Received a formal clarification from MFA on the new visa rules that a foreigner 
can spend no more than 90 of 180 days in Russia.

Spoke to EC Commission and several Embassies.

Consensus:
1.  As promulgated, the new rule modifies a paragrpah in the existing rule that 
dealt with the number of entries:  single/multiple.
2.  As that paragraph applied to ALL visa types (as all visas are either single 
or multiple entry) it is read as applicable de jure to all visa types (student, 
tourits, commercial, work, diplomatic as the main ones relevant to this list).
3.  The "take" from the Embassies is that it will not apply to diplomatic visas 
at all.
4.  The (I feel) optimistic take from one major Embassy is that the new rules 
also will not apply to work visas.  The logic is that it won't apply, b/c it 
won't be possible to work if you have to leave for 90 of 180 days.  A response 
could be that it is also not possible to study if you can only spend 3 months 
of a semester in country.  But... what would be the point of upsetting them?
5.  Informal MFA guidance is that the new rule doesn't apply to diplomatic, but 
applies to ALL other types.

NOTE:  the 90 day term begins from publication, October 4, so... anyone 
affected by it is already more than 3 weeks into the term, and there is not a 
great track record for getting things done in the RF from early December to mid 
January.

Recommendation:  if eligible, get a work visa and register it.  get a lawyer, 
it would be ultimately cheaper to do this, than to be stopped trying to enter 
the RF.

PS.  No... before anyone starts, this does NOT violate human or constitutional 
rights.  No one has a legally protected right to a visa anywhere, there are 
however very significant issues of reciprocity.  The RF position (disclaimer, I 
have been, but am not the RFG's lawyer) is that this is reciprocity, as for 
example U.S. visas don't allow someone to be present in the U.S. more than 90 
of 180 days.  I believe it is a misinterpretation as U.S. student visas for 
example DO allow a person to stay the whole seminar and finish a term, but 
there are visa types intended to prevent permanent residence that require 
leaving.  INS even automatically renewed them for several of the terrorists 
involved in Sep. 11, but... that's another story.
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