EMI for Russians with pooled IBAN for consultant

[RemcoL]

Used Payoneer for several years and was VERY happy with debit Mastercard . Recently Payoneer stopped blocked them all due to ne Russian government rules (in fact Mastercarddid it). Shared IBAN allowed not to to worry so much about CRS with Russia - EMI's with individual IBANs for customers started to send the data (for example BlackCatCard). Sure it requires a lot of trust but it was not a problem with Payoneer. I looked through dozens of EMI's and they do not send card to Russia/Russian citizens or have individual IBANs (or allows only incoming funds from your own account). Are there companies left for Russians like Payoneer? From Wirex, Paesera, Stcipay to ValettaPay, Globalnetit, Beboon amd Payglobal all are not for Russians... I need prepaid/debit card for payments from absolutely legit German company.

Armenia and Georgia (until the end of 2021) may be a solution but they may be too exotic for a conservative German company...

 

[Garret Gates]

Used Payoneer for several years and was VERY happy with debit Mastercard . Recently Payoneer stopped blocked them all due to ne Russian government rules (in fact Mastercarddid it). Shared IBAN allowed not to to worry so much about CRS with Russia - EMI's with individual IBANs for customers started to send the data (for example BlackCatCard). Sure it requires a lot of trust but it was not a problem with Payoneer. I looked through dozens of EMI's and they do not send card to Russia/Russian citizens or have individual IBANs (or allows only incoming funds from your own account). Are there companies left for Russians like Payoneer? From Wirex, Paesera, Stcipay to ValettaPay, Globalnetit, Beboon amd Payglobal all are not for Russians... I need prepaid/debit card for payments from absolutely legit German company.

Armenia and Georgia (until the end of 2021) may be a solution but they may be too exotic for a conservative German company...

I guess for German company, that better to open a real bank account with Reiffeisen, try to setup connections via Russian representative, they gotta have international department or they shall link you with German or Austria ones (UniCredit is 2nd option).

 

[RemcoL]

That's a good solution but I'm trying to find the bank/EMI like Payoneer where customer accounts are pooled in one account so they are a grey zone for automatic exchange...

 

[Garret Gates]

That's a good solution but I'm trying to find the bank/EMI like Payoneer where customer accounts are pooled in one account so they are a grey zone for automatic exchange...

So I can’t understand the way of company formation in Germany, if you want to find a bank account in a grey zone, as Germany has high tax system, and moreover I think there is a double tax avoidance agreement between Russia and Germany... anyway somebody reccomend Pervesk or Bankera here, didn’t try them personaly. There is Dynapay as well, my company formation agent uses it more than half a year and happy!

 

[Garret Gates]

So I can’t understand the way of company formation in Germany, if you want to find a bank account in a grey zone, as Germany has high tax system, and moreover I think there is a double tax avoidance agreement between Russia and Germany... anyway somebody reccomend Pervesk or Bankera here, didn’t try them personaly. There is Dynapay as well, my company formation agent uses it more than half a year and happy!

Ups, sorry, he uses Dynapay 1 year and half...they are open for EU companies.

 

[RemcoL]

Dear Garret, maybe I was not 100% clear - German paying company is not mine and will pay me for legitimate services. Payoneer was convenient for receiving money as prepaid cards funds are kept pooled - so there is nothing what to report by automatic exchange. And yes, in a couple of years this possibility may be closed.
I will look ar Dynapay, thanks!

 

[RemcoL]

Dynapay, Pervesk and Bankera all give personal IBANs=crs/aeoi...

 

[Tax Cow]

Side-tracking a little. Any chance to get paid in dollars? To keep the Russian taxman in the dark, unaware of your offshore bank accounts, there's nothing better than a dollar account in the U.S.

...Not more than .0001% chance that the U.S. will start automatic sharing of bank account information with Russia or China in our, or our childerns' lifetimes.

