Dmitrii Sheinkman Author Dmitrii Sheinkman Residence permit expert, tax adviser 15 min read Message the author

How to open a foreign bank account or brokerage account abroad as a Russian citizen in 2026

A Russian citizen can open a foreign bank or brokerage account: Russian law allows it, and neither the EU nor Switzerland bans accounts for Russians. Without EU, EEA or Swiss citizenship or residence, limits apply: deposits capped at €100,000 per bank, no new cards, no purchases of securities issued after 12 April 2022. A Spanish residence permit lifts them.

This article covers accounts outside Spain: in Switzerland, other EU countries, the UAE, Singapore, Kazakhstan and Armenia, plus a brokerage account for a securities portfolio. Opening an account with a Spanish bank is explained in our guide on how to open a bank account in Spain, and the limits on transfers out of Russia and the checks on sending banks in our guide on how to transfer money from Russia to Spain. Here: what a Russian citizen is allowed to do in 2026, what a residence permit changes, how a bank vets a client, and which obligations arise towards Russia and towards Spain.

What EU sanctions prohibit for a Russian citizen

The restrictions on private individuals are set out in Council Regulation (EU) 833/2014. We checked them against the consolidated version of 24 July 2026, the latest one published on EUR-Lex on the date of our check, 24 October 2026. The regulation contains no ban on opening an account as such. It contains five restrictions that apply to a Russian national or a person residing in Russia:

  • Deposits. A bank may not accept new money if the client’s total deposits with that bank exceed €100,000 (Article 5b(1)).
  • Cards and e-money. Since the 19th sanctions package (Regulation 2025/2033 of 23 October 2025), it is prohibited to issue payment instruments, provide acquiring and payment initiation services, issue electronic money and provide crypto-asset services (Article 5b(2)).
  • Depositories. EU central securities depositories do not service securities issued after 12 April 2022 for Russian nationals (Article 5e).
  • Sale of securities. A Russian national cannot be sold securities denominated in an EU currency and issued after 12 April 2022, or in any other currency and issued after 6 August 2023, nor units in funds invested in such securities (Article 5f).
  • Trusts. A trust cannot be registered or managed if its settlor or beneficiary is a Russian national or a resident of Russia (Article 5m).

In addition, once every 12 months the bank reports deposits of Russian nationals above €100,000 to the authorities (Article 5g). This is the bank’s obligation, not the client’s.

Who the restrictions do not apply to

Article 5b(3), Article 5e(2) and Article 5f(2) make one exception: nationals of the EU, EEA and Switzerland, and people holding a temporary or permanent residence permit in those countries. A Spanish residence permit of any type qualifies, whether by investment, non-lucrative, digital nomad or employment. This is confirmed by the European Commission’s official FAQ on deposits:

  • dual citizenship helps only if the second country is an EU or EEA member or Switzerland; an Israeli, Turkish or Kazakh passport alongside the Russian one does not lift the limit (question 30);
  • a Russian living in a third country without an EU residence permit, for example in the UAE, is covered by the restriction (question 10);
  • what counts as a residence permit is decided by each country itself (question 29).

In its FAQ on payment services of 13 March 2026, the Commission added two important details. A holder of a long-stay type D visa who has completed local residence registration is typically considered legally resident and is also covered by the exception. And a bank issues a card under the exception only if the residence permit is valid for the card’s entire validity: with a three-year card and a one-year permit, the bank may refuse.

How the €100,000 limit is calculated

The limit is the sum of all the client’s deposits with one bank: current, savings and term accounts, in any currency (questions 11 and 22). It is counted per banking licence, not per country (question 31). Securities in a brokerage account are not deposits (question 18), but uninvested cash held with a broker that is a bank does count. If the limit has already been exceeded, the bank does not credit even interest and dividends (question 26).

A joint account of spouses who are both Russian nationals is split between the two, so up to €200,000 can be held on it in one bank (question 32). If one of the co-holders falls under the exception, the ban does not apply to the account, but a joint account cannot be used to get around the rules (question 23). Money that was in the account before the ban took effect stays with the owner, but the account cannot be topped up beyond the limit.

Old cards issued before the 19th package keep working, but reissuing and replacing them is already prohibited (question 7 of the payment services FAQ). Online banking, transfers from the account and cash withdrawals are not affected by the ban (questions 9 and 10). A bank is not required to close accounts, but it stops the prohibited services immediately once a client falls under the restriction, for example when a Russian’s EU residence permit expires (question 5).

