Who counts as a non-resident under Russian law
The word "non-resident" in Russian financial practice is used in two different senses — currency and tax. These statuses are established by different laws, assessed against different criteria, and lead to different consequences. Before planning any operation with the ruble, it is important to understand in which of the two senses you are a non-resident, and how that combines with your citizenship and place of residence.
Currency non-resident under 173-FZ
The basic definition is given by Federal Law No. 173-FZ "On Currency Regulation and Currency Control" in Article 1. Currency residents are: Russian citizens; foreign citizens and stateless persons permanently residing in Russia on the basis of a residence permit; Russian legal entities; their foreign branches and representative offices; as well as Russia as a state and its constituent regions. Everyone else is a currency non-resident.
A key feature of this status: a Russian citizen who has moved abroad even for many years does not become a currency non-resident — they remain a currency resident by citizenship. They are subject to the obligations of notifying the FTS about opening foreign accounts, restrictions on settlements with other residents in foreign currency, and the regime of currency-revenue repatriation. For foreign citizens without a residence permit it is different: they are currency non-residents by default and are subject to other regimes — in particular, they receive accounts at Russian banks as "non-resident".
Friendly and unfriendly countries
Since 2022, 173-FZ has been supplemented by a practically important distinction — between residents of "friendly" and "unfriendly" countries. The list of unfriendly countries is approved by Order of the Government of the Russian Federation No. 430-r of 5 March 2022 and is regularly updated. In 2026 the list includes the United States, EU member states, the United Kingdom, Canada, Australia, Japan, Norway, Switzerland, Singapore, Taiwan, Ukraine and a number of others. All other countries are friendly from the standpoint of the Russian jurisdiction.
This distinction critically affects the working regime: for non-residents from friendly countries almost the full set of operations is preserved (opening accounts, transfers, investments, dividends), while for non-residents from unfriendly countries a whole series of restrictions, introduced by presidential decrees, applies: a special payments regime via the type "С" account, the requirement to obtain Government Commission (Правкомиссия) permits for major deals, restrictions on the withdrawal of dividends and coupons.
Tax non-resident — the difference
Tax status is determined differently. Article 207 of the Russian Tax Code classifies as tax residents those individuals actually present in Russia for at least 183 calendar days over 12 consecutive months. Citizenship is irrelevant here: both a Russian and a foreign citizen can become or cease to be a tax resident depending on how many days they spent in the country.
For tax residents the basic NDFL rate is 13% (15% on the excess over 5 million ₽ of annual income). For tax non-residents — 30% on most types of income, but with important exceptions: dividends from Russian companies — 15%, income from the sale of real estate held for more than 5 years — 0%, and since 2024 for remote workers of Russian companies — 13/15% regardless of residency.
Understanding the two statuses is the first step in any planning. Everything substantive that follows — opening an account, choosing a bank, the transfer method, computing tax — depends directly on what kind of person you are in the eyes of the Russian regulator and tax authority.
Opening a ruble account as a non-resident at a Russian bank in 2026
Opening a ruble account in Russia for a non-resident is a technically possible operation, but one that has become noticeably more complicated since 2022. The restrictions concern not the possibility itself (it remains preserved by law) but the willingness of specific banks to work with specific categories of clients and to pass through thickened compliance requirements.
Grounds for opening
The right of a non-resident to open an account at a Russian bank is directly enshrined in Article 12 of 173-FZ and in Bank of Russia Instruction No. 153-I "On the Opening, Maintenance and Closure of Bank Accounts". A bank does not have the right to refuse to open an account for a foreigner solely because they are a foreigner. A refusal is possible on the grounds of 115-FZ — if the bank suspects the laundering of proceeds of crime, or if the client is on sanctions lists, or if the documents do not meet requirements.
In practice this means: formally you have the right, but the specific bank decides whether it is ready to take such a client, based on its compliance policy. After 2022 banks strongly differentiated their policies by the country of residence of the applicant.
Documents and procedure — 5 steps
The algorithm for an individual non-resident is standard, but the details depend on the bank:
- Prepare documents. Foreign passport with notarised translation, visa or migration card (if entry to Russia is required), INN (can be obtained in parallel from the FTS), for legal entities — constitutional documents with apostille and translation, an extract from the trade register of the country of incorporation, a power of attorney for the representative if the opening is not done by the principal.
- Choose a bank. Check against the bank's current policy on non-residents of the chosen citizenship. For friendly countries the list of working banks is wider; for unfriendly ones it is much narrower. It is better to obtain advance confirmation that the bank is willing to work with you — by phone or via an official channel.
