Problems of Post-Communism

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Russian Citizenship

Eric Lohr

To cite this article: Eric Lohr (2013) Russian Citizenship, Problems of Post-Communism, 60:6,
3-15

To link to this article: http://dx.doi.org/10.2753/PPC1075-8216600601

Published online: 08 Dec 2014.

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 Russian Citizenship
Modernization and Population
Policy in Historical Perspective
Eric Lohr
Downloaded by [King's College London] at 14:44 26 April 2016

Although the collapse of the

Soviet Union in 1991 marked a
S INCE 1991, Russia and the fourteen other post-Soviet
states have each developed their own distinctive
policies, legal regimes, and practices of citizenship and
migration policy. In many ways, the Russian Federation
clear turning point in Russian created its new policies from scratch, importing ideas and
ideas of citizenship, present responding to the demands of international law, as well
as to bilateral relationships with the European Union and
views on this topic share certain other countries. The shifting winds of popular politics,
demand for cheap labor, and geopolitical strategy have
key concepts with the countrys all played roles in the unfolding of Russian citizenship
imperial past. and migration policies. But the key decisions were not
made in a vacuum; they were taken in a country with a
distinct historical tradition of citizenship and migration.
While a strong body of historical scholarship and aware-
ness of distinct national traditions has been a big part of
discussions about citizenship in France, Germany, Britain
and elsewhere, it has largely been absent from Russian
discussions.1 This article lays out the main features of
Russian citizenship history to provide a context for the
contemporary dilemmas Russia faces in its citizenship
practices and policies.
Rogers Brubakers path-breaking study of citizenship
contrasted France and Germany as polar opposite ideal
types. According to Brubaker, in France, the jus soli
principle of ascribing citizenship to all foreigners born
on French soil prevailed, along with other citizenship
and migration policies that tended toward openness and
assimilation. In contrast, in Germany, the jus sanguinis
principle allowed only the descendants of citizens to au-
ERIC LOHR is professor and Susan Carmel Lehrman Chair of Russian History tomatically acquire citizenship, excluding the sons and
and Culture at American University. daughters of foreigners born on German soil.2

Problems of Post-Communism, vol. 60, no. 6, NovemberDecember 2013, pp. 315.

