We advise you of some important changes affecting foreign citizens' stay and residence in Russia in connection with the holding of the 2017 FIFA Confederations Cup football matches.
According to RF Presidential Decree No. 202 on Special Aspects of Taking Enhanced Security Measures during the 2018 FIFA World Cup and the 2017 FIFA Confederations Cup in the Russian Federation dated 9 May 2017 (as amended) (hereinafter the "Decree"), a very strict migration registration procedure for foreign citizens will be introduced in the cities of Moscow, St. Petersburg, Kazan and Sochi during the period from 1 June through 12 July 2017.
The Decree states that registration at the place of stay (or registration at the place of residence) in the above-mentioned cities during the period from 1 June through 12 July 2017 must be handled by the appropriate local authority of the Ministry of the Interior of Russia within 24 hours of the foreign citizen's arrival date at the place of stay (or place of residence).
According to the Decree, it covers almost all categories of foreign citizens, including citizens who need a visa to enter Russia or who don't need a visa to enter Russia, highly qualified specialists and their family members, foreign citizens entering the country for commercial negotiations, tourists, etc. Thus, the time limit for registering almost all foreign citizens at their place of stay (or registration at the place of residence) is being shortened to one day from the date of their arrival.
The Decree does not establish separate rules for those foreign citizens who entered Russia before 1 June. It is possible to conclude from this that foreign citizens who enter Russia before 1 June and who do not have migration registration at their place of stay (or are not registered at the place of residence) must be registered by no later than 1 June.
It should also be noted that the migration registration must be done by a local authority of the Ministry of the Interior of Russia (i.e., it is not permitted to send a notice by Russian Post).
We recommend that you take the following steps in the next few days (i.e., by 1 June):
- Ensure that all of your foreign employees and their family members who have already entered Russia and who are staying in Russia without migration registration get migration registration.
- Make sure in advance that the Ministry of the Interior of Russia office for your district has all the necessary documents about your organization (as otherwise the district offices will refuse to do migration registration of foreign citizens).
- Get information from the Ministry of the Interior of Russia office for your district about (i) how to register someone at their place of stay if the deadline for such registration expires on a weekend (for example, if a foreign citizen has entered the country on Saturday evening and, accordingly, the deadline for migration registration expires on Sunday, which is a non-business day for the migration authority), and (ii) whether it will be a violation if the migration registration is done on the next business day.
The requirements of the Decree do not apply to foreign citizens who are participants in the Confederations Cup, or to representatives of FIFA, subsidiaries of FIFA, confederations and national football associations that are on the FIFA lists.
We also believe that the requirements of the Decree do not apply to citizens of Eurasian Economic Union Treaty member states (Kazakhstan, Belarus, Kirghizia and Armenia) who have come to work, and their family members. The Treaty provides for a 30-day migration registration window for such citizens. If you have citizens from these countries working for you, then we recommend, if possible, clarifying with the Ministry of the Interior of Russia office for your district whether this category of foreign citizens will still enjoy the 30-day window for migration registration during the 2017 FIFA Confederations Cup.
Similarly, the Decree does not apply to foreign citizens whose stay in Russia is subject to the rules established by an international treaty of the Russian Federation (generally, members of international organizations, members of official delegations, employees of foreign embassies, consulates and some other categories of foreign citizens). If an international treaty of the Russian Federation establishes rules other than those provided for by the Decree, the rules of the international treaty will apply.
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