- Visit a branch or in-country representative in person. Under 115-FZ in-person identification of the client is required. This can be done in Russia (a visa is needed) or at offices of Russian banks and their representatives in friendly countries — the UAE, Turkey, Armenia, Kazakhstan, Serbia have networks of representatives of major Russian banks.
- Pass 115-FZ identification. The bank will check the source of funds and the economic substance of the opening (KYC questionnaire), cross-check against sanctions lists (SDN, EU, UK), and request confirmation of the legal source of income. Based on the results, it may demand additional documents, and may refuse.
- Sign the contract and receive account details. Once approved — a bank account agreement in Russian (often in parallel in English), an internet banking application, account details in BIK + settlement-account format (the Russian IBAN equivalent), and access to remote banking via mobile app or web interface.
The procedure realistically takes from 3 business days (for simple cases in a friendly country) to 4–6 weeks (for a legal entity from an unfriendly jurisdiction with deepened compliance review).
Remote opening — myth or reality
Fully remote account opening without any in-person identification is impossible. 115-FZ requires the bank to verify the client's identity in person or via its authorised representative. For a foreigner this means either a trip to Russia, or a visit to a Russian bank's representative in the country of residence.
The good news: large banks have built up a network of such representatives in friendly jurisdictions. For a citizen of the UAE, Turkey, Armenia, Kazakhstan or Serbia, opening an account at a Russian bank is often possible without travelling to Russia — you only need to appear at the office of the local representative. For a citizen of the EU or US such an option is almost absent.
Comparison of banks by accessibility for non-residents
Below — generalised practice as of April 2026 across the largest banks. The policy of a specific branch may differ — always verify before visiting.
| Bank | Non-resident individuals | Non-resident legal entities | Friendly countries | Unfriendly countries |
|---|---|---|---|---|
| Sberbank | Yes | Yes, limited | Full service | Under US/EU sanctions, access restricted |
| VTB | Yes | Yes, limited | Full service | Under sanctions, access restricted |
| Alfa-Bank | Yes | Yes | Full service | Under US sanctions, restrictions |
| T-Bank | Yes, for friendly | Limited | Actively opens | Mostly refused |
| Raiffeisenbank | Yes | Yes | Full service | Conditionally works |
| Gazprombank | Yes | Yes | Full service | Not under direct US sanctions, residual accessibility |
| MTS-Bank | Yes, for friendly | Limited | Opens | Predominantly refused |
For up-to-date information on the Russian banking system and regulatory requirements — the official site of the Bank of Russia, section "Information for market participants".
Types of non-resident accounts and what they're for
"Non-resident account" is not one regime but several account types with different rights and restrictions. After opening, the bank determines the account type based on the client category (individual / legal entity), residency, designated purpose and sources of incoming funds. The same person can have several accounts of different types at once.
Current and settlement accounts
The base category: current account for individuals and settlement account for legal entities. These are ordinary operating accounts — funds are credited to them, payments are made from them, debit cards are issued against them. For non-residents these accounts are opened with a "non-resident" marker in the bank's system, which automatically activates additional control under 173-FZ for transactions.
Most simple scenarios — receiving a salary from a Russian employer, paying for Russian real estate, settling Russian services — are covered by an ordinary non-resident current account. No special regime is required for most such operations, and the bank processes them under the standard procedure, only requiring justification of the payment when threshold amounts are exceeded.
Type "С" account
A fundamentally different regime. Introduced by Decree of the President No. 95 of 5 March 2022 "On the Temporary Procedure for Performing Obligations to Certain Foreign Creditors" as a reaction to Western sanctions. Income of non-residents from unfriendly countries on Russian securities and other financial assets — dividends, coupons, redemption payouts, bond income — is credited to the type "С" account.
The "С" account is opened automatically — by the Russian depositary or issuer when a non-resident from an unfriendly country becomes entitled to receive funds. Self-opening is neither required nor envisaged. The non-resident can dispose of funds on the "С" account only in a very narrow set of cases: payment of taxes in Russia, payment for Russian goods and services, charitable contributions. Withdrawal of funds to an unfriendly jurisdiction is blocked.
In 2023–2025 the Ministry of Finance, jointly with the CBR, conducted several rounds of programmes to buy out assets sitting on "С" accounts from non-residents. The exchange envisaged a mirror operation: Russian residents buy back their frozen-in-the-West assets from "С" accounts. The programmes continue, but the details and limits change. A full breakdown of the regime — in the piece More on the type "С" account.