2013 M.E. Sharpe, Inc. All rights reserved. Permissions: www.copyright.com
ISSN 10758216 (print)/ISSN 1557783X (online)
DOI: 10.2753/PPC1075-8216600601 Lohr Russian Citizenship 3
 Recent work by historians has been critical of carry-
ing the typologizing impulse too far. Andreas Fahrmeir,
Patrick Weil, and others have pointed out that Germany
and France share a great deal more in common than
Brubakers analysis would suggest; among other things,
they have shown that France had a long tradition of jus
sanguinis and exclusionary citizenship rules.3 However,
I think it will be helpful at this early stage of histori-
cal research into Russian citizenship to propose some
preliminary generalizations about the things that distin-
guish the Russian citizenship traditions from those of
other countries. That can help bring Russia into broader
comparative discussions of citizenship.
The Soviet era poses a particular challenge to an at-
tempt to find a distinct citizenship tradition. All coun-
tries define their own citizenship traditions through a long
progression of choices made throughout their history. In
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most cases, there is a legible record of these choices in
the form of a continuous juridical chain of precedents,
court rulings, and interpretations. Thus, detailed analy-
sis of seventeenth-century British court cases on natural-
ization is self-evidently part of the story of U.S. citizen-
ship, as are the provisions of the Napoleonic Code in the
French tradition.4 Countries with a continuous legal his-
tory thus have a traceable path along which certain prin-
ciples emerged, evolved, and influenced the contempo-
rary legislation and statutes on citizenship. In this sense,
Russia poses a problem. The 1917 revolutions declared
the entire prerevolutionary legal apparatus null and void
and started from an entirely different set of principles
and operating procedures. Of course, there were occa-
sional holdovers (like Sergei Kishkin and Vsevolod N.
Durdenevskii) from the old juridical establishment who
brought and applied juridical knowledge across the 1917
divide.5 But the striking fact is discontinuitynot only
in the underlying principles but, more significantly, in
practices.
This is especially apparent in the unprecedented
swing toward autarky in the late 1920s. This was not
a return to pre-1860s or medieval Russian isolation but
rather a distinctly Soviet decision that amounted to a
dramatic break from Russian traditions. Taking a long
view, the Soviet era from Stalin to Gorbachev thus ap-
pears to be in many ways a half-century detour. From
the late 1980s through to the present day, new problems
and dilemmas have emerged. They are not easily seen
in historical context because they are so different from
the issues of the Soviet era. But sometimes, the stron-
gest continuities and parallels are not found in the most
recent decades. If we think about the pre-Stalin history
4 Problems of Post-Communism November/December 2013
of Russian citizenship as creating a national citizenship
tradition in a more anthropological sense rather than a
set of legal precedents, we will be better prepared to see
the commonalities in the problems and dilemmas Russia
faces in its contemporary approach to citizenship.
This article contends that 1991 marked a revolution-
ary break from the preceding decades of Soviet citi-
zenship law, but the more distant pastespecially the
late imperial eraprovides an important context for
contemporary citizenship policy. The key dilemmas of
citizenship policy in that earlier era have reemerged in
remarkably comparable form.6 More specifically, both
periods saw a strong embrace of an open policy of at-
tracting and naturalizing as many people as possible as
an integral part of overall economic modernization strat-
egy. Then both periods saw a turn toward taking ethnic
and national considerations into much greater account.
By the end of each era, a series of decisions amalgam-
ated elements of these two contradictory elements into
an uneasy synthesis.
Attract and Hold
The most consistent and powerful principle and ruling
strategy behind Russian citizenship policy for centuries
prior to the modern era was a principle that I call attract
and hold. From Kievan Rus through the eighteenth-centu-
ry Russian Empire, rulers faced huge practical challenges
in ruling large, relatively sparsely settled lands. Tsars went
to great lengths to attract service elites, merchants, skilled
workers, and especially foreign mercenaries to Muscovy.
Foreigners were a key factor in Muscovite modernization
from the sixteenth century onward. Resident foreign mer-
cenary officers and soldiers played a particularly signifi-
cant role in the gunpowder revolution and the introduction
of new-formation regiments.7 Foreign trade accounted
for a large part of seventeenth-century tax receipts and was
largely run by resident foreigners.8 Moreover, foreigners
played prominent roles in building Russian factories and
developing mines, iron works, armament factories, and
other industries.9
The importance ascribed to foreigners points to the
second enduring theme of the Russian citizenship tradi-
tion: its close linkage to economic modernization strat-
egy. Russian merchants, the Church, and other sources
mounted a substantial resistance to the prominent role
of foreigners. But the tsar far more often used his exten-
sive powers (every single foreigner required permission
to enter service, open an enterprise, enter or leave the
kingdom) to protect and promote the role of foreigners
 in Muscovy than he did to restrict them.10 In the Mus-
covite era, conversion to Orthodoxy was more strongly
associated with gaining full membership privileges than
was taking an oath of allegiance to the tsar (naturaliz-
ing).11 The regime strongly promoted the conversion of
its foreign servitors to Orthodoxy, offering promotion in
rank for military servitors and pay increases and other
privileges for foreigners in other types of state service.12
From the reign of Peter the Great (1682/891725), the
act of naturalization (taking the oath of loyalty to the
tsar) became increasingly important, displacing conver-
sion as the crucial marker of membership in the country.
The tsars consistently encouraged naturalization as part
of their attract and hold policy.
The tsars also went to great lengths to hold popula-
tions in the country. The state banned emigration and
did not recognize loss of Russian subjecthood through
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naturalization abroad. Tsars reinforced and strengthened
systems of serfdom and collective responsibility through
the peasant commune as means to hold peasants in place.
Likewise, the Russian tsars developed elaborate and
fairly effective means to hold their elites in service to
the tsar and prevent their defection to neighboring states.
For example, they enforced a law that properties belong-
ing to any Russian-subject landlord who stayed abroad
for more than five years (three years for members of any
other social order) could be confiscated and transferred
to state institutions without compensation.13 Noble clans
were also held collectively responsible for anyone who
left Muscovite service and the country without permis-
sion.14 Even foreign subjects in Muscovite service were
often denied requests to travel abroad and had to put up
family members as a pledge that they would return.15
The policy of attracting immigrants and encouraging
their naturalization reached its apogee in the eighteenth
century. Peter the Great issued an important decree in
1702 inviting foreigners to come to the empire to trade,
promising them a generous mix of new privileges and
rights.16 The two biggest changes for all foreigners were
explicit new guarantees of the freedom of conscience
and freedom of entry into and exit from the country.17
Foreign entrepreneurs acquired an unprecedented level
of codified protection under the Manufacturing Statute
of 1723.18 Throughout the rest of the century, economic
policy was bound tightly with the notion that popula-
tion was the source of prosperity. Empresses Elizabeth
(17411762) and Catherine II (17621796) both added
aggressive campaigns to promote agrarian migrants to
