
On August 11, 2020, a number of amendments to the Federal Law on Currency Regulation and Currency Control entered into force.
One of them concerns the expanded wording of the term “report on the movement of funds” — the law now uses the wording “report on the movement of funds and other financial assets”.
This addition is linked to the introduction of an obligation (from January 1, 2021) to report on accounts not only with foreign banks, but also with other financial market institutions (brokers, insurance companies, etc.). The current report form provides for disclosure of information solely on the movement of funds, which makes it difficult to determine how to complete the report in respect of the movement of other financial assets (in particular, securities) on such accounts.
Accordingly, amendments to the report form itself [on the movement of funds and other financial assets] should also be expected in the near future.
Another amendment concerns the crediting of foreign-currency loan funds to foreign accounts: the changes will allow crediting not just the amount of the loan / credit, but any funds under the loan / credit agreement (in particular, both the principal amount of the loan and interest thereon). At the same time, the requirements regarding the list of states and the term of the agreements remain in place:
The account must be opened in an EAEU member state or in a jurisdiction that ensures automatic exchange of information with Russia,
The term of the loan / credit agreement must be at least 2 years.
An important feature: the above amendment applies only to those loan agreements to which the repatriation requirements established by Federal Law No. 64-FZ dated 03.04.2018 do not apply, i.e. agreements concluded before 14.04.2018.
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