Non-resident brokerage account
A separate type — the non-resident brokerage account, opened with a Russian broker for trading on the Moscow Exchange or SPB Exchange. For non-residents from friendly countries the procedure is close to opening one for residents — passport, INN, questionnaire are needed. For non-residents from unfriendly countries brokerage accounts are now opened with serious restrictions: securities transactions of these persons since 2022 require separate permits, and any income received is automatically routed to a type "С" account.
In practice most non-residents work via brokers in friendly jurisdictions — Russian brokers in Armenia, the UAE, Kazakhstan retain access to the Moscow Exchange without Russian residency of the client and without the "С" regime.
Payments to Russia from abroad: methods and comparison
The main practical question for a non-resident is how to technically send money to Russia. After 2022 the cross-border payments infrastructure was radically rebuilt: SWIFT for most of the largest banks is disconnected, correspondent relations with Western banks are either terminated or frozen, and traditional card payment systems (Visa, Mastercard) inside Russia do not work for foreign-issued cards. New routes have appeared — via friendly banks, SPFS, crypto infrastructure and payment agents. All have their own pros, cons and risks.
SWIFT — what still works in 2026
SWIFT as a protocol is itself available — what is disconnected are individual Russian banks (Sberbank, VTB, VEB, Rosselkhozbank, Otkritie, Promsvyazbank, Sovcombank, Novikombank and others). Banks not hit by sanctions packages continue to use SWIFT for incoming transfers: Gazprombank (with restrictions), Raiffeisenbank, a number of regional banks, subsidiaries of foreign financial groups.
The problem is not in SWIFT itself but in the correspondent chain: Western correspondent banks massively refuse to process payments addressed to Russian counterparties even via working banks. This means SWIFT technically works, but a payment can hang at the correspondent for weeks or be returned without a clear reason. As of April 2026 successful SWIFT transfers from the EU/US to Russia are the exception rather than the rule.
Correspondent relations and SPFS
An alternative to SWIFT is the Russian "System for Transfer of Financial Messages" (SPFS), developed by the CBR. This is the domestic analogue: banks connected to SPFS exchange payment messages directly. By 2026 more than 550 financial organisations are connected to SPFS, including foreign ones — banks of Belarus, Kazakhstan, Armenia, Kyrgyzstan, Uzbekistan, Turkey, the UAE, Iran, China, India, Cuba and a number of others.
In practice this means: if a payment partner in a friendly country has an account at a bank connected to SPFS, the payment to a Russian bank goes outside SWIFT — within the SPFS network. Times — from hours to 1–2 days. Details and the list of participants — on the site of the Bank of Russia Payment System — SPFS.
The second branch is direct correspondent "Loro/Nostro" relations between Russian and foreign banks in friendly countries. This is a working channel for ruble payments: the foreign bank holds a "Loro" account at the Russian bank, the Russian bank — a "Nostro" account at the foreign bank. Payments go as intra-bank transfers, bypassing SWIFT and Western correspondents. A detailed walk-through of the route on the example of Chinese export — Detailed case: paying for exports from China.
P2P and payment intermediaries
P2P transfers (peer-to-peer, between individuals via cards or mobile apps) are the fastest, cheapest and riskiest path. Basic scheme: you hand over currency to a person with a card at a bank in a friendly country, they or their network transfer rubles to the recipient in Russia via SBP or an intra-bank transfer. Times — minutes, fee — 1–3% on top of the market rate.
The risks are significant. Since 2024 the CBR has sharply tightened monitoring of P2P operations under 161-FZ and guidelines on countering fraudulent transfers. Accounts with regular suspicious credits end up on bank-internal blacklists and are blocked under 115-FZ. For one-off small transfers P2P is acceptable; for regular business settlements it is dangerous and unjustified.
Crypto infrastructure (USDT/USDC OTC)
Stablecoins USDT and USDC have become a de facto separate currency system for cross-border settlements with Russia. Basic logic: the sender abroad buys USDT for their currency via an exchange or OTC desk, transfers to the address of an OTC exchanger oriented to the Russian market; the exchanger credits rubles to an account in Russia.
Times — from minutes to an hour, fees — 0.5–2% taking the FX spread into account, limits — practically without ceiling for serious OTC partners. The main risks: legal uncertainty in Russia (the digital financial assets law does not regulate everything), AML checks on the OTC side, tax claims against the recipient if there is no documentary substantiation of the origin of the rubles. For a business with mandatory currency control, a pure crypto scheme is almost never a fit — a documentary-legal "wrapper" via an agent is needed.
Payment agents
Licensed payment agents are the most reliable path for business. The agent accepts currency from the foreign counterparty into its account abroad, converts and credits rubles in Russia to the Russian recipient. Legally these are different transactions — one agreement between payer and agent, another between agent and recipient. The agent takes on the entire block of currency-control work: assembles the document pack under 173-FZ and Instruction 181-I, keeps records by contract, prepares reporting for the bank.
