Concerns of Russians Over Financial Information Exchange

We examine why many wealthy Russians are especially worried about global information-exchange regimes. The Common Reporting Standard (AEOI/CRS) and Exchange-on-Request (EoR) create layered visibility that can expose residency, assets, and financial flows — with consequences ranging from tax assessments to targeted investigations. Host countries that once offered anonymity now participate in automatic reporting, and requests from foreign authorities can probe ownership, trusts, and transaction histories. For those with ties to Russia, the combination of CRS reporting and Russia’s own residency rules can create unexpected exposure and legal risk.

Key Points Covered:

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• AEOI / CRS “blast radius”: Automatic periodic sharing of account data (balances, interest, dividends, gross sale proceeds) means losing prior anonymity in many host jurisdictions (e.g., UAE, Turkey, Armenia, Georgia, Kazakhstan as they join reporting regimes).
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• Russian residency risk: Russia’s residency tests (183+ days or “center of vital interests”) can result in host-country data being reported back to Russian authorities, potentially triggering tax or regulatory action.
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• Exchange on Request (EoR) “targeted missile”: Narrow, case-specific information requests enable authorities to dig into beneficial ownership, trust records, and detailed transactions — a tool that can be used against high-risk individuals, including dissidents.
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• Practical exposures: AEOI reveals account balances and income; EoR can access detailed ownership and transactional evidence useful for tax audits, currency-control probes, and other enforcement actions.
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• Mitigation needs: Effective responses combine focused tax, legal, and privacy planning—substance, documentation, treaty analysis, and proactive compliance are central to risk management.
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Why It Matters:

For internationally mobile individuals with ties to Russia, the convergence of automatic and request-based information exchange has dramatically reduced secrecy options and increased legal risk. Understanding how AEOI and EoR interact with domestic residency rules is essential for planning, compliance, and risk mitigation.

Takeaway:

Transparency regimes have enlarged the “blast radius” around cross-border wealth. Anyone with potential exposure should seek specialist tax, legal, and privacy advice immediately — not to evade law, but to align structures with reporting realities and limit unintended consequences.