What is the change? Controversial and burdensome requirements that Russian citizens living abroad notify the government of foreign residency or dual citizenship have taken effect; the notification form and deadlines have been set.

What does the change mean? Russian citizens who obtain foreign residency or dual citizenship must notify the Russian government on a prescribed form within specified deadlines in person or personally mail it through the Russian postal service. Failure to do so constitutes a crime.

  • Implementation timeframe:The effective date was Aug. 4.
  • Visas/permits affected:Dual citizenships and foreign residencies.
  • Who is affected:Russian citizens who obtain foreign residency or dual citizenship, except those who are permanently residing abroad.
  • Impact on processing times:
  • Business impact:Russian nationals assigned abroad must adhere to these reporting requirements or risk criminal sanctions.
  • Next steps:Employers should notify Russian nationals of the requirements as soon as possible. Russian nationals affected by the new rules should observe the strict deadlines and procedures for submitting the notification form.

Background: As we reported in June, Russia’s Federal Migration Service (FMS) imposed the new reporting requirements as of Aug. 4.

Since the legislation was introduced, some of the procedures have been detailed and confirmed; however, the FMS has changed some earlier stated submission deadlines.

The prescribed notification form is now available. For purposes of submission deadlines, the FMS is now making a distinction between Russians currently living in Russia and Russians currently living abroad. Russian citizens currently living in Russia who obtain foreign citizenship or residency must notify the FMS within 60 days of the date they receive the citizenship or residency document. For Russian citizens currently living abroad, the FMS has said that their deadline for submitting the notification form is 60 days from the date they return to Russia. (This deadline is not contained in the text of the legislation).

Another controversial provision, which has been confirmed, is the requirement that the notification be made in person to the appropriate local FMS office or personally mailed from within Russia and stamped by the Russian postal service. The FMS has also confirmed that third parties cannot submit notification on behalf of Russian citizens even on the basis of powers of attorney.

Failure to notify the government is a crime punishable by 200,000 rubles, up to one year of the individual’s salary, or community service of up to 400 hours.

Russian nationals who permanently reside abroad are exempt from the notification rules, but they must either obtain a de-registration stamp in their Russian passport or have a document (listok ubitia) listing their foreign address as their permanent address.

BAL Analysis: Russian nationals who fall under the rule should prepare to submit the notification under prescribed procedures within the 60-day deadline. Russian citizens who had foreign citizenship and\or a residence permit before Aug. 4 should notify the FMS office no later than Oct. 3. According to comments given by FMS officials, for Russian citizens currently living abroad the 60-day clock begins when they return to Russia, but note that this interpretation is not reflected in the legislation.

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

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