What is the change? The Russian government has followed through on a ban of visa-free travel with Turkey and a suspension of new work permits for Turkish nationals as of Jan. 1, and announced additional new economic restrictions.

What does the change mean? The restrictions do not require Turkish nationals currently working in Russia to leave the country; however, companies should be aware that Turkish employees and assignees may have difficulties returning to Russia and may be refused entry. Renewal of work permits for Turkish nationals will also be difficult. With suspension of the visa waiver, Turkish nationals who do not hold a residence permit or temporary residence permit are now required to obtain a visa at a Russian consulate.

  • Implementation time frame: Immediate and ongoing.
  • Visas/permits affected: Work permits, visitor visas.
  • Who is affected: The restrictions affect Russian companies hiring Turkish employees, Turkish business and tourist travelers to Russia, Turkish companies and organizations in designated industries doing business in Russia, and Russian companies under the control of Turkish citizens.
  • Impact on processing times: Turkish citizens who previously relied on visa waivers should allow time to obtain a visa before travel.
  • Business impact: Russian companies cannot hire new Turkish employees under the current restrictions, may not be able to renew work permits for current Turkish nationals, and should consider alternatives.

Background: Relations between the two countries have been strained since late November when Turkey shot down a Russian fighter jet which it claimed had violated its airspace. Some of the restrictions were announced in December. The following restrictions took effect Jan. 1, including:

  • Russian companies are banned from hiring new Turkish employees.
  • Visa waivers for Turkish citizens are suspended.
  • Turkish companies operating in Russia (or Turkish citizens heading Russian companies) in certain industries are banned. Sectors include engineering, construction, hospitality and others.
  • Chartered air transportation between Russia and Turkey is banned, Russian tourist companies are banned from selling tours to Turkey, and certain agricultural imports are banned except for personal use.

BAL Analysis: Companies should consider contingency planning in the event that Turkish employees are not allowed to re-enter Russia or their work permits are not renewed.

This alert has been provided by the BAL Global Practice group and our network provider located in the Russian Federation. For additional information, please contact your BAL attorney.

Copyright © 2016 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.

IMPACT – MEDIUM

What are the changes? The Christmas and New Year’s holidays will close many government and private offices around the world for at least two days, with many countries observing longer holiday periods at the end of the year and the beginning of 2016.

What does the change mean? Employers should file as early as possible for visas, work permits and other services to avoid delays during the holiday closures.

  • Implementation timeframe:Now through January.
  • Visas/permits affected:All visas and permits.
  • Who is affected:Companies needing immigration, labor and other services from government offices.
  • Impact on processing times:Processing will be slower due to office closures, shorter business hours and reduced staff.
  • Business impact:Holiday delays should be factored into business schedules and assignments.
  • Next steps:Companies should finalize and submit applications as soon as possible.

Background: Most countries will observe Dec. 25, 2015, and Jan. 1, 2016, and many countries will also reduce business hours in the days surrounding Christmas and New Year’s Day.

Some countries may close for extended periods in the coming months. Russia observes a New Year holiday and Orthodox Christmas Jan. 1-10, with offices reopening Jan. 11. China does not mark Dec. 25 as an official public holiday, but will close Jan. 1-3 for the New Year’s holiday and Feb. 7-13 for the Chinese lunar New Year. South Africa will close offices for varying periods between Dec. 22 and Jan. 11. Mexico’s immigration services will be closed for three weeks Dec. 18 – Jan. 6.

BAL Analysis: Companies should anticipate slower processing for visas, residence permits and work permits from now until offices reopen in early January and they should plan to file immigration-related applications as soon as possible.

This alert has been provided by the BAL Global Practice group. For additional information, please contact your BAL attorney.

Copyright © 2016 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.

IMPACT – HIGH

What is the change? Russian authorities have said they will suspend the country’s visa-free travel agreement with Turkey and stop issuing work permits to Turkish nationals beginning Jan. 1.

What does the change mean? The announcement comes after Turkey shot down a Russian fighter jet Nov. 24 in circumstances that remain disputed. The imposition of a visa regime and the cessation of work permits would have dramatic impacts on Turkish nationals traveling to Russia or seeking work there.

