US Sanctions and a Russian Passport: Who They Actually Apply To

"US Sanctions" Are Three Different Regimes

In conversation people lump sanctions into one block. At the regulatory level there are three distinct mechanisms, and different people's problems come from different layers.

Specially Designated Nationals (SDN List). A public list of specific individuals and companies, maintained by OFAC. If your name is on it, every asset under US jurisdiction is frozen and any transaction is prohibited. For most founders and IT professionals this is not the relevant layer.

Sectoral sanctions. Restrictions on dealing with specific industries — defense, energy, financial sector. If you don't control a company in a sanctioned sector, these don't reach you either.

Territorial restrictions. A prohibition on US companies providing certain services to people physically located in Russia. This is where most everyday problems come from: blocked subscriptions, frozen cards, rejected payment processors, suspended cloud accounts.

A careful reader can already see the key distinction. The third regime — the one that affects the most people — is built around physical location, not citizenship.

"Person Located In" — The Phrase That Changes Everything

If you open the underlying executive orders, the prohibition reads, word for word: US companies are barred from providing certain services "to any person located in the Russian Federation." Not "citizens of Russia," but "persons located in Russia."

This is not a loose paraphrase. It's a legal term in a specific document: OFAC Determination signed by Director Andrea M. Gacki on May 8, 2022, issued pursuant to Executive Order 14071 "Prohibiting New Investment in and Certain Services to the Russian Federation." The determination prohibits the export, re-export, sale, or supply — directly or indirectly — of accounting, trust and corporate formation, and management consulting services to any person located in the Russian Federation. Effective June 7, 2022.

The same "person located in" construction runs through most subsequent executive orders and OFAC determinations on Russia. The regulator deliberately built the rule around location rather than passport — because US jurisdiction doesn't have tools to track citizenship globally, but it does have tools to verify actual presence (address documents, banking records, IP, paperwork).

Out of that single phrase grow four scenarios in which the sanctions don't technically apply to you.

Scenario 1. Residency in Another Country

The cleanest path. If you hold a residence permit in a country outside the sanctioned perimeter — Serbia, Türkiye, the UAE, Armenia, Georgia, Thailand, an EU country if you have grounds — you legally stop being "a person located in the Russian Federation." Even if you visit Russia periodically.

The document a bank or service expects in this case is your residency card from the target country. That alone is usually enough to clear KYC and unlock services that are closed to Russian residents.

One important note: a tourist visa doesn't do this job. The regulator treats residency as evidence that the center of your life interests has moved to another jurisdiction — and that's a term with concrete meaning. You need not just the card, but actual life in that country for a meaningful part of the year.

Scenario 2. Actual Relocation Without Yet Holding the Card

The regulator recognizes facts on the ground, not just paperwork. If you've moved, you rent housing, you pay taxes in the host country, your kids attend a local school, you carry local health insurance — and your residency card is still being processed — you still don't fit the definition of "a person located in Russia."

The evidence in this scenario is built from several layers:

• a long-term lease agreement (six months or more)
• tax registration and proof of tax payments
• utility bills in your name
• local health insurance
• an employment contract or sole-proprietor registration in the host country
• bank statements from local accounts for the last three to six months

Banks and services like this scenario less than scenario 1 — because instead of one card you're handing over a package of documents. But it works. With a properly assembled file most fintech services accept it.

Scenario 3. US Citizenship Held Alongside a Russian Passport

A portion of our clients hold a US passport — born in the United States, naturalized, or acquired citizenship through parents. They also hold a Russian passport, and physically live in Russia.

To the US regulator, you are first and foremost a US citizen. The "Russia territorial" sanctions, which target persons located in the Russian Federation, are not in this logic directed at US citizens. The regulator evaluates your status under US law, not under everyday reality.

In practice this means US services, banks, and payment systems treat you as a US person — with the full set of rights and obligations. Including, by the way, US tax reporting duties that apply to US persons regardless of country of residence.

Scenario 4. An Active Green Card

A Permanent Resident Card (LPR status) makes you a US resident for all practical purposes, sanctions regime included. If you are temporarily in Russia but your LPR status remains valid — confirmed by a non-expired re-entry permit or the appropriate stamp — your legal "place" is the United States.

A nuance worth keeping in mind: an extended absence from the US — especially uninterrupted absence longer than a year — can put the LPR status itself at risk on re-entry. That's an immigration concern, not a sanctions one. But while the status is active, OFAC's territorial restrictions don't apply to you.

What This Unlocks in Practice

Once you fit one of the four scenarios, a set of doors that are closed to "persons located in Russia" opens:

• opening accounts at foreign banks without a KYC-stage rejection
• access to fintech infrastructure: Stripe, Wise, Mercury, PayPal, Payoneer
• working with cloud providers: AWS, Google Cloud, Microsoft Azure
• onboarding to freelance platforms and service marketplaces
• accepting payments from international clients without freeze risk
• legally clean documentation flow with US counterparties

This isn't "circumvention" in the negative sense. It's working inside a law that was explicitly written for persons not located in Russia. The regulator drew that line itself, and any individual physically outside Russia can rely on it.

What This Article Is Not

It is not an invitation to break Russian law. It does not teach you to mask your location, use fake documents, or mislead compliance officers. It does not promise that any bank will automatically accept your documents — every institution has its own risk policy, and that policy can be stricter than the regulator requires.

It is not a substitute for personal advice. Sanctions law is a field where general rules coexist with dozens of exceptions, general licenses, country-specific nuances, and grey zones. Any decision should be based on an analysis of your specific situation.

