Important additions regarding the reduced period during which foreign nationals must register with the migration authority between 1 june and 12 july 2017

As we previously informed you, in accordance with the Russian President's Decree No. 202 ‘On particular aspects of applying increased safety measures during the 2018 FIFA World Cup and 2017 FIFA Confederations Cup in the Russian Federation’ dated 9 May 2017 (the “Decree”), foreign nationals arriving in Kazan, Moscow, St Petersburg and Sochi between 1 June and 12 July 2017, must be registered with the migration authority by the hosting party (the employer or the owner of residential premises) within 24 hours after such foreign nationals have arrived in the above cities.

A similar rule will be in effect in the cities of Volgograd, Ekaterinburg, Kazan, Kaliningrad, Moscow, Nizhny Novgorod, Rostov-on-Don, Samara, St Petersburg, Saransk and Sochi between 25 May and 25 July 2018.

Since the Decree has given rise to many practical questions, below we share with you the clarifications received from senior officials of the Main Directorate for Migration Matters of the Russian Ministry of Internal
Affairs.

• The requirements set out in the Decree apply to all foreign nationals including highly qualified specialists (HQS) who arrive in the cities specified above during the specified periods.
• Foreign nationals who arrive in Kazan, Moscow, St Petersburg and Sochi for a period of less than 24 hours, do not need to register with the migration authority.
• Foreign nationals who arrive in the cities specified above between 1 June and 12 July 2017 must register with the migration authority within 24 hours of the time of their arrival, including if this time falls on a weekend or a public holiday. For this purpose, regional units of the Ministry of Internal Affairs will work every day including on weekends and public holidays.
• The Decree does not provide that registration with the migration authority can be performed through socalled Multifunctional Centres at which a range of state services are offered. Even so, officers of the Main Directorate for the city of Moscow of the Russian Ministry of Internal Affairs will work at such Multifunctional Centres in Moscow and these officers will be able to register foreign nationals with the migration authority.

In practice, when a foreign national is registered with the migration authority, some regional units of the Ministry of Internal Affairs require a certificate confirming that the company is indeed located at the address specified. Senior officials of the Main Directorate for Migration Matters of the Russian Ministry of Internal Affairs have confirmed that current rules do not contain a requirement that such certificate be provided and, therefore, this requirement is unlawful.

With respect to foreign nationals who arrived in the cities specified above before 1 June 2017 and have not yet registered with the migration authority, according to oral explanations of officers of the Ministry of Internal Affairs, such foreign nationals should be registered with the migration authority promptly, without waiting until the 90-day period (for HQS) or the 7-day period (for other foreign employees) expires.

Please note that if a foreign national stays at a hotel, boarding house or a sanatorium, the obligation to register that foreign national with the migration authority should be performed by the hotel, boarding house or sanatorium in question.

Implications for companies

Taking into account the serious consequences that violating the requirements of migration control may entail both for foreign nationals themselves and for those hosting them, companies should be especially prudent in tracking the movement of their foreign employees during the above periods when the sports events will be staged and should ensure that such foreign nationals are registered with the migration authority in time.

We recommend that you find out in advance the working schedule of officers of regional units of the Russian Ministry of Internal Affairs who will be responsible for registering foreign nationals with the migration authority, as well as whether officers of the Main Directorate for Migration Matters of the Russian Ministry of Internal Affairs will be available in the particular Multifunctional Centre in Moscow at which your company intends to register foreign nationals with the migration authority.

Help from your advisers

Pepeliaev Group's experts stand ready to provide all necessary legal assistance relating to migration law, including the registration of foreign citizens with the migration authority, and offer other services with regard
to migration.