CIS Country Routing for Russian Investors
Kazakhstan, Armenia, and Georgia as compliant pathways to US investment
Why CIS Countries Work
Primary Transit Hubs
Connected Banks
Accept Inflows
Can Send Out
The Transit Hub Concept
Since major Russian banks are disconnected from SWIFT and cannot process USD transactions directly with Western banks, Russian nationals need an intermediate step. CIS countries offer this because:
Why These Countries
- Maintain banking with both Russia and West
- Accept Russian nationals for accounts
- Connected to SWIFT network
- No sanctions on their banking system
Legal Basis
- Using third-country banking is legal
- Must have genuine presence/residence
- Must declare all income properly
- Cannot structure to evade sanctions
Country Comparison
Kazakhstan vs Armenia vs Georgia
| Factor | Kazakhstan | Armenia | Georgia |
|---|---|---|---|
| Bank account opening | Easiest (with IIN) | Moderate | Harder (more KYC) |
| Residency requirement | Registration possible | Easy residence permit | 1 year visa-free |
| USD transfers out | Yes (limits apply) | Yes | Yes |
| RUB transfers in | Yes | Yes | Yes (limited banks) |
| Crypto exchanges | Available | Limited | Available |
| Time zone from Moscow | +2-4 hours | +1 hour | 0-1 hour |
| Flight from Moscow | 4-5 hours | 2.5 hours | 2.5 hours |
| Western sanctions risk | Low-Medium | Low | Low |
Kazakhstan
Banking in Kazakhstan
Kazakhstan has become the most popular transit hub for Russian capital due to its developed banking system and relative ease of account opening:
Key Banks
- Kaspi Bank (easiest, mobile-first)
- Halyk Bank (largest, international)
- Forte Bank (good for business)
- Freedom Finance Bank
Requirements
- IIN (Individual ID Number)
- Passport + local SIM card
- Physical presence for IIN
- Address registration (temporary OK)
Getting an IIN (Individual ID Number)
The IIN is required for banking and is obtained at a Public Service Center (CON):
- Arrive in Kazakhstan (visa-free for Russians, 90 days)
- Get temporary registration at hotel or rental
- Visit CON with passport and registration
- Receive IIN same day or next day
- Use IIN to open bank account
Transfer Limits and Fees
| Transaction Type | Typical Limit | Fees |
|---|---|---|
| RUB transfer in (from Russia) | Varies by bank | Low or free |
| Convert RUB to USD | Market rate | 1-2% spread |
| SWIFT transfer out (USD) | $50,000-100,000/day | $30-50 per transfer |
| Card payments abroad | Daily limits apply | Varies |
Armenia
Banking in Armenia
Armenia offers visa-free entry for Russians and has maintained banking relationships with both Russia and Western correspondent banks:
Key Banks
- Ameriabank (largest, international)
- Ardshinbank (good for transfers)
- Converse Bank
- ACBA Bank
Account Opening
- Passport required
- Proof of address (rental contract)
- Source of funds documentation
- Branch visit required
Residence Options
Armenia offers several paths to legal residence:
Temporary Residence (1 year)
- Work permit path
- Business/investment path
- Study path
- Renewable annually
Benefits
- Easier bank account approval
- Higher transfer limits
- Access to investment accounts
- Tax treaty benefits
Transfer Capabilities
Inbound (from Russia)
- RUB transfers via MIR system
- Some Russian banks still connect
- Koronapay transfers work
- Unistream available
Outbound (to USA)
- SWIFT transfers available
- USD accounts possible
- Correspondent banking intact
- Reasonable fees
Georgia
Banking in Georgia
Georgia has become more cautious about Russian accounts but remains an option, especially for those with EU/Western ties:
Key Banks
- Bank of Georgia (largest)
- TBC Bank (modern, digital)
- Liberty Bank
- Basis Bank
Current Challenges
- Stricter KYC for Russians
- Source of funds heavily scrutinized
- Some banks declining Russians
- Higher documentation requirements
Visa-Free Stay
Georgia offers the longest visa-free stay for Russians:
Entry Rules
- 1 year visa-free stay
- No registration required
- Can exit and re-enter
