IMPACT – HIGH

What is the change? All Federal Migration Service offices are enforcing fines on foreign workers who fail to file for a correction to their work permit within seven business days of a change to their passport information.

What does the change mean? Although the fine is not large, it represents an administrative penalty, which counts as a strike under a two-strikes law that imposes a ban on entry for foreigners who incur two administrative violations in a 12-month period.

  • Implementation time frame: Immediate.
  • Visas/permits affected: Standard work permits, highly qualified specialist (HQS) work permits and work patents.
  • Who is affected: Foreign employees and assignees in Russia.
  • Business impact: Foreign workers who miss the deadline must appear in person at the Federal Migration Service office to answer questions and pay the fine, and then again to collect their work permit.
  • Next steps: Foreign employees and assignees planning to update their passport information, including renewal of their passport, should notify their BAL team so we may assist in filing an amendment to their work permit in a timely manner.

Background: The seven-day deadline for reporting passport changes was introduced last year, but not all FMS offices enforced the fines for noncompliance. Now, all FMS offices are enforcing the monetary penalty of 4,000 to 5,000 rubles (about US$50 to $62) before accepting a late filing.

BAL Analysis: To avoid incurring administrative penalties that may have serious adverse consequences in combination with other administrative violations, employers should plan to strictly observe the filing deadline for foreign employees whose passports are renewed or changed.

This alert has been provided by the BAL Global Practice group and our network provider located in the Russian Federation. For additional information, please contact your BAL attorney.

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