settle and bring under tillage the rich soils of the vast,
recently conquered southern steppe. Catherine famously
offered religious freedom, temporary exemption from
taxes, and permanent exemption from military service
as inducements to immigrant groups. She was so keen
to attract foreign settlers that she eased the traditional
pressure to naturalize, allowing foreigners to purchase
unpopulated lands and to enjoy most of the rights of citi-
zens without some of the more onerous burdens of citi-
zenship (first and foremost, military service). In this way,
she offered a better mix of rights and obligations under
the law to immigrants than Russian subjects enjoyed.19
Population Policy
The third most powerful theme in the Russian citizenship
tradition was its linkage to population policy. In a general
sense, we have already seen that there was a positive
population policy of using naturalization, denaturaliza-
tion, and migration policy to try to increase the numbers
of skilled workers and agrarian settlers and to hold them
in the country. But there was also a negative side to
population policy. From the Muscovite era onward, there
were certain populations that the regime did not want.
Jesuits were banned from entering the empire. Likewise,
particularly in the wake of the 1830 and 1863 Polish
rebellions, tight controls were imposed over the entry of
any Catholic clergy. Foreign dervishes were not so strictly
banned from entry but were not allowed to naturalize.20
Various laws and administrative regulations banned the
issuance of visas to foreign Gypsies. Local officials were
granted authority to deport them from the country or to
the interior as vagrants.21 The most important restrictions
in terms of severity and number of individuals affected
applied to Jews.
Despite much international pressure, the regime in-
troduced more restrictions in the late nineteenth century.
Foreign Jews were allowed to settle in Russia only in
exceptional cases requiring the approval of the Minis-
try of the Interior.22 For the few Jews who came to Rus-
sia, naturalization was extremely difficult. By a decision
of 1896, the only categories of foreign Jews who could
become Russian subjects were those building factories,
craftsmen and masters, and Central Asian Jews wishing
to enter guilds in Orenburg province.23 The Department
of Police files contain many cases of the discovery and
deportation of individuals who had acquired visas on
their passports without notation that they were Jewish
or came to Russia with passports falsely using Christian
names. When the police discovered such individuals,
they often deported them from the country by adminis-
trative order.24
Lohr Russian Citizenship 5
 Emigration and denaturalization policy also became
closely linked to population policy. From the Musco-
vite era through the end of the imperial period, Russia
maintained one of the worlds most hostile sets of laws
toward emigration and denaturalization. The origins of
these policies reach deep into the Russian past, when a
shortage of people was the overriding concern and the
goal of keeping serfs, soldiers, servitors, and merchants
bound in servitude or service to the tsar shaped the
countrys most basic institutions. Serfdom evolved as a
means to hold labor in place so the noble service class
could exploit it. Until emancipation, emigration was un-
thinkable for the vast bulk of the enserfed population.
The tsars also held tightly to their noble service elites.
Elaborate systems of collective responsibility, hostage
taking, and monetary penalty and reward were devised
to keep nobles from defecting to other statesespecially
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to the Polish-Lithuanian Commonwealth, where nobles
enjoyed many more personal and political rights than in
Muscovy. Departure from the empire without the tsars
permission was strictly prohibited, and exceptions were
rarely granted. From 1649 onward, departure from the
country required a special foreign passport (zagran-
ichnyi pasport), which served the role of exit visa and
was extremely expensive and difficult to acquire.
Despite official policies, in the late nineteenth century
several factors contributed to the sudden emergence of
emigration as a mass phenomenon. First, the 1860s great
reforms made movement within the country much easier
and paved the way for improvements in public health,
life expectancy, and agrarian productivity. The result
was a serious overpopulation problem in regions of the
country with good soil. The advent of cheap steamship
and railroad travel made mass emigration to free lands in
the Americas and Australia feasible. Big steamship lines
aggressively and very successfully recruited emigrants
from overpopulated regions of rural Europe and from
cities in times of economic downturn. Austria-Hungary,
Spain, Great Britain, Italy, and Germany facilitated their
work by reforming their emigration laws and regula-
tions, thereby making emigration a practical way to re-
lease pressures of unemployment and land hunger.25 In
addition, countries of emigration found that emigrants
repatriated earnings back to their kin, and many returned
to their homelands when economic conditions improved
or when they had made enough money to start a business
or buy land.26
Russia was not an exception to the explosion of mass
emigration from Europe in the second half of the nine-
teenth century; there was a net emigration of over four
6 Problems of Post-Communism November/December 2013
million from 1860 to 1914. However, its official re-
sponse was very different and says a lot about its popula-
tion policy priorities. The regime retained its extremely
expensive and time-consuming requirement of a foreign
passport to leave the country. As late as 1910, the fee
for a foreign passport was 17.25 rubles (roughly equiva-
lent to the average monthly earnings of a Russian farm
laborer).27 The requirement that an applicant receive a
document from the regional gendarme administration
indicating a lack of objection to travel abroad and an-
other verifying that he had no outstanding debts or taxes
both added much time and expense to the application
process. Each of these documents required stamps, the
expense of travel to offices in provincial capitals, and
time spent waiting for each step in the application. Al-
together, the process could often take three months at
an expense of 3040 rubles.28 In addition, if a poten-
tial emigrant wanted to formally denaturalize (or if he
was required to do so by Russian law), then there were
substantial additional fees and bureaucratic hurdles that
could run as high as 100 rubles.29
By the turn of the century, this had become a highly
unusual situation. In England, a foreign passport cost the
equivalent of 1 ruble; in Germany, 3.25 rubles; and in
Spain, it was free of charge. Nowhere did the process
take so long as in Russia. In Italy, the document was
issued within twenty-four hours, and in Spain within
three days.30 The result was the emergence of a huge
underground emigrant smuggling trade that accounted
for as much as 80 percent of all emigration from the
Russian Empire. Despite many proposals to reform the
emigration system, each foundered, and Russia retained
its hostile official attitude and laws toward emigration
and denaturalization right up to 1917. There are a few
reasons why. First, Interior Ministry officials expressed
the worry that emigration was drawing healthy young
workers while leaving women and physically less able
men behind. They did not want to allow such young men
to leave Russian subjecthood if they had not completed
their active and reserve military duties; even if they had
discharged such duties, the regime wanted to maintain
formal control over them. Second, a massive diplomatic
dispute with the United States broke out over the issue of
Russian refusal to recognize the denaturalization of its
Jewish former citizens. In practical terms, the problem
arose when several Jewish emigrants moved to the Unit-
ed States and naturalized, then a few years later returned
to their former homes in the Russian Empire, claiming
the full rights of U.S. citizens. Russian authorities saw
this as an attempt to get around the welter of restrictions
 Table 1

