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TikTok became the fourth IT company to start implementing the law on landing in the Russian Federation

On January 18, 2022, Roskomnadzor announced on its Teegram channel that TikTok has become the fourth IT company to start enforcing the “landing” law in Russia. The social network posted an electronic feedback form with Russian users on its website and mobile application.

According to the RKN, not one of the thirteen foreign IT companies has yet opened a branch in the country under the law on “landing” in the Russian Federation. Yesterday, a representative of Viber said that the company began opening a legal entity for a representative office in the Russian Federation as part of the “landing” law.

On January 17, 2022, Apple, Viber and Likee registered personal accounts on a special website of Roskomnadzor. Apple and Likeme also made electronic forms on their websites for sending applications from Russian citizens and organizations, as provided for by the current legislation of the Russian Federation and the requirement of the ILV.

Regarding the contact form, IT companies implemented this requirement a little differently.

TikTok did this in the form of their standard complaint form, but with localization in our country.

Likee just made a link on the main page of his site at the bottom in the "Support" section in the "Help and Feedback" subsection to a Google form.

On Apple's "Contact Apple" page in the "Help and technical support" section and in the "Submit a request" subsection, a notification appeared "Consumers and organizations in Russia can submit their requests for the App Store, iCloud and Apple Music through a separate link." For each client, a new link is generated, so you can access this form only through the main part of the "Help and technical support" section of the site.

On November 22, 2021, Roskomnadzor published a list of foreign Internet companies that must open representative offices in Russia from January 1, 2022. This list of companies currently includes: Google, Apple, Meta, Twitter, TikTok, Telegram, Zoom, Likeme, Viber, Discord, Pinterest, Spotify, and Twitch.

In addition to the requirement to establish a branch/representative office/Russian legal entity from January 1, 2022, Russian law imposes a number of obligations on foreign entities. So, they must place on their website an electronic feedback form with Russian users, register a personal account on the Roskomnadzor website for interaction with authorities, install a recommended attendance counter on the information resource (the list of recommended attendance counters is determined by the RKN and posted on the main page of the site 236- fz.rkn.gov.ru), also foreign persons are required to restrict access to information that violates Russian law and follow the instructions of the RKN to remove prohibited content within 24 hours.

As of December 29, 2021, none of the foreign companies has opened its branch and announced, except for Viber, that it will do so in the near future.

For each company, the RKN website reflects the status of compliance with the requirements of the legislation of the Russian Federation:

place on the information resource(s) an electronic form: not executed/completed;

create a branch, or open a representative office, or establish a Russian legal entity: not executed;

register a personal account on the official website of Roskomnadzor: not executed\completed.

Current enforcement measures from RKN to 13 companies: no enforcement measures are applied.

Possible coercive measures to foreign companies from the RKN:

a ban on the distribution of advertising of a foreign person and (or) his information resource as an object of advertising;

a ban on the distribution of advertising on the information resource of a foreign person;

search ban.

In early December, the head of Roskomnadzor announced that the department would not immediately restrict the work of foreign Internet companies without representation from January 1, 2022. The representative of the supervisory agency explained that the slowdown and blocking of foreign resources by the ILV is possible, but this will not be done without notification and discussion. In his opinion, the main thing is for companies to enter into a dialogue with the regulator. Foreign IT resources ready for cooperation will be able to deal with all the requirements of Russian legislation during the beginning of the year, even with the help of technical support from RKN specialists.

TikTok became the fourth IT company to start implementing the law on landing in the Russian Federation