IMPACT – MEDIUM

What is the change? Russian citizens must notify the Federal Migration Service if they have obtained residence permits or citizenship overseas.

What does the change mean? Failure to provide the information may result in severe penalties.

  • Implementation timeframe: Aug. 4.
  • Visas/permits affected: Foreign residence permits and citizenships.
  • Who is affected: Russian nationals who are living overseas on residence permits and citizenships.
  • Impact on processing times: None.
  • Business impact: The requirement creates an additional administrative burden for companies who are employing, or planning to employ, Russian nationals for overseas work.
  • Next steps: The Federal Migration Service must approve the notification form and is expected to provide more guidance on the law prior to the Aug. 4 implementation date.

Background: The new requirement covers all Russian citizens, living inside Russia and abroad, who have obtained foreign residence permits or citizenship. Russians who “permanently reside” outside Russia are not required to provide the notification if they have de-registered their places of residence in Russia or establish that their address abroad is now their formal address. Under the new rule, Russian citizens residing outside Russia with dual citizenships or who have foreign residence permits will be required to file their notification with the Federal Migration Service (FMS) within 60 days of the Aug. 4 implementation date. Thereafter, Russian citizens must notify FMS within 60 days of obtaining citizenship or permanent residence permits abroad. Failure to file may result in criminal fines of up to one year’s salary or 400 hours of compulsory community service; violating the filing requirements may result in fines of 500 to 1,000 rubles. Similar requirements are to be imposed on citizens of Crimea on Jan. 1, 2016.

The notification must contain a stipulated list of required information and documents and must be submitted in specific formats. Notifications must be delivered in person or sent by mail to the address of the regional FMS office. If sent by mail, the notification must be dispatched through the official Russian postal service and bear the stamp of the Post of Russia.

BAL Analysis: This adds a procedural burden on many Russian citizens residing outside the country, who must gather the required documents, send the notification to Russia and then have a representative send it through the Russian postal service. Russian missions abroad will not accept these notifications.

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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