Share of Emigration by Ethnic Group (early twentieth century)

Ethnic group 19011910 estimate (%) 19041909 estimate (%) Emigrants (per 100,000)

Jews 41 47 1,662
Poles 29 26 514
Lithuanians 9 9 456
Finns 7 7 182
Slavs (Russians, Ukrainians,
Belarusians) 7 5 9

Sources: Robin Cohen, Cambridge Survey of World Migration (Cambridge: Cambridge University Press, 1995), 90 (column 2); RGIA, f.
565, op. 12, d. 134, l. 149 and RGIA, P. Z. 2531, l. 13 (column 3); RGIA, P. Z. 2531, l. 13, based on figures for 19041909 (column 4).

on the economic activity of Russian-subject Jews and ar- tance in purchasing tickets, arranged cheap lodging en
gued in response that such individuals would be treated route, and helped Jews plan for life in the new country.
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as Russian subjects because the state did not as a rule
recognize denaturalization abroad.31
The third, and probably most important, reason for
the failure to reform emigration laws was the fear that if
laws were liberalized, ethnic Russian emigration might
begin on a mass scale. Instead, the regime pursued poli-
cies that allowed Jews, Germans, and other groups to
emigrate while retaining general restrictions on emigra-
tion (Table 1). The regions that provided the vast ma-
jority of emigrants were the multiethnic western bor-
derland areas of present-day Ukraine, Belarus, Poland,
and the Baltic states. In these regions, officials were
acutely aware of the demographic balances among vari-
ous ethnic populations and their shares of landholding.
In the wake of the 1863 Polish rebellion, then again in
the 1880s, the regime imposed restrictions on the abil-
ity of foreign citizens and Poles to acquire land. Jews
were completely banned from acquiring rural properties.
There were plenty of reasons for officials to see emigra-
tion of non-Russian groups from this region as benefi-
cial to its ruling strategy. Indeed, a series of decisions
essentially legalized emigration for some groups. From
an early stage, the regime was relatively accommodating
of Germans requests to emigrateprobably because of
the rising perception that the German colonists were
acquiring too much land at the expense of Slavs.32 Per-
haps the biggest step toward ethno-nationally selective
legalization of emigration was the decision in May 1892
to allow the Jewish Colonization Association (JCA) to
open branches throughout the country and to provide in-
formation and assistance to Jewish emigrants. A highly
successful organization with over four hundred offices
by 1910, it spread news about emigration, gave assis-
Those leaving through the offices of the JCA did not
have to pay the expensive passport fees, and the orga-
nization took care of the complex and time-consuming
paperwork for the emigrants. The state even gave a dis-
counted train fare to the border. Tolerance of this orga-
nizations activities could be read as an indirect endorse-
ment of Jewish emigration.33 The policy that emigrants
departing through the JCA had to denaturalize and were
placed on the lists of individuals eternally banned from
returning to the Russian Empire suggests that lurking
behind the opening of the door to Jewish emigration was
population policy.34 In addition to being placed on these
lists, governors added a line to the exit documents issued
to the emigrants that the individuals were considered to
have left Russia forever.35
By keeping emigration expensive and very difficult
in general yet introducing these exceptional policies and
arrangements for certain groups, the regime was able to
filter its emigrants, holding firm to Slavs while letting
others leave more easily.
On the whole, the imperial period saw the motive of
modernization and economic development as central to
the establishment of a powerful tradition of attract and
hold. This policy was remarkably persistent, although
it came under challenge from an often contradictory
impulse toward national population politics. The old re-
gime found ways to resolve this dilemma by amalgamat-
ing two incompatible approaches. It used restrictions on
emigration to hold Slavs in the country but allowed Jews
and other less desired populations to emigrate. A set of
rules encouraged skilled worker migration to the cities
but restricted immigrant ability to acquire or inherit land
in the countryside in the western parts of the empire.

