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 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).
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 2023 the fine is 20–40% of the transaction amount (previously it reached 100%), 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. In 2020 a key relief for those who had left appeared—an exemption from notifications and ODDS for anyone spending more than 183 days outside Russia in a year. 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. The tax authority increasingly treats crypto wallets and accounts with foreign payment services as equivalent to foreign accounts, so those are worth factoring into this calculation too.
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.
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.