The Finnish government has placed new restrictions on the entry of Russian nationals travelling to Finland based on tourism. Finland has also stopped accepting tourist visa applications and issuing tourist visas. The restrictions entered into force on 30 September at midnight (local time) and will remain in force for the time being.1, 2
WHY THIS MATTERS
Entry to Finland is further restricted for Russian nationals traveling for tourism purposes, which should be considered by anyone planning to travel from Russia to Finland with a tourist visa. Finland has stopped the issuance of new tourist visas, and visas issued by Finland can be revoked at the border if the conditions of entry are not met. The decision of entry is always based on individual overall consideration conducted by the Border Guard of Finland.
The restrictions may also affect Russian nationals travelling with visas issued by other Schengen countries, as Finland can ban the entry of a Russian national travelling with a visa issued by another Schengen country if the conditions of entry are not met. Finland would not, however, revoke a tourist visa issued by another Schengen country, unless another Schengen country has requested to do so.3
On 29 September 2022, the Finnish government announced that tourists arriving from Russia in high volumes and tourists transiting to other countries through Finland after the mobilization declared in Russia on 21 September 2022 put Finland’s international position and relations at danger.4 Therefore, Finland decided further to restrict the entry based on tourism from Russia. The new restrictions are based on Article 6(1)(e) of the Schengen Borders Code. In short, the Article states that the entry of third-country nationals into any Schengen country requires that they do not pose a threat to public policy, internal security, public health, or the international relations of any of the member states.5
According to a press conference held by the Finnish government on September 29, the border will remain open for persons entering for essential purposes, as well as for people travelling to Finland with D visas or Finnish residence permits. According to the new restrictions, the Border Guard can revoke visas issued by Finland, but Finland would not revoke visas issued by other Schengen countries unless requested. The Border Guard can, however, prevent a person travelling with a visa issued by another country from entering Finland.6
Exemptions for Certain Groups
According to the Border Guard, the restrictions do not currently apply to the following special groups when certain terms are met (please see The Finnish Border Guard’s webpage "Restrictions on the Entry of Russian Citizens") for the detailed terms for each category):
— Family members of Finnish citizens and third-country nationals permanently residing in Finland
— This includes family members of Finnish citizens and third-country nationals permanently residing in Finland (spouses, parents, grandparents, children, grandchildren, and dependents, as well as persons applying for a visa based on an established relationship).
— Transit travel to other Schengen countries based on meeting relatives is not allowed. Entry of family members is only allowed in connection with travel to Finland.
— Proof of family ties must be presented at the border.
— Family members of citizens of a member state of the European Union (EU), a member state of the European Economic Area (EEA), or the Swiss Confederation
— Proof of family ties must be presented at the border.
— Proof that the purpose for entry is work must be presented at the border.
— Logistics and transport industry personnel exercising their duties
— Business travellers
— People arriving in Finland for treatment
— Owners of an apartment or property
— Personnel of diplomatic missions and consular representations
— Other special reasons (necessary reasons, such as humanitarian reasons).7
The purpose of the travel must always be proven at the border.
For previous issues of GMS Flash Alert on this topic, please see GMS Flash Alert 2022-156 (29 August 2022) and GMS Flash Alert 2022-171 (23 September 2022).
The visa restrictions will not have an impact on residence permit processes from Russia to Finland.
The KPMG International member firm in Finland continues to monitor these matters closely.
1 See (in English) Ministry of Foreign Affairs, “Finnish government issues a resolution to strongly restrict entry of Russian tourists into Finland” by clicking here.
2 See (in English) “Q&A 29 September 2022, Ministry for Foreign Affairs, Ministry of the Interior, Border Guard: Government Resolution 29 September 2022 on the restriction of entry of Russian citizens” by clicking here.
3 See (in English) Ministry of Foreign Affairs, “Finnish government issues a resolution to strongly restrict entry of Russian tourists into Finland” by clicking here and “Q&A 29 September 2022, Ministry for Foreign Affairs, Ministry of the Interior, Border Guard: Government Resolution 29 September 2022 on the restriction of entry of Russian citizens” by clicking here .
6 For reports in the press, see: Tulikuuka de Fresnes and H. Tikkala, "Suomen raja sulkeutuu torstaina keskiyöllä venäläisiltä lomamatkailijoita – Sisäministeri Mikkonen: "Vaikutus liikennemääriin on merkittävä” in Yle (online) (29.9. 10:27, Päivitetty 29.9. 15:28)."
7 See (in English) The Finnish Border Guard, ”Restrictions on the entry of Russian citizens” by clicking here.
* Please note the KPMG International member firm in the United States does not provide immigration or labour law services. However, KPMG Law LLP in Canada can assist clients with U.S. immigration matters.
The information contained in this newsletter was submitted by the KPMG International member firm in Finland.
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