Lohr Russian Citizenship 7

 In the Far East, policies restricted permanent Asian im-
migration and naturalization while facilitating a massive
influx of low-wage seasonal guest workers. All these
examples combine to form a complicated set of poli-
cies that sought to reconcile the open attract and hold
modernization and population strategy with restrictive
policies in pursuit of ethno-national population manage-
ment goals.
Soviet Autarky
The Soviet era broke with this complex balance in nearly
every substantial way, creating a kind of half-century
aberration. The key to this revolutionary break was the
interrelated drive toward autarky in citizenship and the
economy. Shortly after seizing power, the Bolshevik
regime declared class-based principles in its citizenship
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policies. It banned immigration and naturalization for the
middle and upper classes, allowing it only for members
of the working class. In principle, workers of the world
were invited to immigrate to the Soviet Union and could
receive citizenship quickly in a simple expedited proce-
dure.36 A March 1918 decree issued an open invitation
to foreigners to seek asylum in the Soviet Union from
political or religious repression in their home countries,
promising that the new regime would not grant extradition
requests for such individuals.37 Naturalization was thus in
principle quite easy for workers, peasants, and socialist
activists.38 In practice, because of high unemployment,
general suspicion of foreigners, and the delegation of
control over each individual naturalization decision to the
Soviet political police (the OGPU), the results of these
policies were limited from the start.39 As hopes for a global
communist revolution faded, the Soviet Union turned its
focus to building Socialism in One Country. On Lenins permission, who refused to return at the request of the
insistence, part of the strategy included attempts to attract
skilled labor and even foreign investment in the economy.
But unemployment remained high through the 1920s,
and as a result, the agency responsible for immigration
claimed that it received 420,000 requests for permission
to immigrate between 1922 and 1925 but granted only
11,000 (2.6 percent).40
Although the door in principle remained open for pro-
letarian immigration and naturalization, the regime dra-
matically cut all ties with millions of its compatriots in
emigration. First, in sharp contrast to the central concern
of citizenship policy for decades prior to 1914namely,
holding ethnic Russians in citizenship and in the coun-
trythe Soviet authorities did not welcome back hun-
dreds of thousands of ethnic Russians who had fought
8 Problems of Post-Communism November/December 2013
in the White armies during the Civil War. Several half-
hearted partial amnesties were declared, but the Peoples
Commissariat of Internal Affairs (NKVD) blocked their
implementation, and only a trickle of such veterans end-
ed up returning. The regime made some overtures en-
couraging the more than two million refugees from the
former Russian Empire to return to their homelands but
took a very hard line on those who did not return imme-
diately. Decrees of November 3 and 19, 1920, ordered
the confiscation of all land, housing, and personal pos-
sessions of individuals who had left the territory of the
Russian Soviet Federated Socialist Republic (RSFSR).41
This decision amounted to a powerful policy against the
return of migrs and refugees, and it established the ba-
sic Bolshevik approach to its diaspora: return immedi-
ately or never.
This policy was carried further by the landmark All-
Russian Central Executive Committee (VTsIK) and
Council of Peoples Commissars (SNK) RSFSR decree
of December 15, 1921, that declared the denaturalization
of all individuals who had been abroad for more than
five years and had not applied for or received passports
from Soviet representatives by June 1, 1922; individuals
who voluntarily served in the armies that fought against
the Soviet government; and anyone who had left Russia
after November 7, 1917, without permission from Soviet
authorities.42 Over the course of the next two years, the
other Soviet republics issued similar decrees.43 With the
formation of the Soviet Union in 1923 and the promul-
gation of the Soviet constitution in 1924, a single So-
viet citizenship was created. A new statute confirmed
the mass denaturalizations according to individual So-
viet republic laws and added that any individuals who
left the territory of the Soviet Union, with or without
authorities lost their Soviet citizenship. The statute like-
wise granted the courts the right to use denaturalization
as a punishment.44 Few migrs were willing to apply
for Soviet citizenship, and those who did by no means
received an automatic acceptance. Officials abroad and
at the border were instructed to be vigilant against al-
lowing the naturalization and return of class enemies
and any individuals suspected of potential disloyalty.45
The decree amounted to a mass denaturalization of the
vast majority of former subjects of the Russian Empire
residing outside the empire. In the interwar era, most
countries moved toward restrictive policies on immi-
gration and naturalization, making it difficult for these
former citizens of the Russian Empire to acquire citi-
zenship in their countries of residence. The result was
 roughly 1.5 million stateless individuals.46 The few who
returned were registered with the police and required to
sign a document promising not to leave the territory of
the Soviet Union.47
This series of decisions at the beginning of the Soviet
era was unprecedented in Russian and global citizenship
history. The new Soviet state permanently and unilater-
ally severed its ties to approximately two million compa-
triotsmany of them ethnic Russians. By denaturalizing
them and confiscating their property, the regime ensured
they would not maintain ties with their kin or travel to the
Soviet Union for any reason. In a few years, roughly fif-
teen times more ethnic Russians left the country than in
the entire history of Russia prior to 1914, and the Soviet
response was to make this mass emigration permanent
through denaturalization and confiscation of property.
The mobilization of the country for forced industri-
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alization in the late 1920s and the early 1930s brought
the drive toward autarky to its furthest extremes. There
was an intensive mobilization of antiforeign sentiments
during the war scare of 19261927. The Ministry of Fi-
nance cracked down on all border crossings to prevent
the export of valuables. The secret police built up formi-
