From Astana to Mauritius: five financial havens for business "relocation" from the UAE

The war with Iran has threatened the UAE's image as one of the safest financial centers in the world. Local authorities have so far characterized investors' behavior as "cautious" and asked not to confuse "short-term disruptions with structural weakness". Alexey Myagchenkov, partner at PGP Tax&Legal, writes in his column for Oninvest about the current mood among investors with Russian roots in the UAE and what jurisdictions they are studying in case the situation worsens.

Relocation options

The UAE business community is now working quietly to assess the risks and build strategies for sustainability. So far, the Emirati banking system is performing well: banks are operating normally, payments are going through without any noticeable changes. We can see this in ourselves and in our clients. Public services in the UAE are also working stably. It is difficult to shock or frighten Russian businesses in general, we only see that our clients have become interested in how to ensure the sustainability of corporate and business processes in case of possible disruptions.

One way is a change of jurisdiction (redomiciliation). It must be said that the interest of companies is still of a research rather than practical nature. As a rule, clients are not so much interested in an immediate "move" as in the very possibility of transferring a company from the UAE to another jurisdiction. Here it is important to take into account that there are many free zones in the UAE, and each has its own rules for the establishment, operation, liquidation and deregistration of companies. Therefore, the issue of "moving" a company should always be analyzed at the level of a specific zone and a specific registrar, and not abstractly "for the UAE".

"Extremely difficult, if not impossible."

Clients are usually interested in three practical questions: in which jurisdictions it is feasible to move a company today, how long it will take and how much it will cost. Investors are characterized by a desire to work in jurisdictions with a predictable corporate environment based on common law and a desire to reduce compliance risks for structures with beneficiaries from CIS countries.

In practice, the issue is often not even the corporate "relocation" per se, but the banking infrastructure. Opening a bank account and further servicing of the company usually becomes the main issue. What is important is not that opening accounts for companies with Russian or, for example, Belarusian beneficiaries is "extremely difficult, if not impossible", but that the probability of successful account opening depends significantly on the bank, ownership structure, citizenship composition, tax residency of beneficiaries, origin of funds, business model and geography of settlements. Even the presence of a second citizenship alone does not remove compliance issues. Therefore, when choosing a new jurisdiction, the banking track should be analyzed in parallel with the corporate track.

Top 5 alternatives to the UAE

At the host jurisdiction level, legal mechanisms are generally in place, but not all work in the same way. Clients ask questions mainly about the following five company jurisdictions.

1. Mauritius

In terms of corporate regulation, Mauritius demonstrates a rather calm and pragmatic approach to the registration of companies with beneficiaries who are Russian citizens. Provided that the company is sanction-free (the beneficiary is not on sanctions lists and is not related to the state), there are usually no significant obstacles to registering the company. In terms of opening accounts, banks are moderately cautious.

Mauritius supports redomiciliation. The country has a number of double tax treaties, including with jurisdictions of interest to CIS investors. Mauritius was removed from the FATF gray list in 2024, which improved its reputation, although the compliance culture of local banks has tightened markedly since then.

2. Cyprus

The legislation of Cyprus allows "relocation" of foreign companies to Cyprus. From a legal point of view, it is a working corporate jurisdiction with an understandable regime. But for clients with Russian roots, Cyprus may turn out to be one of the most sensitive jurisdictions in terms of sanctions compliance, KYC (client due diligence) and subsequent banking support. Therefore, it would be too bold to say that there are no significant obstacles for such clients. It is more correct to say this: formal corporate mechanisms exist, but their practical implementation may be significantly complicated by compliance checks, including at the stage of incorporation or account opening.

It should also be taken into account that Cyprus is a member of the European Union and fully applies EU sanctions against Russian individuals and organizations. The double taxation treaty between Russia and Cyprus has been denounced. For structures where Russian beneficiaries retain economic ties with Russia, the Cyprus route is likely to create more problems than it solves.

3. the International Financial Center Astana (IFCA)

MFCA is by no means the most popular jurisdiction, it is relatively young, and some peculiarities may be associated with this. But now Astana looks like one of the pragmatic options, primarily due to the legal environment (English law, regulator AFSA) and the presence of a working banking infrastructure in Kazakhstan.

MFCA supports redomiciliation: the corporate mechanism generally follows the ADGM (Abu Dhabi Financial Center) model. Kazakhstan is moderate to Western sanctions, and the banking system is generally more loyal to CIS clients than in most other jurisdictions.

But even here, one should not create exaggerated expectations: the existence of a banking system does not automatically mean comfortable settlements with Russia or absence of questions from correspondent banks and compliance services. Secondary sanctions are a real factor: Kazakhstani banks are increasingly taking into account the risk of being subject to secondary restrictions when servicing clients with Russian beneficiaries. Therefore, for clients considering MFCA, it is correct to speak not about "unimpeded" settlements, but about a potentially more flexible, but still sensitive to sanctions factors, route.

4. Singapore

Singapore provides for the regime of transfer of a foreign company with retention of legal personality (inward-redomiciliation). In terms of compliance, the country adheres to an independent regime, but in practice, Singapore banks are traditionally conservative with regard to clients with Russian beneficiaries. Opening an account is possible, but requires careful preparation: the origin of funds, business model and geography of settlements will be analyzed in detail.

5. Hong Kong

Hong Kong has had an inward-mediated regime in place since Ma 23, 2025. The country operates under its own sanctions regime. As a rule, the registration of a company goes without significant difficulties. However, the main difficulty is banking: Hong Kong banks have tightened KYC procedures in recent years, and for companies with Russian beneficiaries, opening an account may require significantly more time and effort than the corporate procedure itself. Here, the issue of opening bank accounts should be worked out before deciding to change jurisdiction.

This article was AI-translated and verified by a human editor