Fee — 1.5–3.5% depending on currency, volume, direction and complexity. Times — usually 1–3 business days. Suitable for regular contracts and large one-off payments. Payment agent NOOR Capital works under this model for contracts from 50,000 USD/EUR/CNY.
Comparison of transfer methods
Summary table — for quickly comparing options across typical scenarios.
| Method | Who uses it | Times | Cost | Risks |
|---|---|---|---|---|
| SWIFT via working Russian banks | Counterparties from countries without a full embargo; large corporate payments | 3–14 days | Fee 0.1–0.3% + spread | High: return at correspondent, freeze, AML demands |
| SPFS | Member banks from friendly jurisdictions | Hours — 1–2 days | Bank fees, usually 0.05–0.2% | Low, if both banks are in the system |
| Bank-to-bank correspondent accounts | Legal entities with regular trade flows Russia ↔ friendly country | 1–3 days | 0.1–0.3% + bank fees | Low, provided correspondent relations are working |
| P2P | Individuals, small amounts, one-off transfers | Minutes | 1–3% on top of market rate | Very high: blocking under 115-FZ, blacklists, reputational losses |
| Cryptocurrency OTC | Tech companies, individuals, freelancers | Minutes — an hour | 0.5–2% taking FX into account | Medium: legal uncertainty, tax claims, AML checks |
| Payment agents | Business: foreign-trade contracts, import, export | 1–3 days | 1.5–3.5% all-in | Low: documents are prepared by the agent, currency control closed |
| Mir card | Individuals in countries that accept Mir (see separate piece) | Instant — a few minutes | Acquirer fee + spread | Medium: limited list of countries and merchant outlets |
The choice of method depends on purpose, volume, regularity and acceptable risk level. For one-off small operations, individuals often choose P2P or crypto infrastructure; for business with mandatory currency control — almost always a payment agent or direct correspondent relations.
Payments from Russia to a non-resident
The mirror scenario — sending rubles or currency from Russia to a non-resident — has its own specifics. Here the matter is not only technical but also about regime restrictions for different categories of recipients: what is permitted, what requires a Government Commission permit, and what is blocked.
Dividends, interest and coupons (type "С" account)
The most specific case is the payout of income on Russian securities to non-residents from unfriendly countries. Under Decree No. 95 such payouts do not go abroad: they are forcibly credited to that same non-resident's type "С" account at the Russian depositary. Neither the issuer nor the broker can transfer the money directly abroad — the regime is automatic.
For non-residents from friendly countries there are no restrictions — dividends and coupons are paid out in the ordinary way to their account in any jurisdiction, provided the transfer channel works. Taxes at payout are withheld by the Russian issuer at the DTT rate, if the treaty is in effect, or at the Russian baseline rate (15% on dividends, 20% on coupons) if the DTT is suspended or absent.
Salaries, fees, services
A Russian company hiring a non-resident (employment contract or civil-law contract) and paying for their work abroad — a standard and permissible operation. Settlements go from the company's settlement account to the contractor's account at a bank in their country. The channels are the same as for inbound payments to Russia, but in the reverse direction: SWIFT via working banks, SPFS, correspondent relations, in rare cases — via subsidiaries of Russian banks abroad.
Tax obligations rest on the employer as a withholding agent. The basic scheme is to withhold NDFL at payment and remit it to the Russian budget. The rate depends on whether the work qualifies as remote (Russian employer — foreign contractor); in that case — 13/15% (see below). For non-employment relations (fees, royalties) with non-residents — 30% by default, or the DTT rate if the treaty is in effect.
SBP and Mir cards for non-residents
SBP — the CBR's System for Fast Payments — has limited availability for non-residents. Basic scenario: to be a participant in SBP as a recipient, you need an account at a Russian bank tied to a Russian phone number. This means a non-resident with an account opened in Russia and a Russian SIM card can receive transfers via SBP from any participant in the system.
The Mir card — Russia's national payment system — is issued to non-residents with Russia-opened accounts on the same terms as to residents. Abroad Mir is accepted at banks and POS terminals in a limited list of countries: Belarus, Armenia, Kazakhstan, Kyrgyzstan, Tajikistan, Uzbekistan, Abkhazia, South Ossetia, Venezuela, Cuba, Iran — with varying degrees of coverage. Turkey in 2022 restricted acceptance of Mir under sanctions pressure, in Serbia — selectively. A detailed acceptance map by country at the current moment — in the piece More on SBP and Mir for non-residents.
