Starting from 1 July 2024, resident legal entities will be required to regularly report on the movement of funds and other financial assets on accounts (deposits) of non-resident legal entities that form, along with them, part of a multinational enterprise group (MNE Group).
These legislative changes were announced well in advance:
- in December 2023, amendments to Federal Law No. 173-FZ of 10 December 2003 On Currency Regulation and Currency Control were published, establishing the fundamental provisions on the obligation of resident legal entities to file such reporting
- in May 2024, in order to further develop the new provisions of the Law on Currency Regulation, the RF Government approved the rules and the form of reporting on accounts of foreign legal entities forming part of an MNE Group
Despite the fact that the new reporting obligations did not come as a surprise to Russian organizations, the detailed mechanism for their implementation still raises a series of questions and needs clarification.
In the review at this link, you will find more information about the analysis of the rules and deadlines for preparing the reporting, the criteria for determining the persons responsible for the filing, and the established liability for violation of the reporting rules.
Kept currency and AML-compliance experts who major in structuring currency transactions and supporting foreign trade activity would be happy to provide services on the analysis of the corporate structure of an MNE Group, assessment of the applicability of the new reporting rules to a specific MNE Group, and development of a roadmap for the reporting campaign.