What to Do Next

If you recognize yourself in one of the scenarios, start not with action but with an inventory.

• What is your legal status right now?
• Where do you physically spend more than 183 days a year?
• Which documents can you already produce, and which do you still need to gather?

If none of the scenarios describe your situation yet, the choice reduces to two strategic moves:

1. Get a residency in a suitable jurisdiction — pick the country by basis (investment, remote work, study, digital nomad), go through the process, obtain the status.
2. Relocate in fact and assemble an evidence base — move, start paying taxes locally, secure a long-term lease, accumulate local paperwork, and run the residency application in parallel.

At Edeal we structure this path as a decision tree: country → basis for status → budget → timeline → document package. Every week we work through several of these for entrepreneurs, IT professionals, and investors.

The main point of this piece: between "I'm under sanctions" and "I'm fully unaffected" sits a wide space of legal options. In our experience, almost everyone finds theirs somewhere inside that space.

US Immigration Options for Russian Citizens in 2026: The Main Categories

Sanctions and immigration are two separate questions. The scenarios above describe when a Russian citizen can legally use US financial and business services. Whether a person can live or work in the United States is a matter of immigration law, and it runs on its own set of categories. Below is a plain-language map of the routes that most often come up for Russian citizens in 2026. This is factual background, not legal advice: Edeal does not file visa petitions, and our work begins on the business and tax layer once a person's status is settled.

Nonimmigrant (temporary) work routes. The H-1B specialty-occupation visa is subject to an annual numerical limit — 65,000 visas under the regular cap, plus 20,000 reserved for holders of a US master's degree or higher, according to USCIS. The L-1 category covers intracompany transfers for staff moving from a foreign employer to a related US entity, and the O-1 category covers individuals with demonstrated extraordinary ability. None of these turns on nationality as such.

The E-2 investor route — an important exception. The E-2 treaty-investor visa is available only to nationals of countries that hold a qualifying treaty of commerce with the United States. According to the US Department of State's treaty-country table, Russia is not on that list. In practice a Russian citizen generally cannot obtain an E-2 visa on the strength of a Russian passport alone; a second, treaty-country nationality would be required.

Immigrant investor route (EB-5). The EB-5 Immigrant Investor Program sets a standard minimum investment of $1,050,000, reduced to $800,000 for a project in a targeted employment area, according to the USCIS Policy Manual. Those amounts have applied to petitions filed on or after 15 March 2022 under the EB-5 Reform and Integrity Act, and are scheduled to adjust on 1 January 2027.

Employment- and family-based green cards. Permanent residence is also granted through employment preferences (the EB-1, EB-2 and EB-3 categories) and through family relationships to US citizens and lawful permanent residents. Waiting times depend on category and country of birth and are published monthly by the Department of State.

The Diversity Visa lottery. Each year up to 55,000 immigrant visas are made available through the Diversity Immigrant Visa Program to nationals of countries with historically low rates of immigration to the United States, according to the US Department of State. Eligibility by country is set annually in the program instructions, so it should be checked for the specific program year.

Where a US Business and Immigration Status Meet

One misunderstanding is worth stating plainly: forming a US company does not by itself grant a visa, residency or the right to work in the United States. A non-resident can own a US LLC, but ownership is not immigration status, and the two are decided under different bodies of law.

What a settled status does change is the business layer. Once a person has lawful residency abroad or lawful presence in the US, the practical questions become straightforward: registering the entity, opening banking, and staying compliant with federal and state tax obligations. This is where Edeal works. We handle US LLC registration, ongoing US tax filing for non-residents and residents, brand protection through US trademark registration, and setup for those who plan to sell through marketplaces such as Amazon. The immigration decision stays with qualified immigration counsel; the company and its finances are ours to run.

Frequently Asked Questions

What are the main US immigration options for Russian citizens in 2026?
The main routes are the same categories open to other nationals: temporary work visas such as H-1B, L-1 and O-1; the EB-5 immigrant investor program; employment-based green cards (EB-1, EB-2 and EB-3); family-based immigration; and the annual Diversity Visa lottery. Sanctions do not create a separate immigration track — nationality mainly affects specific categories, such as the treaty-based E-2 visa.

Can Russian citizens get an E-2 investor visa in 2026?
Generally not on a Russian passport alone. The E-2 treaty-investor visa is limited to nationals of countries that hold a qualifying commerce treaty with the United States, and according to the US Department of State's treaty-country table Russia is not on that list. A Russian citizen would need a second, treaty-country nationality to qualify.

Does opening a US LLC give a Russian citizen a visa or residency?
No. A non-resident can own a US LLC, but company ownership is not immigration status and does not grant the right to live or work in the United States. Immigration and business formation are decided under separate bodies of law.

What is the minimum EB-5 investment for 2026?
According to the USCIS Policy Manual, the standard minimum is $1,050,000, reduced to $800,000 for a project in a targeted employment area. These figures apply to petitions filed on or after 15 March 2022 and are scheduled to adjust on 1 January 2027.

Can a Russian citizen enter the US Diversity Visa lottery?
The Diversity Visa lottery makes up to 55,000 immigrant visas available each year to nationals of eligible countries, according to the US Department of State. Country eligibility is set annually in the program instructions, so it should be confirmed for the specific program year.

Do US sanctions stop Russian citizens from immigrating or forming a US company?
US sanctions are built around where a person is located and specific designations, not nationality alone. They do not create a blanket ban on immigration or on owning a US business for Russian citizens; the immigration categories above run on their own eligibility rules.