What Russian-Passport Buyers Can Realistically Do in 2026

The most important points in 60 seconds

• No jurisdiction covered here bans property purchase by Russian citizens as such. The binding restrictions sit in three places: bank accounts, payment channels and residency programs.
• The UAE is the open route: no nationality-based restrictions, title registers against a Russian passport, and banks apply enhanced source-of-funds checks rather than a prohibition.
• Thailand is open with a currency rule: for foreign ownership registration, the full purchase price must arrive from abroad in foreign currency, evidenced by the bank's FET form.
• Greece suspended the issuance and renewal of investor residence permits for Russian citizens on 28 February 2022, and the suspension remains in force in 2026. Purchase itself is not banned, but the main rationale, the golden visa, is unavailable to a Russian passport.
• The Cyprus permanent residency program carries no nationality bar, but the EUR 100,000 deposit cap under Article 5b of Regulation 833/2014 and bank de-risking make the route practical mainly for clients with EU residence or a second citizenship.
• The deposit cap does not apply to Russian citizens who also hold citizenship or a temporary or permanent residence permit in the EU, EEA or Switzerland. Dual citizens and EU residents are a separate category with materially wider options.
• We do not help anyone circumvent sanctions. Every route described here is legal, and we recommend specialised sanctions and legal advice for each individual case before any payment moves.

What the sanctions actually restrict

Start with what the sanctions framework does not contain. Neither the EU, nor the UAE, nor Thailand has banned the purchase of real estate by a private individual holding a Russian passport. Designated persons on sanctions lists are a separate matter and not the subject of this article. For the ordinary private buyer, the binding constraints sit in three places: bank accounts, payment channels and residency programs.

First, accounts in the EU. Article 5b of Council Regulation (EU) 833/2014 prohibits EU credit institutions from accepting deposits from Russian nationals or persons residing in Russia where the client's total balance at that institution would exceed EUR 100,000. The European Commission's guidance clarifies that the cap is counted across all accounts at one bank, applies to Russian nationals wherever they reside, and does not apply to holders of citizenship or a temporary or permanent residence permit in an EU or EEA member state or Switzerland. For a Greek or Cypriot purchase this is the central constraint, because almost any property price exceeds the cap.

Second, payment channels. Russia's largest banks have been disconnected from SWIFT since 2022, and the EU's 21st sanctions package, adopted on 23 July 2026, extended full blocking measures to a total of 94 Russian banks. A transfer from a sanctioned bank will either fail or be stopped at the correspondent layer. Transfers from non-sanctioned Russian banks remain possible and do clear with full documentation, just with longer review times.

Third, residency. Visa and residence-permit decisions are national: Greece closed its golden visa to Russian citizens, the UAE did not. On top of this sits an informal fourth layer: EU banks and service providers are frequently more cautious than the regulation requires and decline business the law would technically permit. That is practice rather than law, but any realistic client advice has to account for it.

UAE: the open route

Dubai is the one market of the four where, legally, almost nothing has changed for a Russian-passport buyer since 2022. The UAE has imposed no sanctions on Russian nationals, freehold-zone purchases carry no nationality restrictions, and the Dubai Land Department registers title against a Russian passport in the ordinary course. The deed is issued in the buyer's name regardless of where the payment originated.

The real work happens at the level of bank compliance. UAE banks observe international sanctions regimes because of their own correspondent relationships with US and European institutions, so a Russian buyer should expect enhanced due diligence: 12 to 24 months of statements, tax records, source-of-wealth evidence and a sanctions self-certification. With transparent capital this is a procedure, not a barrier. Settlement runs in dirhams, pegged to the US dollar, typically by bank transfer or manager's cheque into the project escrow account.

The residency route also works: a property purchase from AED 2,000,000 can support a ten-year Golden Visa application at the published UAE ICP threshold. No purchase grants residency automatically and the authorities decide each application, but the route itself is open to Russian citizens on the same terms as other nationalities. That combination of open title registration, a functioning banking channel and an available residency route is why Dubai became the primary overseas market for Russian buyers after 2022.

Thailand: open, with a currency rule

Thailand has imposed no restrictions on Russian-passport buyers: the foreign condominium quota, leasehold structures and the usual ownership rules apply to Russians exactly as they do to Germans or Britons, and Phuket remains one of the most active resort markets for Russian-speaking buyers. Thailand's particularity is not sanctions law but currency law, and clients need to understand it before any money moves.

The Condominium Act requires a foreign purchaser to remit the full purchase price into Thailand from abroad in foreign currency. The receiving Thai bank converts the funds to baht inside the country and issues the Foreign Exchange Transaction form, the FET, for transfers of USD 50,000 or more. Without the FET or its equivalent for smaller amounts, the Land Office will not register foreign ownership. The FET matters again at exit: it is the document that supports repatriating sale proceeds abroad.

The practical consequence for a Russian client: the payment must arrive in Thailand from overseas in foreign currency, so the transfer channel has to be planned in advance. Transfers from non-sanctioned Russian banks work, as do transfers from the buyer's own legally held accounts abroad, in the buyer's name. A rouble transfer inside Russia or cash carried into the country does not satisfy the statute, and the buyer's name must appear on the bank documentation as sender or recipient.