A foreign account for a Russian citizen: decision pathCitizenship or residence permitin the EU, EEA or Switzerland?yesnoNo sanctions limitsArt. 5b, 5e, 5f do not applyclient checks remain,as does source of fundsEU bank: €100,000 per bankno new cardsno securities issued after 12.04.2022Switzerland: same, CHF 100,000Obligations once the account is openTowards Russiaover 183 days abroad in the year:no FNS notification, no reportotherwise: notify in 1 month, report by 1 JuneTowards Spain (as a resident)savings income tax: 19–30%Modelo 720: a block over €50,000wealth taxReg. (EU) 833/2014 (24.07.2026), SR 946.231.176.72, Law 173-FZ art. 12, RD 1065/2007.
Diagram based on Articles 5b, 5e and 5f of EU Regulation 833/2014, Articles 20–23 of the Swiss Ordinance SR 946.231.176.72, Article 12 of Russian Law 173-FZ and the Modelo 720 rules.

A Swiss bank account for a Russian citizen

Switzerland is not in the EU but has introduced its own measures: the Ordinance on measures in connection with the situation in Ukraine (SR 946.231.176.72), as in force on 21 September 2026. The rules are almost the same as the EU ones:

  • a bank does not accept deposits from a Russian national if their total with that bank exceeds CHF 100,000 (Article 20(1));
  • since 26 February 2026, it has been prohibited to issue payment instruments and electronic money to Russians and to provide them with crypto services (Article 20(2));
  • securities issued after 12 April 2022 and units in funds invested in them cannot be sold (Article 23), and depositories do not service such securities (Article 22);
  • trusts cannot be set up or managed if the settlor or beneficiary is a Russian national (Article 28d).

The exception is broader than in the EU: the restrictions do not apply to nationals of Switzerland, the EEA and the United Kingdom, or to people with a residence permit in Switzerland, an EEA country or the United Kingdom (Article 20(3)). A Spanish residence permit qualifies. Everything else, from the minimum balance to the onboarding time and the service fee, is up to the bank. We found no official published terms for Russian citizens at Swiss banks: banks disclose these terms on request.

The UAE, Singapore, Kazakhstan and Armenia

Outside the EU and Switzerland, Regulation 833/2014 does not apply. Singapore has introduced measures which, according to a statement by Singapore’s Ministry of Foreign Affairs, target designated Russian banks, entities and activities rather than private clients. In the official sources of the UAE, Kazakhstan and Armenia we found no national restrictions on accounts of private individuals who are Russian citizens similar to Article 5b (checked on 24 October 2026).

The absence of a law does not mean an account will be opened. Banks in these countries decide for themselves whether to accept a client and take into account the risk of US secondary sanctions: US Executive Order 14114 of 22 December 2023 allows sanctions against foreign banks that conduct transactions involving Russia’s military-industrial base. That is why the strictness of checks there depends on the bank, not on the country’s law.

A foreign account for a Russian citizen: what applies in 2026 (checked 24.10.2026)
Where Restriction for a Russian without EU/EEA/Swiss residence What lifts the restriction Minimum and onboarding time
EU countries, including Spain Deposits up to €100,000 per bank; no new cards or e-money; no sale of securities issued after 12.04.2022 EU, EEA or Swiss citizenship or residence permit On request from the bank
Switzerland Deposits up to CHF 100,000 per bank; no new cards since 26.02.2026; no sale of securities issued after 12.04.2022 Swiss, EEA or UK citizenship or residence permit On request from the bank
Singapore Measures against designated Russian banks and entities, not against private individuals — On request from the bank
UAE, Kazakhstan, Armenia No national restrictions on private individuals found in official sources; the decision rests with the bank — On request from the bank

How a bank vets a client

Sanctions are only the first filter. After that, any bank in the EU, Switzerland or the UAE takes the client through the same know-your-customer (KYC) procedure. For a Russian citizen with capital it usually covers four areas.

  1. Identity and status. Passport, residence permit, address. For an EU bank the residence permit settles the main question: whether the client falls under Article 5b.
  2. Tax residence. The client signs a self-certification stating the country of tax residence and gives a tax identification number. Automatic exchange of information rests on this form: in Spain, the duty of banks to establish the tax residence of account holders and report on them is set by Royal Decree 1021/2015 under the CRS standard and EU Directive 2011/16. How residence is determined is explained in our guide to Spanish tax residence.
  3. Source of funds. Where exactly this money comes from: the sale of a flat, dividends, the sale of a business, an inheritance. Contracts, statements and tax returns are needed.
  4. Source of wealth. How the fortune was built overall: a career, a business, investments over the years. For a client with a portfolio of €1 million or more, a bank usually asks for a timeline backed by documents.

Money arriving in the account beyond what was declared is checked again. So the order is: first gather documents on the origin of all the capital, then choose the bank. No lawful route involves accounts in someone else’s name, “transit” companies or splitting amounts: Regulation 833/2014 expressly prohibits taking part in activities whose object is to circumvent the restrictions (Article 12).

