As of January 1, 2020, Russian currency control law has softened. Russian residents may now receive unlimited proceeds from Russian currency control non-resident banks to individual bank accounts opened outside Russia provided that the respective country (i) is in Eurasian economic union, or (ii) provides for automatic exchange of financial data with the Russian authorities. Note that a complete list of such countries is published by the Federal Tax Service, however, at present the U.S. is not included in that list (Order 29.11.2019 No. №ММВ-7-17/[email protected], in Russian only).

Thus, should points (i) or (ii) be inapplicable, Russian residents must repatriate foreign currency (including the sale proceeds, dividend payments, and other distributions associated with their equity awards) into a foreign currency account authorized by the Russian Central Banking Authority.

Russian residents also are required to report foreign accounts and transactions (including foreign equity award brokerage accounts) occurring on or after January 1, 2020 by June 1 of the year following the relevant year to the Russian tax authorities.

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