- Work permit needed for employment
Residence Permit
- Investment path ($100K+ property)
- Employment path
- Remote work program available
- Freelancer/digital nomad options
Transfer Considerations
Georgia's banking system has moved away from Russian connections:
| Transfer Type | Status | Notes |
|---|---|---|
| Direct from Russian banks | Mostly blocked | Few exceptions |
| MIR card payments | Suspended | Since 2022 |
| Crypto on-ramp | Available | P2P and exchanges |
| SWIFT out to USA | Works | Full functionality |
Step-by-Step Process
Typical Path: Russia to US Investment
A compliant process typically involves these steps:
- Sanctions Screening: Verify you are not on SDN or other lists
- Travel: Fly to chosen CIS country (Kazakhstan recommended)
- Registration: Obtain local ID (IIN in Kazakhstan)
- Bank Account: Open local bank account with proper KYC
- Transfer In: Move RUB from Russia to local account
- Convert: Exchange RUB to USD at local bank
- Transfer Out: SWIFT transfer USD to US bank/broker
- Document: Keep complete records of all transactions
Timeline Expectations
| Step | Typical Time | Notes |
|---|---|---|
| Travel + ID registration | 1-3 days | Kazakhstan fastest |
| Bank account opening | 1-7 days | Varies by bank/country |
| RUB transfer from Russia | 1-5 days | Depends on sending bank |
| Currency conversion | Same day | At bank rate |
| SWIFT transfer to USA | 2-5 business days | Standard SWIFT timing |
| Total minimum | 1-2 weeks | If everything goes smoothly |
Compliance Requirements
What Makes Routing Legal vs Illegal
Legal (Compliant)
- Genuine physical presence
- Real local registration
- Transparent banking relationship
- Documented source of funds
- Proper tax reporting
Illegal (Sanctions Evasion)
- Shell accounts with no presence
- Using nominees to hide identity
- Structuring to avoid reporting
- Misrepresenting source of funds
- Acting for sanctioned persons
See our OFAC Sanctions Screening Guide for detailed compliance requirements.
Documentation to Maintain
Personal Documents
- Passport copies
- Travel records (stamps, tickets)
- Local registration documents
- Rental/accommodation contracts
Financial Records
- Bank statements (all countries)
- Wire transfer confirmations
- Currency exchange receipts
- Tax filings (all jurisdictions)
Source of Funds
- Employment records/salary slips
- Business ownership documents
- Investment records
- Inheritance documentation
Frequently Asked Questions
Which country is best for me?
Kazakhstan if you want the fastest, easiest bank account opening. Armenia if you want a clear residence path and IT-friendly environment. Georgia if you plan longer-term relocation and have non-Russian income sources or crypto. Each has trade-offs; the best choice depends on your specific situation.
Do I need to actually live there?
You need genuine presence, not necessarily permanent residence. Opening an account remotely or using a nominee is sanctions evasion. A genuine trip, real registration, and in-person bank account opening is the minimum. Many people split time between Russia and the transit country.
What if the transit country gets sanctioned?
This is a risk, particularly for Kazakhstan which has closer Russia ties. Monitor US Treasury/OFAC announcements. If sanctions are imposed, you may need to move funds elsewhere before cutoff dates. Having accounts in multiple jurisdictions provides flexibility.
How much can I transfer?
Limits vary by bank and change frequently. Typical daily SWIFT limits are $50,000-$100,000. Larger amounts require additional documentation and may take longer. Never structure transactions to stay under limits - this is illegal. Work with your bank transparently on large transfers.
What about taxes?
You may have tax obligations in Russia, the transit country, and the USA. Russia taxes worldwide income for residents. The transit country may tax income earned/received there. The USA taxes certain US-source income. Consult a cross-border tax specialist to structure properly.