A brokerage account abroad

A brokerage account raises two questions at once: where the securities are held and what can be bought on it. For a Russian without an EU residence permit, the main restriction is not opening the account but Articles 5e and 5f: an EU broker cannot sell them bonds and shares issued after 12 April 2022, nor units in funds invested in such securities. In practice this closes off most new bonds and funds. Uninvested cash held with a broker that has a banking licence also counts towards the deposit limit.

With a Spanish residence permit these restrictions do not apply: an EU resident buys the same securities and funds as the broker’s other clients. In exchange, the tax side appears. The broker reports the account to the client’s country of tax residence under the CRS, and a Spanish tax resident declares income and assets themselves, as explained below.

One more detail is custody. Client securities are held separately from the broker’s own assets, but the protection rules in a broker’s insolvency and the amount of compensation depend on the broker’s country of registration. These terms are worth checking in the contract before moving a portfolio, not after.

Example: a family with €3 million in capital moves to Spain

The spouses are Russian citizens. Their capital is €3,000,000: €1,500,000 in a securities portfolio with a foreign broker, €900,000 set aside for a seaside flat, the rest in bank accounts. They obtain Spanish residence permits and from 2027 live here all year round.

  1. Before the residence permit. At an EU bank, the spouses can hold up to €200,000 on a joint account (€100,000 each), and at a Swiss bank up to CHF 200,000. The €900,000 for the flat cannot be parked in advance in one account at one bank: it is transferred in parts for the purchase, or the residence permit is obtained first. An EU broker will not sell them new bonds and funds.
  2. After the residence permit. The Article 5b limits no longer apply: they can hold the full amount in the account, get a card and buy any securities. The bank will check the origin of every large sum.
  3. Russia. In 2027 the spouses spent more than 183 days abroad, so they do not need to notify the Russian Federal Tax Service (FNS) of their accounts or file reports for that year.
  4. Spain: income tax. The portfolio yields 3% a year in dividends and interest, €45,000. Tax on the savings income scale: 6,000 × 19% = €1,140; 39,000 × 21% = €8,190; €9,330 in total, or 20.7% of the income, if all of it is attributed to one spouse.
  5. Spain: Modelo 720. Foreign accounts and foreign securities are separate blocks, and each exceeds €50,000: the return is filed for both blocks by 31 March 2028.
  6. Spain: wealth tax. If the flat becomes the main home, it is exempt up to €300,000. With the €700,000 allowance that applies when the region has not set its own, the base is 3,000,000 − 300,000 − 700,000 = €2,000,000 for the family, before splitting between the spouses and regional reliefs.

The figures in the example are illustrative: the wealth tax rate, the allowance and reliefs are set by the region, and income is split between the spouses according to whose name the assets are in. How wealth tax works by region is covered in our overview of taxes in Spain.

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Obligations towards Russia: notifying the FNS and reporting

Under Russia’s currency control law, Federal Law 173-FZ, all Russian citizens are currency residents wherever they live (Article 1 of Law 173-FZ). Article 12 of the same law allows them to open accounts abroad without restriction; the exception is people barred from doing so by Federal Law 79-FZ, such as public officials. The obligations are towards the FNS, Russia’s Federal Tax Service:

  • notify the tax authority of opening or closing an account, or of a change in its details, within one month (Article 12(2));
  • every year by 1 June, file a report on movements of money and other financial assets, which also covers a brokerage account (Article 12(7); the deadline is per an FNS clarification, forms KND 1120107 and KND 1112520);
  • no report is needed for an account in a Eurasian Economic Union (EAEU) country or a country with automatic exchange of information if no more than RUB 600,000 was credited or debited during the year, or if the year-end balance is no more than RUB 600,000 with no credits during the year (Article 12(7)).

The key point for those who have moved: these requirements do not apply to anyone who spent more than 183 days outside Russia in the calendar year (Article 12(8)). If in a given year you spent 183 days or fewer abroad, you must notify the FNS of any accounts not yet declared and file the report by 1 June of the following year. Failure to file a notification exposes a citizen to a fine of RUB 4,000 to 5,000 (Article 15.25(2.1) of the Russian Code of Administrative Offences). Currency restrictions on the transfers out of Russia themselves, and Russian tax on a non-resident’s income, are covered in our articles on transferring money from Russia and on the Russia–Spain double tax treaty.