  • Implementation time frame: Russian officials have said the visa-free scheme will end and work permits will no longer be issued to Turkish nationals beginning Jan. 1.
  • Who is affected: Turkish nationals traveling to, or seeking work in, Russia.
  • Business impact:Business ties between the two countries are strained after Russia announced sanctions on Turkey, including the changes related to visas and work permits.
  • Next Steps:BAL will continue to monitor immigration-related fallout between Russia and Turkey, including how the new rules will develop in practice.

Background: Russia and Turkey have had close business ties and been important trade partners for years, but relations are near a boiling point after the Nov. 24 incident. Russia has said it will suspend a visa-free travel agreement between the two countries that currently provides for stays of up to 30 consecutive days without a visa. Russian authorities also say they intend to stop issuing work permits to Turkish nationals beginning Jan. 1. The Turkish government has not yet issued any formal statements regarding travel or immigration restrictions on Russian nationals.

BAL Analysis: While Russia has announced that it will impose a visa regime and stop issuing work permits to Turkish nationals, the Federal Migration Service has provided no clear indication as to how travel and immigration requests will be handled in practice after Jan. 1.

Turkish nationals traveling to Russia between now and Jan. 1 are advised to keep documents confirming the purpose of their visit, such as letters from the hosting party or a hotel confirmation. Turkish travelers are likewise advised to keep their passport, migration card and (if applicable) work and resident permits with them at all times.

At this point, it is still possible for Turkish nationals to apply for Russian work permits, but employers should prepare for the possibility that new applications may not be approved. Turkish nationals currently in Russia may not want to leave the country even if they have valid immigration documents, as there is no clear instruction from Russian authorities about how Turkish nationals would be treated upon trying to re-enter the country.

As it is an ongoing and developing situation, travelers are advised to contact their BAL representative for the latest update prior to travel.

This alert has been provided by the BAL Global Practice group and our network provider located in Russia. For additional information, please contact your BAL attorney.

Copyright © 2016 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.

IMPACT – MEDIUM

What is the change? Employers are required to file reports by Oct. 30 on the salaries paid to highly qualified specialists during the third quarter of 2015 (July through September).

What does the change mean? The reports are required every quarter, and employers must meet the minimum salary payment level by the end of each quarter.

  • Implementation time frame: Oct. 30 is the deadline.
  • Visas/permits affected: Work patents and work permits for highly qualified specialists.
  • Who is affected: Companies that employ highly qualified specialists.
  • Business impact: Businesses face fines if they do not file the salary report on time.
  • Next steps: Employers should prepare to file the report by the end of the month.

Background: Employers must meet quarterly salary thresholds and report them each quarter. Employers should make sure they have paid all required salaries by the end of each quarter. Companies that do not comply with the rules may be fined 400,000 to 1 million rubles. Individual company officers may also be fined 35,000 to 70,000 rubles.

BAL Analysis: Companies are reminded to submit the salary notifications no later than Oct. 30 and observe the mandatory salary minimums.

This alert has been provided by the BAL Global Practice group and our network provider located in the Russian Federation. For additional information, please contact your BAL attorney.

Copyright © 2016 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.

IMPACT – MEDIUM

What is the change? Under a new rule, Russia has set a deadline of seven working days for employers to file for corrections to work permits when foreign employees’ names or passport information have changed.

What does the change mean? The new rule adds urgency when employers must file a correction to a work permit; late filing will constitute an administrative violation subject to fines.

  • Implementation time frame: Immediate.
  • Visas/permits affected: Standard work permits, highly qualified specialist work permits and patents.
  • Who is affected: Foreign employees and highly qualified specialists.
  • Impact on processing times: The change does not affect processing times, but it does affect the deadline for filing.
  • Business impact: Employers and their foreign employees have a new deadline that did not exist before.
  • Next steps: Foreign employees who require a correction to their work permit should apply as soon as possible.

