The Central Bank of Russia has issued Bulletin No. 64 (1542) on July 10, 2014 regarding the rules for implementing the FATCA legislation. Central Bank’s guidance is given below:

  • “Punitive withholding” within the Russian territory is not governed.
  • Under a withholding regime, money transfer collected is not regulated and is not allowed.
  • The FATCA implementing law restricts the collection of information and reporting according to investment FFIs (foreign financial institutions).
  • The Russian “FATCA authorized body” can restrict the reporting on certain banking clients within its discretion.
  • At its discretion, the Russian FATCA authorized body can limit application of the rules requiring a bank to end certain client or entity relationships.
  • The law gives restriction on the collection and reporting of information with respect to certain U.S. taxpayers that are long-term residents of Russia.
  • The law does not give for an account closure with respect to manage certain FATCA-related status (for example, a domestic FFI).