dable border fences, a tighter visa system, strict internal
administrative proceduresall directed toward limiting
cross-border movementespecially emigration. The
result was a sharp decline in the number of foreigners
living in the country. In 1928, the NKVD estimated that
there were only 80,000 foreigners in the Soviet Union
(less than one-twelfth the number in 1913).48
But restrictions on immigration were tight as well.
Despite the huge masses of unemployed available for
hire throughout the world during the Great Depression,
the Soviet state remained incredibly restrictive. This
time, it was not because of unemployment in the Soviet
Union, but rather because foreign workers were expen-
sive, and because the OGPU and NKVD became even
more suspicious of foreigners and used their control
over immigration to impose strict limits. By some re-
ports, well over a million people applied to come to the
Soviet Union for work in 19301932. The state allowed
only about forty-two thousand (4 percent) to enter. Then,
as many as ten thousand of those were arrested during
the purges of the 1930s.49
The intensity of interaction along the citizenship
boundary peaked on the eve of World War I, with over
ten million officially recorded border crossings going
each way, and millions more undocumented crossings.
By 1930, this had been reduced to thousands. Small
traders faced strict limits on the amounts of goods and
currency they could bring both ways, and political con-
trols made the free exchange of ideas downright danger-
ous. The Soviet Union brought as decisive a break in
citizenship and migration history as any major country
has experienced.50 Stalins Great Break sealed the coun-
try off from the outside world. It also sealed off Russias
historically evolved citizenship traditions.
Even though conditions seemed favorable for a pro-
immigration policy after the war, with a serious labor
shortage and a boom in both living standards and Soviet
prestige as a result of the war and achievements from
nuclear weapons to space exploration, immigration to
the Soviet Union remained relatively infrequent and re-
markably small in scale for a country of its size and level
of economic development.
After World War II, the Soviet Union forced Eastern
Europe to become communist and gained allies among
many newly independent states that emerged from de-
colonization. The result added a whole series of com-
plexities to the citizenship issue. Within the communist
world, travel, work migration, settlement, and even
naturalization and denaturalization became much easier
than such interactions across borders with the capitalist
world. Citizens of socialist countries came to the Soviet
Union for study, work, or leisure in increasing numbers
from the 1960s onward. The regime also eased restric-
tions on travel and study in the Soviet Union by citizens
of capitalist countries in the 1960s, and the amount of
cross-border travel increased substantially. Altogether,
visitors to the Soviet Union rose from 0.5 million in
1956 to 2 million in 1970 and 5 million in 1980, with
over 60 percent of these visitors coming from socialist
countries. Soviet travel abroad followed a nearly iden-
tical trajectory, with comparable numbers.51 Economic
and scientific cooperation also expanded between the
Soviet Union and the West.52
Despite these changes, the authorities continued to
vigorously maintain the boundary between the capitalist
and the socialist worlds. The Intourist system minimized
uncontrolled contact with Soviet citizens, and elaborate
controls were imposed on Soviets traveling abroad.53
Unauthorized emigration was treated as a betrayal, and
such emigrants were not as a rule allowed to return.54
The few who were permitted to emigrate faced official
harassment, which was often extended to families, col-
leagues, and acquaintances. Soviet citizens were barred
from emigrating even after marrying foreigners.55
Moreover, although these changes appear to be impor-
tant when compared to the extreme autarky of the 1930s
early 1950s, they seem far less significant when compared
Lohr Russian Citizenship 9
 to the explosion of international migration and interac-
tion in the postwar Western world. The gap between the
Soviet Union and the rest of the world grew wider and
wider in the postwar decades. In 1970, for example, more
than two million tourists visited the Soviet Union, but this
was only 1 percent of global international tourism and
less than 2 percent of all visitors to Europe in that year.
Twice as many people visited Yugoslavia and four times
as many visited Austria as traveled to the Soviet Union.56
The most significant exception to the ban on emi-
gration applied to Jews. From 1968 through the 1970s,
the Soviet Union made it possible for a limited number
of Jews to emigratealbeit through a difficult, costly,
and risky procedure. Roughly 0.25 million Soviet Jews
were allowed to emigrate (about 10 percent of the 1970
population of 2.2 million).57 This decision had far less
to do with population policy than in the late imperial
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period and was more closely linked to external factors
dtente, the rise of Soviet foreign trade (especially grain
imports), and the signing of the Helsinki Accords and
other international agreements that obliged the USSR to
respect the right to emigrate.
The 1970s Jewish emigration from the Soviet Union
was an important exception to the general policy of
maintaining the ban on emigration. But once an exit visa
was granted, it was abundantly clear that it was a one-
way ticket with no return allowed. This was important,
because of all subgroups of the Soviet population, the
Soviet Jews (along with the Armenians) were a highly
educated, mobilized diaspora that could easily activate
a vibrant new interface with the outside world. But un-
til the late 1980s, the regime effectively prevented such
interaction from occurring. The citizenship boundary re-
mained harder than nearly any other in the world right
up to the collapse of the Soviet Union in 1991.
Post-Soviet Citizenship
With the collapse of the Soviet system, the floodgates
suddenly opened. Millions of Russians were able to
choose whether to emigrate and denaturalize. On the eve
of the 1991 dissolution of the Soviet Union, the Russian
Federation adopted an extremely open citizenship law
based on inclusive jus soli principles that automatically
granted citizenship to all permanent residents of the
Russian Federation on February 6, 1992 (the day the law
came into force), unless the individual decided to opt out
within one year. This approach was consonant with Rus-
sian citizenship traditions. The ascription of citizenship
to everyone on a territory at a deadline was the standard
