Special regulation: Transactions with foreigners. Update 2024
Traditional update of our special regulation memo.
Over the past four months, the key positions have not changed, but the Central Bank of the Russian Federation provided an important clarification in a recent letter in response to our request regarding who should be considered "unfriendly" persons.
- Two citizenships: "unfriendly" + "friendly"
If an individual holds a passport from a "friendly" country but is also a citizen of an "unfriendly" country, they are still recognized as "unfriendly."
- Two citizenships: "unfriendly" + Russian
We would like to remind you that a different approach applies to citizens of the Russian Federation and those with a Russian residence permit: in letters related to Presidential Decrees No. 79, 81, 95, and others, the Bank of Russia clarified that they are residents of the Russian Federation and do not fall under the category of "unfriendly" persons.
In other words, having a passport from a "friendly" country does not help avoid restrictions, unlike a Russian passport or residence permit.
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