This amendment substantially changed the economics of remote work for Russians who moved to friendly countries and continue to work for their home companies. Before 2024 a move for 184+ days automatically meant a switch to the 30% rate; now — not, if the employer is Russian.
Currency control for non-residents: duties and risks
Currency control is a system of checks the bank is required to perform on every operation involving a non-resident or crossing the Russian border with capital. The state's goal is to track the movement of money between residents and non-residents, ensure repatriation of currency revenue, and counter the laundering of criminal proceeds and the financing of terrorism.
What the bank checks under 173-FZ
A Russian bank is a currency-control agent. Under 173-FZ and Bank of Russia Instruction No. 181-I, on every operation with a non-resident the bank checks: presence of a basis (contract, agreement, invoice), correspondence of the payment purpose to that basis, absence of signs of circumvention of currency law, presence of a UNK (Unique Contract Number) for contracts above the thresholds, and standard 115-FZ patterns (source of funds, economic substance).
For payments under contracts thresholds apply: import contracts from 3 million ₽ require registration with the bank (UNK), export contracts — from 10 million ₽. Contracts below the threshold go as "non-contract" with a simplified document set. All contracts are subject to reporting — the parties must submit supporting documents (SPD, completion acts, customs declarations) within the deadlines set by Instruction 181-I.
115-FZ identification
In parallel with currency control there is the "anti-laundering" regime — 115-FZ "On Counteracting the Legalisation (Laundering) of Proceeds of Crime". Under this law the bank is required to identify the client before opening an account (KYC), regularly update questionnaires, monitor "suspicious" operations against a list of indicators approved by the CBR, and report on them to Rosfinmonitoring.
For non-residents 115-FZ is applied with particular attention: a foreigner is treated as "elevated risk" by default, and the bank conducts an extended check of the source of funds, beneficiary (for legal entities) and absence from sanctions lists. Multiple "suspicious" operations by the same client are grounds for unilateral termination of the bank account agreement.
When a payment is blocked
A payment can be suspended at the execution stage on several groups of grounds:
- Documentary: no UNK for a contract above the threshold; payment purpose does not match the contract; no act/invoice/confirmation; insufficient pack for currency control.
- Substantive (115-FZ): suspicion of payment splitting, of pass-through operations, of cash-out schemes; high frequency of operations not matching the nature of the client's business; payment to a counterparty from a "grey" jurisdiction.
- Sanctions: match or close similarity with sanctions lists (SDN, EU, UK, OFAC); payment to a person related to sanctioned activity.
- Technical: errors in details; incorrect currency-operation code; signature mismatches.
On suspension the bank sends the client a request for additional documents. The reply window is usually 5–10 business days. If documents are not provided or do not confirm the economic substance of the operation, the bank refuses to execute the payment. With systematic refusals — termination of the agreement.
Documents for different operation types
Summary table — what the bank expects to see for typical scenarios. A detailed treatment of currency control for the Russian exporter, with checklist and document formats — Currency control for the exporter — in detail.
| Operation type | Documents | Submission deadline | Refusal risk |
|---|---|---|---|
| Payment under a contract up to 600,000 ₽ | Contract, invoice, purpose justification | Before sending the payment | Low if documents are correct |
| Import contract from 3 million ₽ | Contract, deal passport / UNK, invoice, customs declaration (upon import) | Before payment + SPD within 15 days after import | Medium: UNK must be set up in advance |
| Export contract from 10 million ₽ | Contract, UNK, SPD (supporting-documents certificate), customs declaration | UNK before shipment; SPD within 15 days after | Medium: revenue repatriation within the established period |
| Dividends to a non-resident | Payout decision, minutes of the meeting, tax calculation, recipient's residency certificate | Before payout | High for unfriendly countries (type "С" account) |
| Salary to a foreigner abroad | Employment contract, timesheet, payroll slip | Before transfer | Low if regular |
| Loan repayment | Loan agreement, payment schedule, interest calculation | Before transfer | Medium: economic-substance check |
| Buying/selling securities | Broker statement, agreement, tax calculation | Within brokerage servicing | Depends on residency and security type |
The full set of currency-control regulations: 173-FZ "On Currency Regulation", 115-FZ "On Counteracting Money Laundering", Bank of Russia Instruction 181-I. These are three documents thoroughly familiar to every participant in foreign-trade settlements (ВЭД, FTS).
Taxation of non-resident income from Russia
The tax regime for non-residents is a separate, large topic. Here — an overview of the key rates and rules that most non-residents face. For the full breakdown — the piece Detailed guide to taxes and DTTs.