10 Problems of Post-Communism November/December 2013
practice applied by the tsars to newly annexed territories
and was comparable to the ascriptive nature of the early
Bolshevik citizenship treaties and practices. The law also
allowed any former Soviet citizens who had not estab-
lished permanent residence to acquire citizenship through
a simple declaration requiring only a handful of easily met
conditions.58 Along with these liberalizations, the Russian
Federation began the process of legally abolishing the
propiska system of controls over the right to live in certain
regions and guaranteed the right of all citizens to move
freely within the country, rights that were finally codi-
fied in article 27 of the 1993 Constitution of the Russian
Federation.59 The emancipatory trend culminated in the
landmark 1996 law that for the first time in all of Russian
history made the right to enter and leave the country a
basic, legally defined right of the Russian citizen.60
The 1990s saw a return to a strong version of the at-
tract and hold approach. Naturalization was made easy,
and unprecedented numbers took advantage of the new
situation. Because the authority to approve naturaliza-
tion was dispersed among local authorities, consulates
abroad, and central institutions, statistics are generally
unreliable, but they probably averaged nearly a half mil-
lion per year. From 1991 to 2009, 7.4 million people
were naturalized in the Russian Federation. On the sur-
face, this is an unprecedented success in the history of
Russia. While immigration had been a big part of the late
imperial modernization of 18601914, naturalization
rates then were far lower. On closer inspection, however,
these numbers are deceptive. Almost 99 percent of these
naturalizations were residents or nationals of countries
of the former Soviet Union. The biggest source of natu-
ralizations from outside that space was Afghanistan,
with only ten thousand naturalizations. Despite all the
public worry about a flood of Chinese taking over the
Far East, only fifteen hundred Chinese were nationalized
in that period.61 In short, nearly all naturalization has in-
volved the absorption of former Soviet citizens into the
successor Russian Federation.
As in the wake of World War I, after the Soviet col-
lapse tens of millions of people found themselves within
the boundaries of countries that did not match their ori-
gins, identities, or affinities. The sorting of nationalities
and citizenships among the fifteen successor states was
a drawn-out and contentious affair that continues to this
day. It has proceeded quite differently from what hap-
pened in the early 1920s. While the 1920s treaties and
mass denaturalization were aimed against dual nation-
ality and toward creating a loyal population of desired
class backgrounds, the 1990s saw a relatively open door
 to naturalization without deadlines and, following glob-
al trends, have been very tolerant of dual citizenship.
Former citizens of the Soviet Union residing outside the
Russian Federation were allowed to receive citizenship
through a simplified procedure that amounted to noth-
ing more than filling out a simple form. They were not
even required to enter the Russian Federation to do this.
This remarkably open definition of citizenship is typi-
cal of revolutionary regimes, but in many ways it went
further even than the early French revolutionary laws by
explicitly allowing dual citizenship.62
These policies have helped keep people from becom-
ing stateless individuals, a serious problem affecting
millions in the 1920s. But they have also created large
populations of Russian Federation citizens living outside
the borders of the state. This has given rise to many con-
flicts between Russia and the host countries, especially
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in Latvia, Estonia, Georgia, Moldova, Transnistria, and
the Crimean region of Ukraine.63
On the whole, the 19912000 period was quite the
opposite of the decade following the collapse of imperial
Russia and the Bolshevik revolution. In many ways, the
decade was marked by an extreme embrace of the impe-
rial attract and hold policy. However, ethno-national
population politics emerged as a challenge (along with
other factors) to the 1990s policies.
Since 2000, Russia has more sharply defined and
more closely policed the boundary between citizen and
foreigner. The law allowing former Soviet citizens to ac-
quire Russian Federation citizenship by simplified pro-
cedure expired in 2000 and was not renewed. A series
of unpublished Ministry of Internal Affairs instructions
sharply restricted the ability of former Soviet citizens
to naturalize, among other things forcing anyone who
did not have a residence permit by February 6, 1992,
to apply for citizenship through the standard difficult
procedures. A new citizenship law of May 2002 shifted
policy strongly in the restrictive direction. Former So-
viet citizens could no longer simply declare their will to
naturalize and do it by simplified procedure (as the 1991
law had allowed). Now, all former Soviet citizens had to
(1) document competence in the Russian language, (2)
show evidence of a legal source of income, (3) produce
evidence of the renunciation of prior citizenships, and
(4) acquire a permanent residency permit. The law es-
sentially made former Soviet citizens from neighboring
states equivalent to immigrants from distant countries.64
One of the primary effects of these decisions was to fi-
nallyeleven years after the end of the Soviet Union
make it clear that the open invitation to all former Soviet
citizens to acquire Russian Federation citizenship had
come to an end.65 In some ways, then, it amounted to a
shift from the policy that the Russian Federation was the
legal successor to the Soviet Union to a recognition that
the former Soviet space had now been divided into mu-
tually exclusive citizenries. One of the laws aims was
to make it more difficult for the millions of non-Russian
guest workers from Central Asia and the Caucasus to
naturalize and thereby acquire access to Russian govern-
ment services and welfare benefits. Another important
motive that President Vladimir Putin himself stated was
to slow down the demographic impact of large-scale im-
migration of minorities from these regions.66
A remarkable aspect of the shift toward a restrictive ap-
proach concerns refugees from conflicts in former Soviet
states in the Russian Federation. A 1993 law created the
category of forced migrant to cover these mostly Rus-
sian-speaking displaced people. Access to medical care,
pensions, and other forms of welfare were provided to
this favored immigrant category, and federal funding pro-
