Banks and brokerage firms in Armenia have started requesting tax residency information from Russian nationals who hold accounts in the country. The data collection is tied to preparations for the first automatic exchange of banking information with a group of states that includes Russia. The exchange is scheduled to begin in September 2025.
Armenian regulators are already sending requests to personal account holders, controlling persons, and company beneficiaries. Clients are being warned that if they fail to provide the information, account servicing may be terminated.
After the start of the war in Ukraine, tens of thousands of Russians moved to CIS countries, including Armenia. Many opened bank accounts there, and some entrepreneurs relocated their businesses to the republic.
“Armenia, by our observations, is the most popular jurisdiction among Russians in the post-Soviet space for opening foreign accounts. These are not only bank accounts but also brokerage accounts, since Russians use Armenian infrastructure to trade securities,” Sergei Nazarkin, managing partner at NSV Consulting, told RBC.
According to Alexander Nadmitov, managing partner at the law firm Nadmitov, Ivanov and Partners, Armenia’s banking system has become a convenient channel for international settlements: foreign companies open accounts there to receive export revenue from Russia or transfer funds for imports.
Whether information is transferred depends on the client’s tax status. If a person lives in Armenia for more than 183 days a year, pays taxes there, or proves that the center of their vital interests is in that country, they are considered an Armenian tax resident. In that case, their information should not be passed to Russian tax authorities. That status is determined by Armenia’s tax authorities using data received from banks.
Tax lawyer Sergei Frankov, whose name was changed for security reasons, said banks compile lists of non-residents, collect data on balances and account turnover, and send it to Armenia’s Finance Ministry. Information on the income and assets of Russian non-residents, as well as companies they own, will then be forwarded under the automatic exchange system to Russia’s Federal Tax Service. For asset owners, this creates risks of tax audits, additional tax assessments, fines, and even criminal liability for concealing income and assets.