Background: The rule applies to foreign workers whose name has changed or whose passport information that appears on their work permit (passport number, name) has changed. Previously, the law did not impose a deadline to file for work permit corrections. Under the new rule, those who fail to file within seven working days will have an administrative violation on their record and will be subject to a fine of 4,000 to 5,000 rubles (about US$70 to $90).

The rule officially took effect June 30. Employers who have not yet filed for corrections should do so without delay.

BAL Analysis: Foreign employees should review their work permits and patents and file for corrections if they are required. BAL can assist in the process.

This alert has been provided by the BAL Global Practice group and our network provider located in Russia. For additional information, please contact your BAL attorney.

Copyright © 2016 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.

IMPACT – MEDIUM

What is the change? Russian employers have until July 31 to report the salaries of highly qualified specialists during the second quarter (April 1 to June 30).

What does the change mean? Employers who fail to report salaries face the possibility of steep fines.

  • Implementation time frame: Now until July 31.
  • Visas/permits affected: Work visas.
  • Who is affected: Companies employing highly qualified specialists.
  • Business impact: Companies that violate reporting requirements face fines ranging from 400,000 (about $7,000) to 1 million rubles ($17,750). Company officials may also be fined between 35,000 (about $620) and 70,000 rubles ($1,250).
  • Next steps: Salary reports may be submitted in-person or mailed to the Federal Migration Service.

Background: The quarterly salary reporting is not new, but under a law passed earlier this year employers must now meet salary minimums on a monthly, rather than yearly, basis. A new form has also been introduced that must be used when reporting salaries.

BAL Analysis: In preparing salary notifications, employers should make sure they are observing the new monthly minimum salary requirements.

This alert has been provided by the BAL Global Practice group and our network provider located in the Russian Federation. For additional information, please contact your BAL attorney.

Copyright © 2016 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.

IMPACT – MEDIUM

What is the change? The Russian Federal Migration Service is introducing electronic letters of invitation (e-LOIs) into the work visa process.

What does the change mean? The FMS will transmit a letter of invitation in digital format directly to the appropriate consulate, eventually making the process more efficient for companies applying for work visas for foreign highly qualified specialists.

  • Implementation time frame: Immediate and ongoing. The testing phase is expected to be completed by mid-July.
  • Visas/permits affected: Work visas.
  • Who is affected: Employers applying for work visas.
  • Impact on processing times: Currently, processing for the electronic letter takes one day longer than for a paper LOI, but the FMS is working to improve the speed. It is hoped that when the system is finalized, applicants will be able to receive their approved letters on the same day they are issued.
  • Business impact: The change will speed up processing by eliminating paper mailings.
  • Next steps: The FMS in Moscow and other cities has begun issuing electronic letters, but the agency is still testing its equipment and training its officers. With the digital procedure, the letter of invitation will be sent directly from the FMS to the consulate. As such, the current system will not allow the applicant to review the letter for errors before it is sent to the consulate.

Background: Foreign highly qualified specialists who submit an initial visa application must obtain a letter of invitation from Russian migration authorities approving the application before they can obtain the visa from a Russian consulate. FMS is offering electronic letters of invitation for business and work.

BAL Analysis: Applicants may now opt for electronic transmission of letters of invitation in Moscow and other jurisdictions that have implemented the new procedure, but applicants should be aware that the system is still in the testing phase and there is a risk of complications if there is an error in the letter.

This alert has been provided by the BAL Global Practice group and our network provider located in the Russian Federation. For additional information, please contact your BAL attorney.

Copyright © 2016 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.

IMPACT – MEDIUM

What is the change? Russia has begun accepting 2016 quota applications from companies aiming to secure foreign labor.

What does the change mean? If they have not already done so, employers should begin preparing applications to fill foreign-labor allocations for 2016.