Baseline NDFL rates
For individuals — tax non-residents of Russia — the following main NDFL rates apply under Article 224 of the Tax Code:
- 30% — general rate on most income from sources in Russia (salary, fees, rent — for those not falling under the exceptions).
- 15% — on dividends from Russian companies.
- 13/15% — on income under employment and civil-law contracts of remote workers of Russian organisations (since 2024). This is an exception to the general 30% rate.
- 13/15% — on income from the sale of real estate, if the holding period exceeds the minimum (3 or 5 years depending on the way of acquisition); within this, sale income is effectively not taxed.
- 30% — on income from the sale of other property not falling under the minimum holding period.
- 0% — on a number of social payments, prizes in international competitions and other special categories.
For legal entities — non-residents — the source-withholding tax rate is 20% on most passive income (royalties, interest on loans), 15% on dividends, 10% on freight. The specific rates are reduced by the DTT, provided it is in force and the recipient's tax-residency certificate is presented.
Active vs suspended DTTs in 2026
Russia has historically concluded more than 80 Double Taxation Treaties (DTT, СИДН in Russian). These treaties reduce the source rate on dividends, interest and royalties, usually to 5–10% against the Russian baseline 15–20%. As of April 2026 the overall picture is as follows:
- In force are DTTs with CIS countries (Armenia, Kazakhstan, Belarus, Kyrgyzstan, Uzbekistan, Tajikistan, Turkmenistan, Moldova), China, India, Turkey, the UAE, Serbia, Venezuela, Cuba, Iran, Brazil, South Africa, Argentina, Singapore, Malaysia, Indonesia, Vietnam and a number of other friendly jurisdictions.
- Suspended by Decree of the President No. 585 of 8 August 2023 unilaterally are DTTs with the US, the United Kingdom, Germany, France, Italy, Poland, Latvia, Lithuania, Estonia, Czechia, Sweden, Japan, Canada, New Zealand, Norway and most EU countries — about 38 treaties in total.
- Denounced or in the process of denunciation are the treaties with Latvia (full break), Denmark, Austria.
The current list of active DTTs is maintained by the FTS: Active DTTs — FTS. Before each major operation applying a preferential rate, verify against the current treaty status.
How a non-resident can pay less — legal paths
The basic toolkit:
- Use the active DTT between Russia and the country of tax residency. Condition: timely submission of the residency certificate, apostilled and translated.
- Account for the exceptions to the 30% rate for remote workers (since 2024 — 13/15% regardless of residency).
- Use the holding-period reliefs on real estate and other property for the zero rate.
- Apply deductions if they are admissible for non-residents (most standard social and property deductions are not available to non-residents, but there are exceptions).
- Structure the contract correctly — sometimes switching from an employment contract to a civil-law one or vice versa substantially changes the tax base.
Sanctions restrictions 2026 and unfriendly countries
The 2026 sanctions landscape for a non-resident is not one "list of bans" but a complex multi-layered construct: decrees of the President of Russia, government resolutions, decisions of the Government Commission on the Control of Foreign Investments, plus mirror sanctions of Western jurisdictions (OFAC, EU, UK) that affect operations with Russian persons on the Western bank's side. For a non-resident from an unfriendly country both systems apply at the same time.
Who counts as unfriendly
The list is approved by Order of the Government of the Russian Federation No. 430-r of 5 March 2022 and is periodically updated. As of April 2026 the list contains: the US, Canada, EU member states in full, the United Kingdom, Norway, Switzerland, Liechtenstein, Monaco, San Marino, Andorra, Australia, New Zealand, Japan, Singapore, Taiwan, South Korea, Ukraine, North Macedonia, Albania, Montenegro, Micronesia, the Bahamas.
Affiliation is determined not only by the citizenship of an individual but also by the place of incorporation of a legal entity, the beneficiary, the controlling person. A Russian company with a foreign owner from an unfriendly country can fall under restrictions as a "person of an unfriendly state" by beneficiary.
Decrees of the President and their status
The base acts that form the regime:
- Decree No. 79 of 28.02.2022 — mandatory sale of 80% of currency revenue by exporters (the threshold was lowered, abolished in 2024).
- Decree No. 81 of 01.03.2022 — special procedure for transactions involving persons of unfriendly states; Government Commission permits for transactions with shares, stakes, real estate.
- Decree No. 95 of 05.03.2022 — procedure for payments to unfriendly creditors via the type "С" account.
- Decree No. 254 of 04.05.2022 — special procedure for performing obligations on Eurobonds.
