The 2022 Relocation Wave
- Armenia: 20,000–30,000 Russian IT specialists, peaking in mid-2022. Most have stayed or integrated; Yerevan's IT sector grew significantly.
- Kazakhstan: 15,000–20,000 Russian tech workers. Almaty and Astana absorbed most of them.
- Georgia: 50,000–80,000 Russians entered at peak. By 2025, approximately 60–70% have moved to other countries. Those who stayed make up a meaningful share of Tbilisi's IT workforce today.
These are, on average, senior engineers with 8–15 years of experience at companies like Yandex, Sber, VK, and various Russian product companies. Many have strong records in backend, mobile, and data engineering. European companies that found them on LinkedIn or through referrals are asking the right question: how do we hire them legally?
The Key Legal Question: Residency vs Citizenship
Citizenship is the country that issued your passport. A Russian citizen holds a Russian passport.
Tax residency is the country where you pay income tax — typically where you live and work. A developer who moved to Yerevan in 2022, registered as a sole trader (ЧП — individual entrepreneur) in Armenia, and pays 10% flat Armenian income tax on their invoices is an Armenian tax resident. Their citizenship is irrelevant to their tax obligations and to your compliance.
Sanctions are jurisdiction-based, not citizenship-based. EU Council Regulation 833/2014 (and its subsequent amendment packages) restricts transactions with entities domiciled in Russia and specific named individuals on the EU consolidated sanctions list. They do not restrict hiring a Russian national who is domiciled and tax-resident in Armenia. The same principle applies under US OFAC rules: the SDN list contains named persons — not nationalities.
What EU and US Sanctions Actually Say
EU (Council Regulation 833/2014 et seq.)
- Prohibits purchase of services from entities in Russia
- Prohibits transactions with listed persons (EU Consolidated Sanctions List)
- Does NOT prohibit hiring services from individuals domiciled in third countries (Armenia, Kazakhstan, Georgia are not sanctioned)
US OFAC (Office of Foreign Assets Control)
- SDN List: specific named individuals and entities — blocked regardless of location
- Non-SDN lists: sectoral sanctions on specific Russian industries
- Routine transactions with Russian nationals outside Russia are generally permissible
If a developer is not on any SDN list and is domiciled outside Russia, hiring them through an EOR in a non-sanctioned country is permissible under both EU and US frameworks.
NexoStaff KYC and Screening Process
Every developer is screened against the following before onboarding:
- 1EU Consolidated Sanctions List (EU Council decisions and UN Security Council resolutions)
- 2OFAC SDN and Consolidated Sanctions List
- 3UN Security Council Consolidated List
- 4HM Treasury UK Financial Sanctions
- 5Residency verification — tax registration documents, local ЧП/ИП registration, utility/lease proof of address
- 6Crypto wallet screening — for developers receiving any crypto-denominated payments
Developers who remain tax residents of Russia, or who appear on any designated persons list, are not onboarded. This is a hard constraint. Screening is done at onboarding and reviewed annually.
The Hiring Structure
Your company (German GmbH / Spanish S.L.)
↓ monthly EUR invoice (B2B vendor payment)
NexoStaff (Spanish S.L. or German GmbH)
↓ civil services agreement
Developer — registered as ЧП in Armenia / ИП in Kazakhstan
tax resident of Armenia / Kazakhstan- Your counterparty is NexoStaff — an EU-registered entity. You pay a EUR invoice for software development services.
- No direct transaction between your company and the developer.
- This removes the direct employer-employee relationship (no PE risk) and the compliance burden of running your own KYC.
What NexoStaff Does NOT Cover
We cannot onboard a developer who:
- Is still a tax resident of Russia
- Has not yet completed local registration (ЧП in Armenia / ИП in Kazakhstan, Azerbaijan, or Georgia)
- Appears on any sanctions list
- Plans to work primarily from Russia (travel is fine; tax residency is the test)
We do not:
- We do not help developers relocate.
- We do not provide legal opinions on individual sanctions scenarios. We are happy to provide documentation for your compliance officer.
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