  • Implementation time frame:The application period opened April 9. Deadlines are July 1 for 2016 quota applications and Sept. 1 for 2015 “correction” applications.
  • Visas/permits affected:Standard work permits and work visas for visa-country nationals.
  • Who is affected:Companies seeking to hire non-Highly Qualified Specialists and non-CIS nationals for 2016.
  • Impact on processing times:The process may take several months; applications are expected to be approved toward the end of 2015 or the beginning of 2016.
  • Business impact:Companies that do not file on time, or do not file according to new rules, could lose the ability to secure foreign workers for 2016.
  • Next steps:Companies must obtain a login and password for the Migrakvota website and complete an online application form, which they then submit electronically. Paper applications are then submitted on specific dates on which they are accepted.

Background: The application process for standard work permits has changed considerably. The CIS standard work permit process has been abolished; CIS nationals now apply for work patents, which do not require a quota. Quotas are also not required for HQS workers, regardless of nationality. The overall number of workers who will be admitted through the quota system for 2016 will likely be announced later this year.

Additional new rules require businesses to guarantee medical insurance and housing for foreign workers who are given jobs through the quota system. Russian officials have said a company’s guarantee of medical insurance and housing can be made in a single “guarantee letter” submitted with the application.

After companies have submitted applications electronically, they are required to file paper applications. Paper applications were accepted during a two-week period earlier this month and can be filed May 17-22 or June 15-30. Correction applications for the 2015 quota can be submitted July 13-24 and Aug. 10-31.

BAL Analysis: Russian companies aiming to secure foreign labor for 2016 should take note of the application dates and new rules requiring them to guarantee health insurance and housing accommodations.

This alert has been provided by the BAL Global Practice group and our network provider located in Russia. For additional information, please contact your BAL attorney.

Copyright © 2016 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.

IMPACT – MEDIUM

What is the change? Employers must report the first quarter salaries of highly qualified specialists no later than April 30.

What does the change mean? While this is a regular quarterly requirement, employers should remember that under a new law, they must meet salary thresholds that are calculated monthly, not yearly.

  • Implementation timeframe: Now until April 30.
  • Visas/permits affected: Work visas.
  • Who is affected: Companies employing highly qualified specialists.
  • Business impact: Companies should track salaries on a monthly basis to comply with the new rules and to make reporting easier.
  • Next steps: Employers should plan to file the salary notifications before the end of the month. Failure to do so will incur government fines.

Background: April 30 is the deadline for companies to report salaries paid to foreign highly qualified specialists during the first quarter, Jan. 1 through March 31.

Employers should also note that under new rules, HQS salaries must meet thresholds each month, rather than on a yearly basis. For example, employers must show that they are paying a 2-million-ruble annual minimum salary proportionately by paying the employee 167,000 rubles per month.

Companies that violate salary reporting requirements face administrative fines that range from 400,000 to 1 million rubles. Individual company officers may also be fined 35,000 to 70,000 rubles.

BAL Analysis: Companies are encouraged to work with their BAL attorney to prepare the salary notifications and observe the new monthly minimums.

This alert has been provided by the BAL Global Practice group and our network provider located in Russia. For additional information, please contact your BAL attorney.

Copyright © 2016 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.

IMPACT – MEDIUM

What is the change? Russia is requiring foreign nationals applying for highly qualified specialist work permits to have at least 3 ½ years remaining on their passports.

What does the change mean? Foreign nationals who have less than 3 ½ years on their passports and who are in need of an HQS work permit should renew their passports as soon as possible.

  • Implementation timeframe: The change went into effect the week of March 23.
  • Visas/permits affected: Work permits for highly qualified specialists.
  • Who is affected: Foreign nationals applying for HQS work permits, including those applying for extensions.
  • Impact on processing times: Processing times may be significantly delayed if applicants do not have 3 ½ years remaining on their passports.

Background: Russia’s recent move to enforce a 3 ½-year passport rule may be an effort to limit the number of applications it processes. HQS work permits are valid for three years; by requiring 3 ½ years of passport validity, Russian authorities can cut down on the number of foreign nationals who need to renew HQS work permits because of an expired passport.

BAL Analysis: Foreign nationals applying for HQS work permits should check their passports and renew them if necessary.

This alert has been provided by the BAL Global Practice group and our network provider located in Russia. For additional information, please contact your BAL attorney.

Copyright © 2016 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.