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 status 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.
Currency Resident—It's About Status, Not Days
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.
⚙️ Tax residency is about the personal income tax rate and is calculated by days. Currency residency is about account reporting and is tied to citizenship. You can be a tax non-resident and simultaneously a currency resident—this is a typical situation for someone who has left.
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 by June 1 of the year following the reporting year: for 2025—by 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 the annual turnover or balance as of December 31 on the account does not exceed 600,000 rubles (the limit is calculated for each account separately).
💡 Important caveat: after 2022, the list of countries actually exchanging data with Russia has shrunk, so the second exemption should be checked against the current list of automatic exchange for the current year. Exemption from ODDS based on the 183-day period does not automatically cancel the obligation to notify about account opening—the scope of obligations is best verified for your specific situation.
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 about 300 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 separately and much more severely—there the fine is calculated as a percentage of the transaction amount.
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.
💡 You can leave Russian taxes, but you cannot leave currency control. A citizen remains a currency resident; the only question is whether they are exempt from ODDS based on the 183-day period and whether the account falls under the automatic exchange limit.
This material is for informational purposes, reflects the provisions of Law 173-FZ and the Administrative Code as of the date of preparation, and is an expert overview, not individual advice. Lists of automatic exchange countries and the exact scope of obligations should be verified for your specific situation.
Key factual claims
- The Report on Movement of Funds and Other Financial Assets (ODDS) is filed annually by June 1 of the year following the reporting year: for 2025—by June 1, 2026.
- 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.
- Related links: Loss of Russian Tax Residency · Tax Residency: 183 Days · CFC (Controlled Foreign Companies) · CRS and FATCA · Unfriendly Countries for Russia · FTS: Account Notification
- This material is for informational purposes, reflects the provisions of Law 173-FZ and the Administrative Code as of the date of preparation, and is an expert overview, not individual advice.