Currency control in Russia operates on two levels. The first is the requirements of the federal law “On Currency Regulation and Currency Control,” which apply on an ongoing basis and cover the basic obligations of residents: notifying the tax authority about foreign accounts, reporting on the movement of funds through them, and complying with limits on cash currency transactions.

The second level consists of restrictions introduced by presidential decrees in connection with sanctions. These restrictions cover financing of foreign companies, granting loans to non-residents, as well as transactions involving real estate, securities, and shares in Russian companies where the counterparty is connected to an unfriendly state. Many such transactions require a separate permit from the Russian Government Commission for Control over Foreign Investment.

Failure to comply with these rules creates risks beyond fines: a transaction carried out in violation of presidential decrees may be declared invalid, and the proceeds received under it may be recovered in favor of the state.

Below is a detailed breakdown of all the key requirements.

Notifications and Reports on Foreign Accounts

Notification and reporting obligations depend on how much time a resident has actually spent in Russia during the year.

Residents who spent more than 183 days in Russia during the year are required to:

– file a notification with the tax authority on the opening, closing, or change of details of a foreign account — no later than one month from the date of the relevant event;
– if a resident spent more than 183 days outside Russia, but in the previous year was present in Russia for 183 days or more, the notification is filed by June 1 of the following year;
– file a report on the movement of funds through the foreign account by June 1. The procedure here depends on the country where the account is held:
– if the account is held with a bank in an EAEU member state or in a state that automatically exchanges financial information with Russia, a report is required only if the account’s annual turnover exceeded 600,000 rubles, or if the year-end balance exceeded that amount;
– if the account is held in any other foreign state, a report must be filed regardless of the transaction amount.

Residents who spent 183 days or less in Russia during the year are exempt from the obligation to file notifications and reports on foreign accounts.

Two further points are worth noting:

– currency transactions involving the withdrawal of lawfully credited funds from foreign accounts may be carried out without restriction;
– if a resident receives a loan from a non-resident into their foreign account, for repatriation purposes the funds must be transferred to a Russian bank within 45 days.

Cash Currency Transactions

Cash withdrawals. For accounts opened before March 9, 2022, a limit applies to cash withdrawals of foreign currency — 10,000 US dollars, or the equivalent amount in euros. If the account balance exceeds this limit, the remaining amount may only be withdrawn in rubles.

Taking currency out of Russia. Taking cash foreign currency out of Russia is prohibited if the amount exceeds the equivalent of 10,000 US dollars. When taking out several types of currency at once, each is converted into rubles at the Central Bank’s exchange rate on the date of departure, after which the resulting ruble amount is converted in aggregate into US dollars to verify compliance with the limit.

Funding Foreign Accounts by Residents

The rules for crediting funds to residents’ foreign accounts differ depending on the currency of the transfer:

– rubles may be credited to a foreign account without any restrictions, including in cases where the funds are subsequently converted into foreign currency abroad;
– foreign currency may be credited, except in cases where the source of funds is profit distributed by Russian legal entities. This rule covers, in particular, dividends on shares of joint-stock companies and distributed profit of limited liability companies.

Financing Foreign Companies

Presidential Decree No. 81 of March 1, 2022, and subsequent acts govern how residents may invest in foreign organizations and grant them loans.

Contribution to charter capital. A resident may make a contribution to the charter capital of a foreign organization, or pay for a share in it, without obtaining an individual permit, but within a limit of 30 million rubles per company. This rule has been in effect since April 1, 2024. The limit will be lifted on July 1, 2026, after which the restriction on the contribution amount will no longer apply.

In-kind contributions. Contributing non-monetary property — real estate, shares, or rights to intellectual property results — as a contribution is permitted, subject to the restrictions established by Presidential Decree No. 81.

Loans in the currency of controlled foreign companies. A resident may, without a time limit, grant loans in the currency of a controlled foreign company (CFC) disclosed to the Federal Tax Service, for the purpose of maintaining property abroad. The amount of such loans is limited to the volume of financing provided in the previous year.

Ruble-denominated loans. Granting loans in rubles to persons from friendly states is permitted without additional approvals.

Restructuring of previously issued loans. Restructuring loans that were issued to non-residents in foreign currency before March 1, 2022, does not require an individual permit.

Loans to Non-Residents: Summary Table

|Loan Currency |Recipient |Permit Required |
|Rubles |Person from a friendly state |Not required |
|Rubles |Person from an unfriendly state|Permit from the Government Commission required|
|Foreign currency|Any non-resident |Permit from the Government Commission required|

Who Is Not Considered a Person Connected to an Unfriendly State

For purposes of applying these restrictions, the following are not considered persons connected to an unfriendly state:

– a person controlled by a person from a friendly state, provided that such control was established before March 1, 2022;
– a controlled foreign company of a Russian resident, the information on which has been disclosed to the Federal Tax Service.

Real Estate Transactions

Foreign real estate. Transactions involving residents and persons connected to unfriendly states with respect to foreign real estate are permitted without a permit from the Government Commission, provided that settlements under the transaction are made through a foreign account disclosed to the Federal Tax Service.

Real estate located in Russia. A change of owner of real estate in Russia in a transaction between a resident and a person connected to an unfriendly state requires either a permit from the Government Commission or the use of a special type “C” account. There are exceptions to this rule — a permit is not required in the following cases:

– the transaction is carried out with a controlled foreign company, the information on which has been disclosed to the Federal Tax Service;
– the real estate is sold to a non-resident from an unfriendly state;
– the transaction is gratuitous and made in favor of a resident;
– the transaction is between close relatives.

Securities Transactions

Russian securities. Transactions involving Russian securities between a resident and a person connected to an unfriendly state generally require a permit from the Government Commission. A permit is not required in two cases:

– when securities are returned by nominee holders;
– when securities are transferred gratuitously to close relatives or a spouse, including for a nominal price of 1 ruble.

Foreign securities. Trading foreign securities through accounts opened with foreign brokers is permitted without additional approvals.

Transactions Involving Shares in Russian LLCs

A permit from the Government Commission is required to carry out transactions involving shares in Russian limited liability companies in the following cases:

– between a resident and a person connected to an unfriendly state;
– between two persons connected to unfriendly states;
– between a person connected to an unfriendly state and another foreign person.

Liability for Violating Currency Restrictions

Carrying out a transaction in violation of presidential decree requirements entails the following consequences:

– the transaction may be declared invalid by a court;
– funds received under such a transaction are subject to recovery in favor of the state.

List of Unfriendly States and Territories

The states and territories currently classified as unfriendly include: Australia, Austria, Albania, Andorra, Belgium, Bulgaria, the United Kingdom (including its territories — Jersey, Anguilla, the British Virgin Islands, Gibraltar), Hungary, Germany, Greece, Denmark, Ireland, Iceland, Spain, Italy, Canada, Cyprus, Latvia, Lithuania, Liechtenstein, Luxembourg, Malta, Micronesia, Monaco, the Netherlands, New Zealand, Norway, Poland, Portugal, the Republic of Korea, Romania, San Marino, North Macedonia, Singapore, Slovakia, Slovenia, the United States, Taiwan, Ukraine, Finland, France, Croatia, Montenegro, the Czech Republic, Switzerland, Sweden, Estonia, and Japan.

*This material has been prepared based on the requirements of the Federal Law “On Currency Regulation and Currency Control” and presidential decrees governing special economic measures. The information is current as of the publication date; for an assessment of a specific situation, consultation with a lawyer is recommended.*