As you're well aware, Russia already has active CRS AEOI relationships in place with a number of EU states. Leaving aside the conflict in Ukraine, there's quite a bit of comradish romance between the EU and Russia which in my opinion will only grow stronger after the departure of the UK from the union. Not much effort needed to force EU-based FIs to take an incremental step to take pooled accounts into the scope of CRS. You're on thin ice with a pooled account! And the ones who offer it are quite pricey, or pose a substantial exit scam risk. Nevertheless, if you still want to use a pooled account to avoid CRS, leave a PM or a message to my profile for a few options.

Regards

 

[MountainMan3436]

I don’t think whether the IBAN is pooled or shared makes any difference to the CRS reporting. Reporting requirements are based on whether an account exists. An account doesn’t necessarily have a direct IBAN. And conversely, just because an IBAN exists does not mean funds are not pooled.

 

[Tax Cow]

I don’t think whether the IBAN is pooled or shared makes any difference to the CRS reporting. Reporting requirements are based on whether an account exists. An account doesn’t necessarily have a direct IBAN. And conversely, just because an IBAN exists does not mean funds are not pooled.

Arguments make sense but that's not how CRS works in practice. A pooled account (IBAN code) is held by a Financial Institution and thus exempt. Individual entities (re)using that account for their own businesses are a mere ID number referenced in payment descriptions. Nobody has an "account" per-se. There's nothing to report...

CRS guidelines are quite permissive of enhanced scrutiny (on both fronts - jurisdiction and FI level) but there is no requirement to dismantle those to individual beneficiaries for the purpose of CRS. Standard KYC/AML legislation still applies.

One creative way to avoid CRS AEOI is to send funds to a pooled account of a pension fund:
- send cash in before the year ends (or another month of reporting period end) , and then change mind in the month of January, saying you do not wish to save for retirement at this point. No country will recieve CRS AEOI report from that FI offering the pension plan. The difficult part is finding a flexible fund.

The above example is quite extreme as not many funds allow such rapid withdrawals after commitment, but let's say you have 10 mil of stinky cash, you can ring-fence it from CRS AEOI, without putting in any meaningful effort, in a pension fund for a few years until you're ready to take it out for a small fee.

Pooled accounts (including those of 3rd party voulentary pension funds) are a very useful tool in washing if CRS is a concern. I just would not build my active business around these.

 

[MountainMan3436]

Yes this example of the pension fund is of course correct, and many other pooled type accounts (like professional client accounts or trustee accounts) have different reporting regulations.

But I thought we were talking about EMIs. EMIs cannot (legally) simply hold pooled funds without opening an account in their books. Whether an EMI issues a direct IBAN or some other form of account identifier like a “reference number” it is still an account at an EMI. It would be dangerous for someone to think that just because there is no IBAN number there will be no CRS reporting.

 

[RemcoL]

I also do not think that pooled card debit/prepaid card accounts will live forever and AEOI will reach them some day in the future, probably rather soon. But currently they are not so much on the radar and I hope that other forms of being not so much visible will be found. For example, stable anonymous cryptocoin-based cards (like Monero but not bitcoin).

 

[JohnLocke]

I guess for German company, that better to open a real bank account with Reiffeisen, try to setup connections via Russian representative, they gotta have international department or they shall link you with German or Austria ones (UniCredit is 2nd option).

Where did you get this from, have you tried it or just something you think will work?

 

[Garret Gates]

Where did you get this from, have you tried it or just something you think will work?

I’m telling from my co-partner experience, he is a long-term client of Reiffeisen in Russia and he could set up connection with Reiffeisen in Prague and open account for his EU business. But anyway I can’t say “one size fits to all”, maybe depends on business type.

Where did you get this from, have you tried it or just something you think will work?

Btw, another colleague, with the same story, it was with Citibank, he opened business account in Citibank London for his US LLC.

 

[Granwasa]

Good morning OP,
I would suggest you to try Advcash, Perfectmoney and Capitalist.net. They all accept Russian users and are well established.