Obligations towards Spain after the move

A Spanish tax resident pays tax on worldwide income, wherever the account is held. Interest, dividends and gains on the sale of securities go into the savings income base. Since 2025 its scale has been 19% up to €6,000, 21% up to €50,000, 23% up to €200,000, 27% up to €300,000 and 30% above that (Articles 66 and 76 of Law 35/2006, as amended by Law 7/2024). Tax withheld in the source country is credited under the double tax treaty.

Separately from the tax, there is an information return: Modelo 720. It is filed if a block exceeds €50,000: foreign accounts, foreign securities and funds, and foreign real estate are counted separately. The deadline is 1 January to 31 March of the following year; a new return is due when a block grows by more than €20,000 (Articles 42 bis and 42 ter of Royal Decree 1065/2007). Crypto-assets held with foreign custodians are declared separately on Modelo 721, see our article on cryptocurrency in Spain.

A resident pays wealth tax on all net assets, including accounts and securities abroad (Article 5 of Law 19/1991). As a general rule the tax-free allowance is €700,000 and the main home is exempt up to €300,000, but the allowance, rates and reliefs are set by the regions.

Under the Beckham regime the picture is different: foreign capital income is not taxed in Spain, and Modelo 720 does not have to be filed, as the Spanish Tax Agency states. This exemption does not extend to a spouse and children who have not opted into the regime.

What to do before and after the move

  1. Gather documents on the origin of your capital before choosing a bank: sale contracts, statements, tax returns, dividend resolutions.
  2. Decide when to move large sums: before the residence permit, with the €100,000 per-bank limit, or after it, with no limit.
  3. Check which securities in the portfolio fall under Articles 5e and 5f and what the broker will do with them once your status changes.
  4. Work out the year of the move: how many days outside Russia, from what date Spanish tax residence begins and which assets go into the first Modelo 720.
  5. Assess wealth and inheritance tax before buying a home: the region is a tax decision too. See our guide to inheritance and gift tax in Spain; if assets sit in companies, see a holding company in Spain.

If you are planning to move with capital and want to understand in advance which accounts and obligations your family will have, book a consultation: we will go through your sequence of steps, and the scope of work will be agreed after the call.

Frequently asked questions

Is the €100,000 limit lifted once I get a Spanish residence permit?

Yes. Article 5b(3) of EU Regulation 833/2014 excludes people with a temporary or permanent residence permit in an EU or EEA country or Switzerland. With a Spanish residence permit, a bank can accept deposits above €100,000 and issue a card, but it will still check where the money comes from.

Is the €100,000 limit the account balance or the total of all top-ups?

The balance. The ban covers accepting new deposits if the client’s total deposits with that bank exceed €100,000. If you have spent part of the money and the balance has fallen below the limit, you can top the account up to €100,000 again.

Is a joint account of spouses capped at €100,000 or €200,000?

If both spouses are Russian citizens without an EU residence permit, the amount is split between the two, and up to €200,000 can be held on a joint account in one bank. That is the European Commission’s answer in its FAQ on deposits, question 32.

Can a Russian citizen open a bank account in Switzerland?

Yes, Swiss law does not prohibit it. Without a residence permit in Switzerland, the EEA or the United Kingdom, a deposit limit of CHF 100,000 per bank applies, along with a ban on new cards and on the sale of securities issued after 12 April 2022. Each bank discloses its minimum balance and timelines on request.

Do I need to notify the Russian tax service of a foreign account if I live in Spain?

No, if you spent more than 183 days outside Russia in the calendar year: in that case the notification and reporting requirements of Article 12 of Law 173-FZ do not apply to you. If in a given year you spent 183 days or fewer abroad, the notification and report must be filed by 1 June of the following year.

Are a brokerage account and a bank account added together for Modelo 720?

No. The €50,000 threshold is counted for each block separately: foreign accounts, foreign securities and funds, and foreign real estate. If only one block exceeds it, only that block is declared.

Do I have to file Modelo 720 under the Beckham regime?

No. The Spanish Tax Agency explains that a person under the special regime for inbound workers does not file Modelo 720. A spouse and children who have not opted into the regime and have become tax residents file the return on the general rules.

Key points about a foreign bank account for a Russian citizen

  • A Russian citizen can open an account abroad: neither Russian law nor EU or Swiss sanctions prohibit it.
  • Without an EU, EEA or Swiss residence permit, banks in the EU and Switzerland apply a deposit limit of €100,000 or CHF 100,000 per bank, a ban on new cards and on buying securities issued after 12 April 2022.
  • A Spanish residence permit lifts these restrictions but does not remove the check on where the money comes from.
  • Obligations towards Russia for the account fall away in any year in which you spent more than 183 days abroad.
  • Towards Spain, a tax resident faces savings income tax of 19–30%, Modelo 720 when a block exceeds €50,000, and wealth tax.
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