Travel Restrictions and Extradition Exposure: A Practical Assessment for Foreign Nationals

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Practice Analysis

Byline:
By Vitaliy Vetrov

May 2026

INSIGHTS ARTICLES —travel restrictions extradition russia

Foreign nationals involved in Russian criminal investigations — whether as targets of the investigation or as witnesses to events that form the subject of the investigation — face two distinct but related legal risks relating to their freedom of movement: the risk of a travel restriction order preventing departure from Russia while in the country, and the risk of extradition to Russia if they are outside Russia when proceedings commence.

Travel Restrictions Inside Russia

A travel restriction order is a non-custodial interim measure available under Article 97 and Article 105.1 of the Russian Code of Criminal Procedure. It can be applied by the court at the investigator's request at any stage of the investigation, once a person has been granted the status of suspect or accused.

The order prohibits the subject from leaving Russian territory for the duration of the investigation and the subsequent proceedings. A violation of the order — departure from Russia without authorisation — is a criminal offence and typically results in an immediate upgrade to pre-trial detention.

For a foreign executive who is under travel restriction, the practical consequences are severe: they cannot leave Russia, attend board meetings or management meetings in other jurisdictions, fulfil personal or family obligations outside Russia, or relocate regardless of developments in their employment or personal situation. The order can be maintained for extended periods — there is no absolute statutory limit — and may outlast the investigative stage by months or years if the proceedings move slowly.

Challenge of a travel restriction order is possible but requires a formal application to the court that imposed the order, demonstrating that the reasons for imposition no longer apply or that a less restrictive alternative is appropriate. The prospects of a successful challenge depend on the stage of the proceedings, the nature of the alleged offence, and the specific circumstances of the case.

Extradition from Russia to Foreign Countries

Russia has bilateral extradition treaties with a number of states — primarily CIS members and a selection of other jurisdictions. For most Western European countries, the United States, Canada, Australia, and other major commercial partners, Russia does not have bilateral extradition treaties. In the absence of a treaty, extradition from Russia to those countries is not available on a legal basis, and Russia will not extradite its own citizens in any circumstance.

For a foreign national who is outside Russia and becomes the subject of a Russian criminal investigation, the theoretical extradition risk from Russia is therefore limited — but not eliminated. For a foreign national from a CIS country, an extradition treaty may exist. For transit through jurisdictions that have different extradition relationships with Russia than the foreign national's home country, case-by-case assessment is necessary.

Extradition from Third Countries to Russia

The more practically significant risk for a foreign national who is outside Russia is an Interpol Red Notice — an international notice issued at the request of a national authority seeking the provisional arrest of a person pending extradition. Russia files Red Notice requests for economic crime suspects.

A Red Notice does not oblige any country to extradite — extradition still requires a treaty and a formal process — but it can result in temporary detention at a border crossing, airport, or during routine police contact. The notice is visible to immigration authorities worldwide and can complicate travel even in jurisdictions that have no extradition relationship with Russia.

Challenge of a Russian-initiated Red Notice through the INTERPOL Commission for the Control of Files (CCF) is available where the Notice is based on politically motivated proceedings or does not meet INTERPOL's standards for criminal-justice purposes. The process is available to individuals and their counsel. Assessment of the grounds for a CCF challenge is part of the advisory service we provide for clients facing this situation.

Pre-Travel Assessment

For a foreign national who is currently in Russia and whose status in any criminal investigation is uncertain, a pre-travel assessment — before booking a flight — is essential. The Federal Bailiff Service (FSSP) database records travel restriction orders that have been registered by the courts. This database is accessible to the subject and their counsel, and a check of this database before travel provides a measure of assurance — though not absolute certainty, since recently imposed orders may not yet be recorded.

For a foreign national who is outside Russia and has become aware of a Russian criminal investigation, the priority assessment covers: the probability of an Interpol notice; the extradition treaty position between Russia and the foreign national's country of nationality and country of residence; and the legal position in any third countries through which the individual intends to travel.