High alert mode in Moscow because of the coronavirus—what to do?

In connection with the threat of the spread of coronavirus in Moscow, the Mayor of Moscow adopted a decree on the introduction of high alert status on March 5, 2020. The document introduces additional obligations for persons arriving from countries with an unfavorable situation with the spread of coronavirus infection, as well as for employers operating in the city of Moscow.

Russia also has a restriction on the entry of Chinese citizens and a ban on crossing the land border and air links between Russia and China that is valid until April 1. This period may be extended. In addition, on February 28 and March 1, Russia temporarily limited flights to Iran and South Korea, respectively.

What are residents of the Russian capital obliged to do?

Citizens arriving in Russia from countries where cases of coronavirus are registered are required to:

  • Inform the authorities about their return and places and dates of stay in countries with an unfavorable situation with the virus. Contact information the Moscow city hotline at
    +7 (495) 870-45-09.
  • Ensure self-isolation at home for a period of 14 days upon return from China, South Korea, Italy, Iran, France, Germany, and Spain, or other countries with an unfavorable situation with coronavirus infection. For these purposes, they can get a sick leave certificate by calling the hotline without visit medical institutions.
  • If signs of the disease appear, seek medical help at home.

Is self-isolation introduced for passengers flying to Moscow who have symptoms of the virus only, or for all passengers?

Self-isolation is introduced for all passengers arriving in Moscow by any means of transport from countries with an unfavorable infectious situation.

Do the regulatory acts only apply to Russian citizens or to foreigners too?

All restrictions apply to Russian citizens, foreign citizens, and stateless persons.

Is the 14-day self-isolation rule mandatory for everyone or is this a recommendation?

A 14-day self-isolation is mandatory for everyone. It is not clear yet how this will be controlled, but we expect increased attention to companies employing foreign citizens. Supervisory authorities can bring both employers and employees to administrative liability for violation of the legislation on sanitary and epidemiological welfare (article 6.3 of the Administrative Offences Code RF). The sanctions may vary between small fines or, in specific situations, administrative suspension of a legal entity for up to 90 days. Foreign citizens, who are subject to two or more administrative sanctions, may be limited to entry Russia by the state authorities. Renewing or obtaining new migration documents may be restricted as a result.

What if a citizen who, for example, was in Austria (not named in the list of countries with an unfavorable situation with the spread of coronavirus infection) returned to Moscow through Germany? And vice versa, if a citizen who was, for example, in Germany and returned to Moscow with transit in Austria?

The requirements of the decree apply to all persons who visited countries with an unfavorable situation with coronavirus infection, regardless of the time spent in that country. Therefore, all who stayed in these countries or flew through these countries may be subject to the requirements of the Decree. All passengers arriving in Russia from abroad may be interviewed at the checkpoint whether they have visited any of the related countries or not, and if so, they are subject to the relevant checkup.

What to expect for citizens at the airport who are affected by increased temperature or other symptoms of infection?

Some passengers reported that those who had an increased temperature were escorted to an area with specialists in protective suits who examined them, checked where the person had been for the last 1-2 weeks, and let them go. We believe that the practice may change and we will keep you informed if we receive new information about such process.

The Decree obligates all employers operating in the city of Moscow:

  • To ensure temperature measuring of all employees at the working place
  • To suspend individuals with increased temperature from work
  • To assist employees self-isolating at home
  • To ensure the disinfection of the premises where the sick person was
  • To provide, at the request of supervisory authorities, information about the contacts of the patient in connection with the performance of job duties

We recommend the following practical steps for employers:

  • Provide temperature measurement for all employees and visitors entering the office
  • Providing disinfectants and educating your employees regarding hygiene measures
  • Monitoring the general health conditions of employees
  • Having a continuity plan in place to secure the health of your employees and your business
  • Provide the ability to work remotely for employees in self-isolation
  • Offering support for changing private travel arrangement

Along with administrative measures against citizens, company officials, and employers themselves in the event of a massive illness or death due to the spread of coronavirus infection, the CEO of the legal entity and other responsible officers may be subject to criminal prosecution (article 236 of the Criminal Code of the Russian Federation).

How do you ensure business continuity? 

If the General Director of a Russian legal entity cannot enter the Russian Federation or must be in self-isolation, we recommend that you consider the following options:

  • Issuance of a power of attorney to an authorized representative of the legal entity for the purpose of managing the activities of the legal entity while the General Director is absent from office
  • Election of a second General Director of the legal entity. This allows for operational business continuity. This may make sense not only under restrictions due to the coronavirus, but also for the interchangeability of directors and additional control for the founders
  • Review all planned business and private trips and, if possible, postpone them until the situation normalizes

 

Do you have further questions or need support with developing or adapting a continuity plan?

Contact us

Alex Stolarsky
Partner, Rechtsanwalt, Legal & Compliance, Moscow
+7 / 495 / 956 55 57
Denis Bushnev
Legal Team Leader, Labor and Migration Law
+7 / 495 / 956 55 57
Ekaterina Kvaskova
Director for Internal Controls, Member of the Board
+7 / 495 / 956 55 57

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