- Decree No. 322 of 27.05.2022 — procedure for payments on corporate Eurobonds of Russian issuers.
- Decree No. 138 of 03.03.2023 — special procedure for accounting for rights to securities where there is a foreign intermediary.
- Decree No. 585 of 08.08.2023 — suspension of DTTs with unfriendly states.
All these decrees are supplemented by government resolutions, decisions of the Government Commission on the Control of Foreign Investments (PKII) and clarifications of the Ministry of Finance and the CBR. The full current regulatory base — on the legal portals consultant.ru and garant.ru.
What this means in practice for a non-resident
A resident of an unfriendly country in 2026 faces the following set of restrictions: inability to withdraw income on Russian securities without a permit (type "С" account); requirement of a Government Commission permit for transactions with stakes in Russian companies above certain thresholds; restrictions on the disposal of real estate in Russia; inability to receive dividends to an account abroad without a special procedure; the need for deeper documentation on any operations involving a Russian bank.
A resident of a friendly country does not face significant restrictions — for them the regime is close to the pre-Covid standard. The main differences are the mandatory in-person identification (not optional, but a requirement), more thorough source-of-funds checks for large amounts, plus difficulties on the side of foreign banks (Western correspondents may refuse to process Russian payments even from citizens of friendly countries on their own compliance grounds).
When you'd better not do it yourself
The financial infrastructure for non-residents in 2026 is a field where a mistake in scheme design can cost months of frozen accounts, loss of funds, or criminal risk. There are scenarios in which an attempt to "save on the agent" statistically leads to losses exceeding the savings. Six such scenarios:
- Transferring more than 1 million ₽ a month via P2P with "acquaintances". Regular large P2P operations are the main indicator for banks' anti-fraud monitoring systems under 161-FZ and CBR guidelines. The recipient's account is blocked under 115-FZ, ends up on the inter-bank "blacklist", and recovery requires substantiating each operation and usually drags out for 3–6 months.
- Using someone else's accounts or front individuals. This is Article 187 of the Criminal Code — "Unlawful turnover of payment instruments", up to 7 years' imprisonment. Liability rests on both the formal account holder and the ultimate beneficiary in whose interests the scheme acted. Any offer to "open an account in the name of our person for 5%" is a direct path to criminal liability.
- Settlements with residents of unfriendly countries without a Government Commission permit when one is required under Decree No. 81 and accompanying acts. Transactions above the threshold without a permit are recognised as void, the bank blocks the operation, and if it is processed — the consequences go up to return of funds and sanctions.
- Opening an account in the name of a nominee to bypass sanctions. A guaranteed block at the first check, plus a high risk of the beneficiary themselves ending up on SDN/EU lists as a "sanctions-evading person". One precedent in OFAC's public reporting creates long-term reputational and operational problems for the beneficiary across all jurisdictions.
- Paying in crypto without KYC and a tax base. Tax claims (NDFL on crypto income — the usual base, the bank will ask to substantiate the origin of incoming rubles) plus AML checks on the exchanger's side. Without a documentary trail of the source of funds — rubles in the recipient's account may be frozen, and the tax authority may assess additional liabilities with penalties and fines.
- Securities transactions of non-residents from unfriendly countries bypassing the type "С" account. Any attempt to "extract" income on Russian securities of a non-resident from an unfriendly country bypassing the "С" account (via a chain of intermediaries, transfer of rights) is a violation of Decree No. 95 and an automatic landing in the focus of Rosfinmonitoring and the CBR. Brokers, depositaries and banks are required to block such operations.
In each of these scenarios there is a legal alternative: a Government Commission permit, an asset buyout programme from "С" accounts, working through a licensed payment agent NOOR Capital, use of active DTTs with friendly countries. All of them require time and documentation, but work in the long run without the risks of freezes and criminal liability.
Frequently asked questions
1. Can a foreigner open a ruble account in Russia in 2026?
Yes. Opening an account as a non-resident — individual or legal entity — at a Russian bank in 2026 is still possible. The restrictions concern not the act of opening itself but the list of banks willing to work with citizens of unfriendly countries, as well as mandatory in-person identification under 115-FZ. Most large banks serve residents of friendly jurisdictions; for unfriendly countries the list of banks is noticeably narrower.
2. What is a type "С" account and do I need to open it myself?
A type "С" account is a special regime introduced by Decree of the President No. 95 of 5 March 2022. It is where income of non-residents from unfriendly countries on Russian securities and other assets is deposited — dividends, coupons, redemption payouts. You don't need to open it yourself: the account is automatically opened by the Russian depositary or issuer when the obligation to credit the funds arises. Withdrawal of funds is possible only via special programmes of the Ministry of Finance or decisions of the Government Commission (Правкомиссия).
