From 25 May 2018 to 25 July 2018, high security measures in the host regions and cities of the 2018 FIFA World Cup will be in place. The host regions and cities include Moscow, Saint Petersburg, Tatarstan, as well as the Nizhny Novgorod, Sverdlovsk and Krasnodar regions.

The security measures will be implemented under Order No. 202 of the Russian President dated 9 May 2017* (the “Order”) and Russian Government Decree No. 689 dated 9 June 2017* (the “Decree”).

The measures include restrictions on hazardous production facilities, registration procedures on migration for Russian and foreign citizens, movement of vehicles, public meetings and the sale of weapons, explosive substances and alcohols.

This Alert focuses on the restrictions on hazardous production facilities and the movement of vehicles, which may impact companies operating in Russia during the World Cup.

We will provide more information on the other security measures that may affect guests at the World Cup in another Alert to be released in the near future.

Activities of hazardous production facilities

The following activities must be suspended from 25 May 2018 to 25 July 2018:

  • the operation of hazardous production facilities;
  • the use of atomic energy;
  • the use of ionising radiation sources;
  • the use of substances that are included in the federal register of potentially hazardous chemical and biological substances;
  • the use of pathogens of infectious diseases; and
  • the loading, transportation and unloading of dangerous goods by rail, inland waterway and sea.

The exceptions do not apply to the provision of medical services.

The decision to temporarily suspend activities will be taken by the CEO of the relevant company in the form of an order. The draft of the order must be approved by the relevant authorities during the FIFA World Cup. Companies will then have to provide a declaration that the hazardous activities have been suspended to the relevant authorities.

The Russian state authorities have already started sending letters to companies that operate hazardous industrial facilities, cargo transportation and loading/unloading facilities, ordering them to prepare for the suspension of their activities during the World Cup and to confirm their compliance.

Companies may be able to avoid suspending their activities, if they can show that suspension is not possible but that other measures have been taken to ensure work safety at their production facilities. We assume that the state authorities will decide on a case-by-case basis whether the measures taken are sufficient.

Restrictions on movement of vehicles

During the World Cup, restrictions on transportation by bus, water and air will apply. On match days, transportation of cargo by sea and air will be restricted in areas within the immediate vicinity of the World Cup stadiums. These measures could potentially lead to delays in the delivery of goods.

Previous experience

Similar security measures were taken during the Sochi Winter Olympic Games in 2014 and the FIFA Confederations Cup in 2017. In these cases, the state authorities adopted a fairly pragmatic approach to the application of the measures, minimising the impact on businesses.

Recommendations

Companies should check whether these measures apply to their operations in Russia and if applicable, take necessary measures to minimise impact on their operations.

In particular, we recommend that companies renegotiate delivery terms if the sale or transportation of their goods is likely to be restricted during the World Cup. This will avoid any potential breach of contract.

In Russian