Greece: the residency route is closed

Greece is the hardest of the four cases. By ministerial order of 28 February 2022, the submission, issuance and renewal of investor residence permits for citizens of the Russian Federation is suspended until further notice. The suspension is still in force: Circular 1/2026 of the Greek migration ministry, issued in spring 2026, confirms it remains active and now explicitly extends to change-of-purpose applications. For a Russian passport, the Greek golden visa does not exist in 2026.

It is worth separating the visa from the purchase. EU law contains no ban on the property purchase itself, and the Court of Justice held in Jemerak that notarial authentication of a sale contract falls outside the prohibition on legal advisory services: the notary acts as an independent public official, and ancillary notarial tasks including escrow handling and registration remain permissible. The Article 5n services prohibition is addressed to entities established in Russia, not to private individual buyers.

Practice is harsher than theory. Completing a purchase requires a European bank account, which brings in the EUR 100,000 cap and the caution of banks reluctant to onboard clients holding only a Russian passport and no EU residence. A purchase with no golden visa prospect, a difficult banking channel and no right to stay beyond visa limits rarely makes sense. Our honest read: in 2026 Greece is a market for Russian citizens with EU residence or a second citizenship, not for single-passport holders.

Cyprus: formally open, practically narrow

The Cyprus permanent residency program, from EUR 300,000 of qualifying investment, carries no nationality bar: unlike Greece, Cyprus has not suspended applications from Russian citizens as such. The program additionally requires a secured annual income from abroad of at least EUR 50,000 for the main applicant, and all payments must reach Cyprus through the banking system from overseas.

This is where the route narrows. Cypriot banks are subject to the same Article 5b cap of EUR 100,000, and since 2022 the Cypriot banking sector has significantly de-risked its Russian client base: intensive source-of-funds scrutiny, long timelines, declines without detailed reasons. What is legally possible and what is practically achievable diverge more widely here than in any other market of the four. For Russian citizens holding EU, EEA or Swiss residence or a second citizenship the cap does not apply and Cyprus remains workable; for single-passport holders without European residence, every step from account opening to transferring the investment amount needs individual legal structuring before any deposit is paid.

Comparison: availability for Russian citizens

How payments actually work

The payment question decides more than any other. The starting point: transfers from Russian banks under blocking sanctions or disconnected from SWIFT are unusable for an international transaction, and attempting to route them through intermediary chains is a path to frozen funds and compliance exposure, not to a completed deal.

Three channels work legally. First, a transfer from a non-sanctioned Russian bank: these banks retain correspondent relationships, and with full source-of-funds documentation the payment clears, most smoothly into the UAE and Thailand. Second, payment from the buyer's own account abroad, held in the buyer's name: accounts in the UAE, Armenia, Kazakhstan and other jurisdictions, where the funds arrived legally and are documented, are accepted by receiving banks under standard review. Third, funds already outside Russia: proceeds of foreign business, asset sales or inheritance, with documentation of the source.

On cryptocurrency, our position is deliberate: we do not recommend it as a payment channel. Even where crypto settlement is technically possible, the source of converted funds is scrutinised more intensively than a bank transfer, some banks refuse converted amounts outright, and for a Russian client a crypto channel adds sanctions and tax exposure rather than removing it. Advisors should also flag the Russian side: the currency-control rules of the Russian Federation on residents' foreign accounts and transfers are a separate compliance layer that belongs with a Russian-qualified advisor before the transaction.

Dual citizens and EU residents

Everything above about EU caps concerns Russian citizens without European status. Article 5b(3) of Regulation 833/2014 expressly exempts from the EUR 100,000 cap anyone who holds citizenship of an EU or EEA member state or Switzerland, or a temporary or permanent residence permit in one of those countries. For this category, European bank accounts operate without the sanctions ceiling, which makes a Greek or Cypriot purchase financially feasible in the ordinary way.

Residency is subtler. The Greek suspension is framed by Russian citizenship, so whether a dual citizen can apply on the second passport is not a technicality but a case-specific legal question for a Greek immigration lawyer, answered before any money moves. Cyprus does not block Russian applications, and for dual citizens and EU residents it is in practice the most workable European route of those covered here. There is no universal answer, and any promise of one should put an advisor on guard.

Our position: legal routes only

We do not help anyone circumvent sanctions. That is an operating principle, not a disclaimer: we do not build chains through nominees, we do not advise splitting payments under thresholds, and we do not take on transactions where the full origin of funds cannot be shown to a bank. Sanctions regimes change and guidance is updated, so for every individual case, especially one touching the EU, dual citizenship or corporate structures, we recommend specialised sanctions and legal advice before the first payment.

Within those limits the working space remains large. The UAE and Thailand are full, open markets with functioning banking channels and clear procedures, and that is where our practical work with Russian-speaking clients is concentrated: district and asset selection, developer verification, transaction structure and support through registration. Where a client's situation includes European status, we will say honestly which route is real and which is not, before time and money are spent.

Frequently asked questions