Pursuant to changes in the Russian law, Russian citizens who as of August 4, 2014 hold a foreign citizenship or right of permanent residence in another country, must notify the Russian authorities of this by October 2, 2014.

Russian citizens must notify the Russian Federal Migration Service (FMS) if they hold:

• foreign citizenship,
• permanent residence permit or
• other valid document confirming the right of the Russian citizen to permanently reside in a foreign state.

There is no need to notify the FMS regarding a visa (work, student, investor, entrepreneurial, spousal, child, etc.) and permit for temporary residence in a foreign state that is issued based on such visa.

Russian citizens residing abroad permanently are relieved of the above obligation. Permanently residing abroad means persons who have been de-registered in Russia and have a relevant mark in their passport, along with an address departure sheet. At the same time, if a Russian citizen resides abroad year round, but has not been de-registered in Russia, they must still send the notification.

In respect to children under 18 with a Russian citizenship, the notification must be submitted by their parents. The notice must be sent even if the parents themselves are citizens of only one state and do not have permanent residence rights in a foreign state.

Russian citizens who as of August 4, 2014 have citizenship or permanent residence right in another country, but will be abroad up to the time the deadline for filing notifications expires, can file the notification shortly after arriving in Russia.

In the event citizenship or permanent residence right in a different country is obtained after the law enters into force on August 4, 2014, the Russian citizen must file the notification within 60 days from the day he acquires the foreign citizenship or receives the document on the permanent residence right in a foreign state.

The law does not place restrictions on obtaining a second citizenship.

Therefore, Russian citizens who are not registered at a place of residence in Russia are relieved of the obligation to file a notification on holding citizenship of a foreign state or right to reside in another state.

Persons registered at an address in Russia  who hold citizenship of a foreign state or the right to reside in another state, must notify the Russian authorities of this, or de-register at the place of residence in Russia. If a person wishes to de-register, he can file an application in free form with the registration recordkeeping authorities, indicating the country to which he is moving. The person is then deregistered, an appropriate mark is made in his passport and he is issued an address departure sheet.

A Russian citizen can also de-register while abroad, by drawing up an application, notarizing his signature, adding an apostille and arranging a notarized translation. The signature can also be certified in a consular section. De-registration is confirmed by a stamp being placed in the passport. If the person being de-registered is abroad, his representative by power of attorney can provide the Russian citizen’s passport to the authorized body. The passport will be stamped and returned to the representative.

Submitting the notification

FMS Order No.450 dated 28.07.2014 establishes the form and procedure for filing notifications on Russian citizens holding citizenship of a foreign state or other valid document confirming their right to permanently reside in another state. The said act and forms of notifications are available on the FMS web site. The notification form is available here.

In order to file a notification, the Russian citizen or his representative needs to visit the FMS territorial body at the place of his permanent residence or any post office on the territory of the Russian Federation. There is no option for sending a notification by post from a different country, through an embassy or consulate, by email or via official web sites.

If a Russian citizen with citizenship or right of permanent residence in another country does not have permanent registration on the territory of the Russian Federation, he should send the relevant documents by post to the FMS body at the place of his actual stay.

The notification is to be filed in two copies in person or through a lawful representative; a representative by power of attorney cannot file the notification.

Along with the notification, simple copies of the following documents must be attached:

• Russian passport or other ID of the person on Russian territory (diplomatic passport, service passport, ID (military ID, birth certificate));
• foreign passport or other document confirming the second citizenship or right of permanent residence in a foreign state.

There is no need to attach notarized copies or translations of the said documents.

When a notification is filed, the FMS or post office official confirms its acceptance with his signature and returns a tear-off slip to the person filing.

Liability for not filing a notification

Please note that not fulfilling the obligation to notify of the acquisition of a foreign citizenship now entails criminal liability. Those who fail to fulfill this obligation face a fine of up to 200,000 rubles or in the amount of the convicted person’s income for up to one year or up to 400 hours of mandatory works.

In addition, breach of the timeframes for filing, inaccurate (incomplete or false) information entails an administrative fine from 500 to 1000 rubles.

We recommend monitoring information of the Federal Migration Service of the Russian Federation. The FMS web site address is http://www.fms.gov.ru

Lawyers of Capital Legal Services will be glad to answer your questions tied to the procedure for filing a notification of dual citizenship in St. Petersburg by phone at +7 812 346 7990 and in Helsinki by phone at +358 20 7346 490.

Vladislav Zabrodin, Managing Partner at Capital Legal Services, live on the air at Radio Sputnik (Helsinki, Finland), answered questions from the audience concerning notification regarding a second citizenship or permanent residence permit of Russian citizens permanently residing abroad. Listen to the interview>>