What Currency control covers
Currency control is procedural, and that is exactly why it catches people: the penalties come from missed notifications and incomplete paperwork, not from getting a figure wrong. It also runs on its own definition of "resident" that has nothing to do with tax residency — a distinction that surprises foreign nationals constantly. We build it into your contracting and payments so the bank stops blocking transfers and the deadlines stop slipping.
Currency control governs how money crosses the Russian border, and it catches foreign-owned companies and individuals constantly — because the penalties come not from paying the wrong amount but from procedure: a missed notification, a supporting document the bank never received, a foreign account nobody reported. Get the paperwork right and it is invisible. Get it wrong and the bank blocks the payment or a percentage-of-transaction fine arrives.
This is the distinction that trips up foreign nationals most often. Currency-resident status under 173-FZ is based on citizenship and residence-permit status, not days in Russia. A foreign executive on an HQS permit can pay NDFL as a tax resident for years and still not be a currency resident at all — which means no obligation to report their home-country accounts. The two statuses are assessed separately, and conflating them creates obligations that do not exist or misses ones that do.
We assess your status correctly first, then build currency control into contracting and payments rather than treating it as an afterthought: contracts registered where required, supporting documents ready before the bank asks, notifications and reports filed on their deadlines. Where there is historic non-compliance, we handle disclosure — the two-year limitation period means old breaches can still be pursued.
What we handle
Contract registration
Cross-border contracts registered with the servicing bank and the supporting-document pack built so payments clear instead of stalling in currency-control review.
Details +
Contract registration
Cross-border contracts registered with the servicing bank and the supporting-document pack built so payments clear instead of stalling in currency-control review.
Account notifications
FTS notification of foreign bank, brokerage and e-wallet accounts within the deadline — after the currency-resident status that decides whether you even have to is established.
Details +
Account notifications
FTS notification of foreign bank, brokerage and e-wallet accounts within the deadline — after the currency-resident status that decides whether you even have to is established.
Annual cash-flow report
The annual ODDSFA report on foreign accounts prepared and filed — including the 183-days-abroad exemption check that can remove the obligation entirely for a given year.
Details +
Annual cash-flow report
The annual ODDSFA report on foreign accounts prepared and filed — including the 183-days-abroad exemption check that can remove the obligation entirely for a given year.
Disclosure & penalties
Voluntary disclosure and penalty mitigation for past non-compliance — argued within the two-year limitation window rather than left to accumulate per account and year.
Details +
Disclosure & penalties
Voluntary disclosure and penalty mitigation for past non-compliance — argued within the two-year limitation window rather than left to accumulate per account and year.
What’s included
When clients come to us
“Your bank has blocked a cross-border payment and is asking for documents you do not have.”
“You hold foreign accounts and are not sure whether you are even a currency resident.”
“You have missed a foreign-account notification and want to disclose before it is found.”
“You spend much of the year abroad and want to know if the annual report still applies to you.”
Foreign executive — reporting obligations that did not exist
The client, an HQS-permit holder resident in Russia for four years, had been told by a home-country adviser to report their foreign accounts to the FTS and was worried about years of missed filings. We established that, without a permanent residence permit, they were not a currency resident under 173-FZ at all — the tax residency they had been paying under was a different test entirely. There were no missed obligations, because there were no obligations. The engagement was short and the relief was real.
How the work runs
Assess
Currency-resident status established — the citizenship-and-permit test, not the tax-residency one.
Register
Contracts registered and payment documentation built so transfers clear.
Notify
Foreign accounts notified and the annual report filed, or the exemption claimed.
Remediate
Historic breaches disclosed within the limitation window, penalties mitigated.
Currency Control Pack
Questions about Currency control
Am I a currency resident if I'm a tax resident?+
Not necessarily — they are separate tests. Currency-resident status under 173-FZ depends on citizenship and residence-permit status, not days in Russia. A foreign national on an HQS permit can be a tax resident for years without being a currency resident, meaning no obligation to report home-country accounts. The two must be assessed independently.
Why did the bank block our cross-border payment?+
Banks act as currency-control agents and must check the supporting documents behind each cross-border payment. Incomplete or missing paperwork, or an unregistered contract where registration was required, is the usual cause. Building the document pack correctly at contracting stage prevents it.
What are the penalties for currency-control breaches?+
They can be significant — in some cases a percentage of the transaction amount for companies. For individuals they are more modest but apply per violation and accumulate across accounts and years. Most arise from missed notifications or documentation rather than the underlying transaction, and the limitation period is two years.
Do I have to file the annual foreign-account report?+
If you are a currency resident with foreign accounts, yes — the ODDSFA report is due by 1 June for the previous year. But an individual who spent more than 183 days outside Russia during that year is exempt for that year under Article 12, which is why the day count is worth tracking.
Do the rules change often?+
Yes — the regime has changed repeatedly in recent years, so we monitor it and keep your position current.
Can I receive my salary from a foreign employer into a foreign account?+
Yes — salary from a foreign employer into a foreign bank account in an FATF/OECD member state is a permitted credit since 2022. However, salary from foreign employers into accounts in non-FATF countries may not be permitted. The permitted credit rules are complex and have changed multiple times — we verify the current position before you set up any foreign payroll arrangement.
I have a foreign brokerage account with securities. What do I need to report?+
The brokerage account itself must be notified. The annual movement report must show all credits (purchases proceeds received, dividends, coupons) and debits (securities purchases, withdrawals). Foreign securities income is also subject to Russian PIT reporting — the two compliance streams are separate but linked. We handle both.