
The situation
A new law amending the procedures for foreign nationals’ registration will go into effect on July 8, 2018.
A closer look
- Redefined terms. The new law redefines key terms that affect the registration process.
- Impact.
- Foreign nationals must be registered at their actual place of dwelling and employers can no longer register foreign employees at the company’s address if the employee has housing other than the employer’s location.
- Due to this change, Fragomen and its co-counsel will no longer be able to assist foreign nationals with address registration services.
- Impact.
- Registration obligation transferred to host party. The obligation to complete the foreign national’s registration will be imposed on the host party as opposed to currently, where the burden is on the foreign national. The law defines a “host party” as a Russian national, a permanently residing foreign national, a legal entity, or a branch or representative office of a legal entity who has provided a foreign national with accommodation where they actually dwell.
- Impact.
- Host parties, particularly those residing outside Russia, should be aware of the steps they may need to take, including appearing in person at the local migration agency with all the requisite lease/property ownership and other documents.
- Foreign nationals must still provide their host party with the documents required for registration and must collect the registration document from the host party once the process is complete.
- Impact.
Looking ahead
The new law does not explain if it is necessary for foreign nationals who were previously registered at their company’s address to re-register at their place of actual dwelling. Fragomen will provide an update once this information is provided by state authorities.
This alert is for informational purposes only. If you have any questions, please contact the global immigration professional with whom you work at Fragomen or send an email to [email protected].
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