Russian Currency Control in 2026: What It Means for Business in Armenia

Russian currency control is set out in Law 173-FZ “On Currency Regulation and Currency Control”. It imposes main obligations on Russian residents: they must register contracts with the bank, keep documents, and report on foreign accounts. An Armenian company as a taxpayer is not registered under Russian law. But the law applies if your counterparty or you (owner, sole proprietor/citizen of Russia) are Russian residents. The Russian data below comes from the Russian Federal Tax Service page on currency control, updated 12.11.2026, Armenian data from Republic of Armenia law.

Who the Law Applies To

The law distinguishes between residents and non-residents (Art. 1, Part 1, Clauses 6 and 7). According to the version published on the Federal Tax Service website (as amended to 02.07.2021), residents are:

• Russian citizens, including those living abroad;
• Foreigners and stateless persons with a Russian residence permit;
• Legal entities established under Russian law and their foreign branches.

Non-residents include, among others, legal entities established under the laws of foreign countries and located outside Russia. Therefore, under Russian rules, an Armenian company is a non-resident. A Russian citizen residing in Armenia remains a resident, even when registered as a sole proprietor in Armenia: a sole proprietorship is considered an individual. This is the 2021 version: check with a Russian law expert for the current text and any possible exceptions. The Federal Tax Service audits both residents and non-residents, and liability under the Russian Code of Administrative Offenses applies to both.

For Armenian businesses, it's important to understand what the Russian side is obligated to do. This determines what documents they may request from you.

Obligations of a Russian Resident

Recent Changes to Repatriation

The FTS mentions the following exemptions:

• The repatriation requirement for import and export contracts for services from non-residents is suspended (Law of 28.06.2021 No. 223-FZ, Presidential Decree of 08.08.2022 No. 529).
• Since January 1, 2020, the requirement has been canceled for non-goods export contracts where the value and payment are in rubles.
• Since July 1, 2021, the requirement has been canceled for export contracts in foreign currency, except for supplies of raw materials.

The FTS gives a separate warning (and the Bank of Russia explains even broader non-application of repatriation): currency law acts are currently applied with regard to the exemptions and restrictions established by the President, Government, and Bank of Russia. Liability for violation of repatriation does not apply if the resident fulfills it within 45 days of the contractual deadline. For exports, there is no liability if the value under contract is not more than 200,000 rubles.

What This Means for You

A typical case: a Russian company pays an Armenian sole proprietor or LLC under a contract. If the recipient is a Russian non-resident, the Russian bank treats the payment as a currency transaction between a resident and a non-resident. The general rule of Art. 6, Law 173-FZ: such transactions are generally permitted, but some restrictions apply (namely Art. 11 and temporary acts of the President and the Bank of Russia). If the sole proprietor is a Russian citizen, they are a resident themselves. Both the bank and the counterparty usually require documents. Prepare the following:

1. The contract with details of both parties, subject matter, value, currency, and deadlines.
2. Invoice and act or bill of lading for each payment.
3. Current bank details to which payment is made.
4. Answers to bank queries regarding the purpose of payment.

Settlement in rubles does not remove the transaction from currency control: Part 1 Art. 19 covers both foreign currency and Russian rubles. Specific exemptions for ruble contracts are listed above.

Example

A Russian LLC purchases a batch of goods from an Armenian sole proprietor, who is not a Russian resident, for 12 million rubles. For the Russian party, this is an import contract. As the value exceeds the 3 million ruble threshold, the LLC must register the contract with an authorized bank and submit all documents in accordance with Instruction No. 181-I. Typically, your bank will request the contract, invoice, and shipping documents. If the contract amount is below the threshold, registration is not required, but the payment is still processed by the bank as a foreign exchange transaction.

Questions you should ask your Russian counterparty before signing the contract:

• Which bank will process the payment and what documents does it require?
• Does the contract specify when and how you provide invoices and acts?
• Are they paying from their account in a Russian bank or via a foreign account?

Russian Citizens' Accounts in Armenia

Since January 1, 2020, Russian resident individuals can, without restrictions, credit their foreign accounts with funds from non-residents, if the account is opened in a bank of a EEU member or a country that exchanges financial information with Russia. The EEU list from FTS explicitly names Armenia. Movement reports are not required for individuals if the bank is in an EEU country or a country with automatic information exchange, and provided:

• Annual credits and debits do not exceed 600,000 rubles, or
• The year-end balance does not exceed 600,000 rubles if there were no credits in the year.

Russian organizations and sole proprietors provide reports quarterly. A separate report is needed for transfers using payment instruments of foreign providers if total credits from the beginning of the year exceed 600,000 rubles. Such operations are not allowed for foreign trade or loans.

What Armenian Law Says

Armenian law does not require the repatriation of revenues to Armenia and does not restrict current foreign exchange operations (Art. 4 Part 1 of the Law “On Currency Regulation and Currency Control”). Payments for goods and services between Armenian residents are made in drams (Art. 6 Part 2). In written contracts with non-residents, legal entities, or sole proprietors, for non-cash payments, prices can be specified in foreign currency (Art. 6 Part 7). Residents can open accounts in foreign banks (according to the Central Bank of Armenia). Armenian banks serve as foreign exchange control agents and check transactions for compliance with the law (Art. 9).

Liability

Violations of Russian currency legislation are punishable under Art. 15.25 of the Russian Code of Administrative Offenses. The Federal Tax Service lists these sections:

• Part 1: illegal currency transactions;
• Parts 2 and 2.1: violation of procedures and deadlines for account notification, failure to report accounts;
• Parts 4, 4.2, 4.3, and 5: violation of repatriation requirements (4.3 also covers failure to fulfill obligations by permitted means when repatriation is canceled);
• Parts 6.1-6.3: late submission of reports, with different consequences for delays up to 10 days, over 10 but not more than 30 days, and over 30 days;
• Part 6.3-1: failure to submit documents to the bank within 90 days after the deadline.

For violations on a large scale, over 100 million rubles, separate liability applies. Cases under Parts 5.1 and 5.2 (for officials) are heard by a judge. Other measures under Art. 15.25 are applied only by currency control authorities.

What Armenian Businesses Should Do

• Check with your Russian counterparty: are they a resident, what contracts do they have, and which bank handles the transaction.
• Russian residents are prohibited from making foreign trade payments via electronic payment services of foreign providers. Do not agree to such payments.
• Keep the contract, invoice, and act as a full package: the Russian bank may request them when reviewing payments. This is a recommendation, not a universal legal requirement.
• If you (for example, a Russian citizen with an Armenian sole proprietorship) or your partner are Russian residents, discuss reporting issues with an expert before opening an account in Armenia.

How to receive payments from abroad into Armenia is covered in Receiving Payments from Abroad. For transfers from Russia, see Transfers from Russia.