Concept
Russian currency residency is constantly confused with tax residency—yet these are two different regimes with different logic. Tax residency is determined by days and decides at what rate you pay personal income tax. Currency residency is determined by citizenship and decides whether you are obliged to report your foreign accounts to the tax authority. Leaving the country and ceasing to be a tax resident is easy; ceasing to be a currency resident is almost impossible.
Who Is Recognized as a Currency Resident
All Russian citizens without exception are recognized as currency residents, as well as foreigners with permanent residence permits. Unlike tax status, currency status does not depend on the number of days in the country: a citizen remains a currency resident even after living abroad for years. This is precisely why obligations regarding foreign accounts persist even for those who left long ago.
Notification of Account Opening
A resident must notify the tax authority of the opening, closing, or change of details of a foreign account within one month using the prescribed form. The requirement applies not only to banks but also to other financial market organizations—brokers, certain payment and investment services. This is a one-time action for each account event, separate from annual reporting.
ODDS—Annual Report
The Report on Movement of Funds and Other Financial Assets (ODDS) is filed annually no later than June 1 of the year following the reporting year: for 2025—no later than June 1, 2026. There are two exemptions. First: residents who spent more than 183 days outside the Russian Federation in a calendar year do not file ODDS (Part 8 of Article 12 of Law 173-FZ). Second: the account is opened in an EAEU country (Belarus, Kazakhstan, Armenia, Kyrgyzstan) or in a state that carries out automatic exchange of financial information with the Russian Federation, and either the total of credits and debits on the account for the reporting year does not exceed 600,000 rubles, or the year-end balance does not exceed 600,000 rubles—with the second option available only if nothing at all was credited to the account during the year (Part 7 of Article 12 of Law 173-FZ). The limit is calculated for each account separately, and foreign currency is converted at the Central Bank rate as of December 31 of the reporting year.
Penalties
Under Article 15.25 of the Administrative Code, late or improperly formatted notification of an account costs a citizen 1,000–1,500 rubles, and complete failure to submit—4,000–5,000 rubles. Late filing of ODDS is penalized on a sliding scale: a warning or 300–500 rubles for delays up to 10 days, 1,000–1,500 rubles for 11–30 days, and 2,500–3,000 rubles for delays exceeding 30 days. Illegal currency transactions through such an account are punished far more severely: since 24 July 2022 the fine is 20–40% of the transaction amount (previously it reached 100%; the reduction was introduced by Law No. 235-FZ of 13 July 2022), and even the reduced rate makes a prohibited credit noticeably more expensive than any late report.
How the Rules Evolved
The regime took shape in stages. For a long time, reporting on foreign accounts was required of all citizens without relief, and the tax authority obtained information mainly on request. The turning point came when Russia joined automatic exchange under the CRS standard in 2018: the tax authority began receiving account data directly from dozens of jurisdictions. The key relief for those who had left—an exemption from notifications and ODDS for anyone spending more than 183 days outside Russia in a year—appeared earlier, with the late-2010s reform of currency residency; the 2020 redraft (Law 499-FZ) merely reworded it. What 2020 itself brought was a different relief: the 600,000-ruble limit for accounts in EAEU and automatic-exchange countries. After 2022 the picture shifted again: some Western countries wound down exchange with Russia, while the tax authority began redrawing the automatic-exchange list every year, adding friendly jurisdictions and dropping offshores. As a result, the scope of obligations today depends heavily on exactly where the account is held.
What You Can Credit to a Foreign Account
Notification and ODDS are only part of the regime. Law 173-FZ separately restricts which funds a resident may credit to a foreign account. For accounts in EAEU countries and in automatic-exchange states, the list of permitted credits is broad: salary, rental income, proceeds from the sale of securities, interest, and dividends all qualify without reservation. For accounts in other countries the list of permitted credits is narrower, and every inflow should be checked against the law—a credit outside the permitted categories counts as an illegal currency transaction with a fine set as a percentage of the amount. On top of this, since 2022 restrictions from the presidential "currency" decrees apply to transfers abroad and transactions with residents of unfriendly countries; the relevant limits are periodically revised by the government commission.
How It Works in Practice
Three typical situations show how the regime works. A person who has relocated, holding a card and brokerage account in Kazakhstan (an EAEU country), notifies the tax authority of the opening within a month but is exempt from ODDS as long as turnover and balance stay within 600,000 rubles. The holder of an account with a European broker in a country that has suspended exchange files the notification on general terms but can no longer count on the "limit-based" exemption for such an account. Finally, someone who has spent more than 183 days abroad in a year is exempt from both notifications and ODDS for that year—but the moment they return and spend most of the following year in Russia, the obligations revive in full. A separate duty covers transfers made through electronic means of payment provided by foreign payment service providers: it sits in the same Part 7 of Article 12 of Law 173-FZ, and its exemption threshold is likewise 600,000 rubles credited over the year. Crypto wallets as such are not among the objects of reporting under Article 12.
What's Important to Remember
The currency and tax aspects of relocation operate under different rules, and both need to be addressed. In the CRS era, one should assume that the tax authority most likely already has data about the account, so it's cheaper to maintain notifications and ODDS transparently than to explain after the fact. Each year it makes sense to recalculate days abroad and check the list of automatic exchange countries—this determines whether a report is needed at all.
Q/A
I have lived abroad for four years — have I stopped being a Russian currency resident?
No: currency residency is tied to citizenship and does not lapse with time spent away. The relief comes from a different provision — Part 8 of Article 12 of Law 173-FZ: for a calendar year in which you spent more than 183 days outside Russia, neither notifications nor ODDS are filed. Return and spend most of the following year in Russia and the obligations revive in full.
The account is with a foreign broker, not a bank. Does it still have to be notified?
Yes. The requirement covers not only banks but other financial market organizations — brokers, certain payment and investment services; the deadline is the same, one month from the opening, closing or change of details. Crypto wallets as such, by contrast, are not among the objects of reporting under Article 12.
The Swiss account holds less than 600,000 rubles — can ODDS be skipped?
No. The 600,000-ruble limit works only for accounts in EAEU countries and in states on the tax authority's automatic-exchange list, and Switzerland was struck off it by Order No. ED-7-17/986@ of 28 October 2022; Order No. ED-7-17/916@ of 30 October 2024 removed the 26 EU member states as well. For accounts in those countries ODDS is filed regardless of the amount.
Year-end balance 400,000 rubles, but there were credits. Does the limit save me?
No. Part 7 of Article 12 offers two routes and this fails both: the year-end balance counts only where nothing at all was credited to the account during the reporting year, while the other route adds credits and debits together. The limit is calculated for each account separately, and foreign currency is converted at the Central Bank rate as of 31 December.
I filed ODDS two months late. How expensive is that?
Cheap by the standards of this regime: under Article 15.25 of the Administrative Code a delay of more than 30 days costs a citizen 2,500–3,000 rubles, up to 10 days a warning or 300–500, and 11–30 days 1,000–1,500. A prohibited credit to the same account is incomparably dearer: since 24 July 2022 the fine is 20–40% of the transaction amount.