3. What's the difference between a currency non-resident and a tax non-resident?
These are two independent statuses. A currency non-resident under 173-FZ is a person without Russian citizenship or without permanent residence in Russia; this status determines what foreign-currency and ruble operations are allowed. A tax non-resident under Article 207 of the Russian Tax Code is an individual who has spent fewer than 183 days in Russia over 12 consecutive months; this status affects the NDFL rate. A Russian citizen can be a currency resident and at the same time a tax non-resident — for example, if they have moved abroad for a long period.
4. Can I open an account remotely without traveling to Russia?
Not fully. Under 115-FZ the bank is required to identify the client in person, or to delegate that function to its authorised representative. Some large banks have offices or representatives in friendly countries (UAE, Turkey, Armenia, Kazakhstan, Serbia), and through them the procedure is possible without a trip to Russia. Any offers to "open an account by correspondence" from intermediaries usually mean using someone else's account or a nominee scheme — this is illegal and leads to funds being blocked.
5. Which bank should a non-resident foreign individual choose?
There is no universal answer — the choice depends on the applicant's country, the purpose of the operations and the bank's willingness to work with unfriendly residents. For citizens of friendly countries the most accessible are Sberbank, VTB, Alfa-Bank, Gazprombank and T-Bank. For citizens of unfriendly countries the list is significantly narrower: typically the banks that have not been hit by direct sanctions work — Gazprombank (within a limited perimeter), Raiffeisenbank, regional banks. Always check the current policy at the specific branch before visiting.
6. Can a foreign company receive rubles for Russian exports?
Yes. A foreign buyer can pay for Russian exports in rubles from its ruble account at a Russian bank or via a "Loro" correspondent account of a foreign bank. Since 2022 a number of export contracts (including raw materials) have been moved to ruble settlements. For a buyer from an unfriendly country — the path is via a special-purpose ruble account with a restricted regime and mandatory currency control.
7. What working methods exist in 2026 to send money to Russia from the EU or US?
As of April 2026 SWIFT works only via Russian banks that have not been disconnected from the system — a limited group of credit institutions. Alternatives: P2P transfers via banks in friendly jurisdictions; cryptocurrency OTC payments with conversion to rubles via Russian exchangers; payment agents that accept currency abroad and credit rubles in Russia; correspondent relations via banks in third countries. All options require documentary substantiation of the source of funds for currency control.
8. What happens if currency control blocks a payment to a non-resident?
The payment is suspended, the bank requests additional documents (contract, invoice, closing acts, confirmation of source of funds). If documents are not provided or do not confirm the economic substance of the operation, the bank refuses to execute it and reports the suspicious operation to Rosfinmonitoring. The money does not "disappear" — it is returned to the sender with a refusal mark. Repeated refusals for the same client lead to account closure.
9. What's the NDFL rate for a non-resident freelancer working for a Russian company?
Since 2024, for remote workers who are tax non-residents performing work for a Russian company from abroad, the NDFL rate is 13% (15% on the excess over 5 million ₽ per year) — regardless of tax residency. This is the rule of Article 224 of the Tax Code as amended on 31 July 2023. Previously, for non-residents this rate was 30%. The rule does not extend to income from non-employment relations (dividends, rent); other rules apply to those.
10. Are DTTs with EU countries still in effect in 2026?
Most are not. The treaties with the US, Germany, the United Kingdom, France, Italy, Latvia and a number of other unfriendly countries have been suspended unilaterally by Decree of the President No. 585 of 8 August 2023. This means the preferential rates provided for by the DTT effectively do not apply, and taxation reverts to the Russian baseline rates. The current list of active DTTs is best checked on the FTS website before each operation.
11. Is it safe to use P2P transfers for large amounts?
For regular or large payments (from 1 million ₽ per month) P2P is dangerous. Since 2024 banks have been actively applying 161-FZ and CBR guidelines on countering fraudulent transfers: accounts with suspicious activity are blocked and the client ends up in the 115-FZ database. For one-off small operations P2P is acceptable, but it requires a clear source of funds and should not be repeated monthly under the same scheme.
12. When should you go to a payment agent rather than trying it yourself?
If the operation exceeds 1 million ₽, requires a closing-document pack for Russian currency control, is tied to an export-import contract or implies regular tranches, it makes sense to work via a licensed payment agent. The agent accepts the money abroad and credits rubles to the supplier in Russia, putting together the document pack under 173-FZ and 181-I. DIY schemes with P2P or front accounts in such scenarios lead to blocking and legal risks.