Bank Compliance for Russian Investors
Navigate OFAC sanctions, compliant transfer methods, and US banking under current restrictions
Critical Information
Sanctions Screening
List Verification
Enhanced Due Diligence
Bank Options
Since 2022, Russian nationals face the most challenging banking environment of any major investor group. Direct transfers from Russian banks are largely blocked, and US banks apply maximum scrutiny to Russian-connected transactions. However, legal pathways remain for non-sanctioned individuals with properly documented, compliant capital.
Current Sanctions Landscape
US sanctions on Russia are extensive but NOT comprehensive. Understanding what is and is not sanctioned is critical.
What IS Sanctioned
- SDN-listed individuals and entities
- Most major Russian banks (Sberbank, VTB, etc.)
- Russian Central Bank transactions
- Certain sectors (defense, technology)
- Occupied Ukrainian regions
- Oligarchs on sanctions lists
What is NOT Sanctioned
- Ordinary Russian citizens
- Some smaller Russian banks
- Funds held outside Russia (legally)
- Personal savings and investments
- Russian passport holders abroad
- Non-SDN business owners
Key Sanctions Programs
- Executive Order 14024 (Russia harmful activities)
- Sectoral Sanctions (SSI)
- Correspondent banking prohibitions
- SWIFT disconnections
- Export controls (EAR)
Self-Check Resources
- OFAC SDN Search Tool
- Consolidated Sanctions List
- EU sanctions database
- UK sanctions list
- Professional sanctions screening
OFAC Screening Process
Every transaction involving Russian nationals undergoes intensive OFAC screening. Here is what banks check.
Name Screening
- SDN (Specially Designated Nationals) list
- Sectoral Sanctions Identifications
- Non-SDN Menu-Based Sanctions
- Fuzzy matching for name variants
- Cyrillic-Latin transliteration checks
Address and Entity Screening
- Russian address verification
- Business entity ownership
- Beneficial ownership disclosure
- 50% ownership rule for entities
- Associated persons and companies
Banking Options
US Banks Accepting Russian Clients
Most major US banks will serve non-sanctioned Russian nationals, but with enhanced due diligence. Some are more experienced than others.
| Bank | Approach | Notes |
|---|---|---|
| Citibank | Case-by-case with extensive documentation | Has Russian-speaking compliance staff |
| Chase | Very cautious; may decline new accounts | Existing customers may be retained |
| Bank of America | Enhanced due diligence required | Slower processing times |
| HSBC USA | Global screening; thorough but experienced | Private banking options for HNW |
| Regional banks | Varies widely; some more flexible | Less experience with Russian clients |
Account Opening Challenges
Common Rejection Reasons
- Funds originating from sanctioned banks
- Incomplete beneficial ownership disclosure
- Connection to sanctioned individuals
- Insufficient source of funds documentation
- Bank risk appetite exceeded
How to Improve Chances
- Use funds held outside Russia
- Provide comprehensive documentation
- Work with an attorney
- Consider private banking
- Be transparent about everything
Documentation Requirements
Enhanced Due Diligence Documents
Russian nationals should expect to provide more documentation than investors from other countries. Prepare these in advance.
Identity and Background
- Valid passport (Russian and/or foreign)
- Secondary ID documents
- Proof of current residence
- Employment history
- Professional background
Source of Wealth
- Employment income documentation
- Business ownership records
- Investment history
- Real estate sale documentation
- Inheritance records
Source of Funds (Specific)
- Bank statements showing accumulation
- Tax returns (translated)
- Sale contracts and receipts
- Wire transfer history
- Intermediary bank documentation
Negative Confirmations
- No SDN list presence (self-certification)
- No connection to sanctioned entities
- No government/military affiliation
- No sanctioned bank origin
- Attorney opinion letter (helpful)
Compliant Transfer Methods
How to Move Funds Legally
Direct transfers from Russian banks to US banks are effectively blocked. Compliant alternatives exist for legitimately-sourced funds.
Permitted Routes
- Transfer from non-sanctioned third-country accounts
- Funds already held outside Russia
- Income earned outside Russia
- Investment returns from non-Russian sources
- Sale of non-Russian assets
Third-Country Banking
- UAE (Dubai) - still accessible
- Georgia - Russian-friendly
- Armenia - accessible
- Turkey - case by case
- Note: Still requires clean funds
What to Avoid
- Transfers from sanctioned banks
- Correspondent banking through Russia
- Crypto used to evade sanctions
- False documentation
- Nominee/straw person arrangements
Process Timeline
- Account opening: 2-4 weeks typical
- Wire processing: 3-10 business days
- Compliance review: additional 1-2 weeks
- Full clearance: 4-8 weeks realistic
Third-Country Banking Strategies
Many Russian investors establish banking relationships in third countries. This is legal if the underlying funds are legitimate and properly documented.
| Country | Accessibility | Notes |
|---|---|---|
| UAE (Dubai) | Good | Popular choice; increasing scrutiny |
| Georgia | Very Good | Russian-speaking; fewer restrictions |
| Armenia | Good | Accessible for Russian residents |
| Turkey | Moderate | Case by case; some restrictions |
| Kazakhstan | Good | Accessible; watch for secondary sanctions |
| EU countries | Difficult | Most have similar restrictions to US |
Frequently Asked Questions
Am I automatically sanctioned because I am Russian?
No. Being a Russian citizen does not automatically make you sanctioned. Sanctions target specific individuals, entities, and sectors. You can verify your status using OFAC's SDN search tool. However, banks will apply enhanced due diligence to Russian nationals regardless of sanctions status.
Can I transfer money from Sberbank or VTB?
No. Sberbank and VTB are under full blocking sanctions. Direct transfers from these banks will be blocked. You would need to move funds to a non-sanctioned bank first (which may also be difficult from within Russia), and even then, US banks will scrutinize the ultimate origin.
What if I have dual citizenship?
Dual citizenship with a non-Russian country (especially a Western country) can help, but banks will still screen for Russian connections. Use your non-Russian passport for account opening, but be prepared to disclose Russian citizenship if asked. Never hide it - that creates far bigger problems if discovered.
Can I use cryptocurrency to transfer funds?
Using cryptocurrency specifically to evade sanctions is illegal under OFAC regulations. If you convert sanctioned funds to crypto and then to USD, you are violating sanctions. US exchanges and banks will ask about the source of crypto-derived funds. Legitimate crypto holdings are fine, but not as a sanctions evasion mechanism.
What about funds I had outside Russia before 2022?
Funds legitimately held outside Russia before the sanctions escalation are generally the easiest to use. You will need documentation showing when and how the funds were moved, and that they were not sourced from now-sanctioned entities. Account statements from before 2022 are very helpful.
Should I work with a lawyer for banking issues?
For Russian nationals, I strongly recommend working with an attorney experienced in sanctions compliance. An attorney can provide an opinion letter, help prepare documentation, and communicate with banks' compliance departments. The cost is modest compared to the cost of failed transactions or account closures.