Bryan Cave Leighton Paisner (Russia) LLP advises that, on 27 June 2018, the Russian President signed a new federal immigration law1 (the Law) amending a number of requirements on registration of foreign citizens. The Law came into force on 8 July 2018.
Russian entities normally act as host organisations for their foreign employees or colleagues arriving on a business visit. In these instances, they are to register the arriving foreign citizens at their location.
The key amendment introduced by the Law is that it cuts back considerably on the list of instances when an entity may register foreign visitors at its own address.
Under the new rules, an entity may only register a foreign citizen at its location for immigration record purposes if the visiting person actually lives at the entity’s address or on its premises that have no address (in a building or structure), including temporary ones.
In all other instances, i.e., when the foreign citizen does not intend to reside at the location of the entity, immigration registration is to be effected:
at the residential premises where the person actually lives, or
at the hotel or other hotel organisation, spa or holiday centre, boarding house or other premises where the person actually lives2.
We believe that the new rules introduced by the Law might somewhat complicate immigration recording of foreign citizens. Being unable to register a visiting foreigner at its own location, an entity will most likely be compelled to engage the owner of the premises (apartment, etc.) where the person lives for this purpose. Consequently, all registration actions will need to be taken by such owner.
Bryan Cave Leighton Paisner (Russia) LLP will continue monitoring law enforcement trends in the sphere of immigration law requirements and keep you informed of all material aspects of their practical implementation, as well as other essential developments.
1Federal Law 163-FZ “On amendments to the Federal Law ‘On Immigration Records of Foreign Citizens and Stateless Persons in the Russian Federation’”
2In certain instances, the legislation also allows foreign citizens to be registered at healthcare and social service institutions and organisations effecting criminal or administrative penalty enforcement with respect to the person.
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