An amendment to the Law "On Currency Regulation and Currency Control" (the "Currency Law"), which came into effect on 15 March 2003, has created a situation with regard to the ability of non-residents to repatriate foreign currency from Russia in a non-cash form.
Previous Version of the Currency Law
Pursuant to the previous version of the Currency Law, non-residents (both individuals and companies) were expressly allowed to transfer out of Russia foreign currency in cash and non-cash form (i) in the amount that has been previously transferred into Russia or (ii) foreign currency that has been legally acquired in Russia.
Amendments
The intention of the amendments was to introduce a simplified regime for non-resident individuals to take cash out of Russia in the amount of up to US$10,000 without the need to prove to the Russian customs authorities that such foreign currency has been previously transferred into Russia. However, when incorporating these amendments into the text