but on the entire amount received. The logic of the law is as follows: one can freely transfer one's own funds from one's other accounts to a foreign account, but the receipt of funds from third parties is regulated by geographic location.

Accounts in the EAEU and Automatic Exchange Countries

Part 5.2 of Article 12 allows individuals to receive any funds from non-residents into such accounts, without any restrictions on the basis. The sale of foreign real estate, payment under a contract with a foreign client, income from a foreign fund—all of this is legal if the bank is located in Armenia, Kazakhstan, Georgia, the UAE, or another country on the list. This is why the bank's geography is now more important than the interest rate on the balance.

Accounts in Other Jurisdictions

This list includes: salaries under an employment contract with a non-resident, travel expenses, pensions and stipends, alimony and social benefits, non-resident insurance payments, refunds of previously paid amounts, payments under foreign court decisions, interest on balances, minimum deposits upon opening, cash, and conversion results of already credited funds. Anything outside this list may be considered illegal by the tax authorities.

The practical conclusion is simple: an account in a jurisdiction not on the list is good for storage and spending, but poorly suited for receiving proceeds. It's more logical to deposit funds into such a system from your own account in the country where the automatic exchange is available.

Dividends from Russian companies remain subject to a separate ban

Decree No. 79, as amended by Decree No. 430, prohibits the deposit of foreign currency into foreign accounts if this involves the transfer of funds received as dividends on shares of Russian joint-stock companies or through the distribution of profits of Russian companies. This restriction applies regardless of where the account is opened and whether the country is on the automatic exchange list. For Russian business owners with assets abroad, this is a separate issue that must be considered before making a payment, not afterward.

Transfer Restrictions: What's Already Been Lifted and What Remains

Even seemingly recent publications here are massively outdated. Effective December 8, 2025, the Bank of Russia lifted limits on foreign currency transfers abroad for Russian citizens and non-resident individuals from friendly countries. The previous ceilings of $1,000,000 per month into foreign bank accounts and $10,000 through transfer systems no longer apply.

What remains in effect until December 7, 2026

Restrictions have been extended for non-residents from unfriendly countries: individuals and legal entities from such countries not employed in Russia are not allowed to transfer funds abroad, while those employed are allowed to transfer their salaries. An exception is made for foreign companies controlled by Russian entities and for investors using "In" accounts.

The absence of a limit does not equal the absence of control

The Bank continues to act as a currency control agent and requests transaction documentation. When making the first transfer to their foreign account, a legal entity submits a Federal Tax Service notification to the Russian bank confirming acceptance. Payment verification checks have become more thorough: banks examine the chain of counterparties, the purpose of the payment, and whether the amount corresponds to the stated reasons. A prepared explanation for the transaction saves weeks of correspondence.

How to structure the process and where we intervene

Foreign exchange obligations are best managed as an annual cycle rather than as a one-time task. We support this entire cycle: from selecting a bank's jurisdiction for a specific type of income to preparing notifications and reports and defending your position in response to regulatory inquiries.

Annual calendar for foreign account holders

Companies must submit a CFC notification for the previous year by March 20th, while individuals must do so by April 30th. The penalty for missing the deadline is 500,000 rubles per company. Individuals must submit a cash flow report for the previous year by June 1st. Companies and sole proprietors must submit reports quarterly within 30 business days of the quarter's close. Notification of participation in a foreign organization must be submitted within three months of acquiring a stake; the penalty for missing the deadline is 50,000 rubles per company.

It's worth creating a calendar tailored to your structure once and then simply maintaining it, because account due dates and company due dates are separate and rarely overlap.

What we do on the client's side

We analyze the structure: what accounts exist, who owns them, in what jurisdictions, what receipts are coming from them, and what is planned. We check each basis for crediting for compliance with Article 12. We prepare forms and supporting documents, including bank statement translations. If there are undeclared accounts or disputed transactions from previous years, we calculate the consequences for each year separately and propose a disclosure procedure that minimizes the penalties.

We work remotely and in person, offering consultations via a Moscow phone number and email; you can contact us through the contacts section. If you're simultaneously working on a corporate structure, consider company registration and existing companies with open accounts—we integrate the currency aspect into the solution from the start, rather than adding it on later.