grams aimed to help localities provide long-term housing
to accommodate people with forced migrant status. This
amounted to one of the most generous programs aimed at
assisting former Soviet citizens to migrate and integrate
into the Russian Federation. Most of these programs, how-
ever, were allowed to expire in 2001. Moreover, the law
required beneficiaries to be Russian Federation citizens.
Until the 2002 law, it was easy for applicants for forced
migrant status to quickly acquire Russian citizenship. Af-
terwards, it became much more difficult.67 Symbolic of
the shift of official attitude toward such migrants was the
dissolution of the Federal Migration Service, created in
1992 primarily to provide social services, and the transfer
of its functions in 2002 to the Ministry of Internal Affairs.
Observers have noted a sharp turn from a focus on welfare
and integration to policing as a result.
These restrictions had an immediate and dramatic
impact. The annual number of naturalizations had been
over four hundred thousand every year from 1992 to
2000 but fell sharply to about forty thousand in 2003.68
But in contrast to the early Soviet turn toward autarky in
ever more radical waves of mobilization, after intense
debate the government backed off the restrictive 2002
law, and naturalizations recovered in the succeeding
years, facilitated by the repeated renewal of provisions
allowing fast-track naturalization for former Soviet citi-
zens, spouses, refugees, anyone born in Russia during
the Soviet era, soldiers, graduates of Russian postsec-
ondary educational institutions, and people with valu-
able scientific or technical skills.69
Lohr Russian Citizenship 11
 The restrictive turn of the 2000s also did not mean
an end to attempts to naturalize strategic groups in the
former Soviet space. Quite the contrary: in the summer
of 2002, the Russian Federation launched a controver-
sial drive to naturalize residents of the South Ossetian
and Abkhazian regions of Georgia. Then in 2008, Russia
claimed the right to protect the interests of its citizens in
Abkhazia and South Ossetia during its war with Geor-
gia.70 Georgia has vigorously protested these naturaliza-
tions, claiming that in 1993 it had given all residents of
the region six months to formally turn down Georgian
citizenship. If they failed to exercise this option, then
they were ascribed Georgian citizenship and according
to Georgian law were not allowed to take a second citi-
zenship without permission. The European Union (EU)
independent report produced under the supervision of
Heidi Tagliavini agreed that the collective Russian natu-
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ralizations of these populations contradicted Georgian
and international law. The Georgian case has been a
radical departure for Russia from a long history of ad-
herence to territorial principles recognizing the right of
states to determine the citizenship status of individuals
on their territory. But there has been some evidence that
Russia has pursued collective naturalization in Crimea,
Transnistria, and other regions. The issue remains highly
charged and unresolved.71
Finally, in 2007, the Putin administration introduced a
new resettlement program for compatriots (sootechest-
venniki) and granted participants the ability to naturalize
by simplified procedures. According to Oxana Shevel,
the original concept and later amendments intentionally
defined the concept in a plastic way, and the fuzziness
of the compatriots concept means that limiting migra-
tion, employment, and now also citizenship benefits to
participants in the compatriots resettlement program
allows the government to control the composition of
migrants, including the ethno-cultural composition if it
wanted to, without formally declaring such a policy.72
That said, the compatriots program has had only limited
success to date; only thirty thousand people have moved
to Russia since 2006, just one-tenth of the goal.73
The biggest dilemma for Russian citizenship going
forward is likely to be the conflict between Russias
nationalistic turn against foreigners, minorities, and
the globalizing reforms of the 1990s, on the one hand,
and the intensification of a chronic shortage of labor, on
the other. The opposition of these forces often plays a
central role in the history of citizenship throughout the
modern world, and it was central to the era from 1860
to 1914. But the intensity of this conflict in Russia over
12 Problems of Post-Communism November/December 2013
the last decade has rarely been matched. Russia clearly
needs more workers. Even though the excess of immi-
gration over emigration was 6 million between 1992 and
2008, deaths exceeded births by 12.6 million in the same
period, bringing a population decline of 6.6 million. Al-
though there has been a recent improvement in birth
rates and life expectancy, demographers still predict a
massive decline in the working-age population over the
coming decades.74
As in the late imperial era, the regime is going to great
lengths to encourage ethnic Russians to stay in Russia,
to have children, and to remain in the Far East to coun-
ter the perceived Asian demographic threat. But none of
these policies has been very effective, and demographers
are skeptical about their future prospects. Relatively
high wages have pulled millions of workers into Russia
on a temporary or a long-term basis. Comparable to late
imperial policies toward temporary Asian workers, the
regime has imposed guest worker rules that make it dif-
ficult for these laborers to naturalize and thus maintains
their temporary, marginal status. These restrictions could
act as a brake on future labor immigration, especially in
the quite possible event that source country economies
begin to perform better relative to the Russian economy.
Even if guest labor flows continue at their high current
rate, there will still be a massive shortage of labor. Many
analysts conclude that the only realistic solution is to
encourage mass immigration.
But Russia has already accepted more immigrants in
two decades than the entire net immigration to the Rus-
sian Empire from 1828 to 1914.75 Nationalist groups on
the right have made mobilization against immigration
one of their biggest issues, and anti-immigrant sentiment
is popular across the political spectrum.76 Immigration on
a scale to meet labor demands will be difficult to sell to
the public. Exacerbating the problem is the fact that the
most willing migrants have been Muslims from the Cau-
casus and Central Asia or Asians in the Far Eastboth
targets of Russian nationalists and popular prejudice. In
both cases, immigrants have been portrayed as security
riskswhether because of purported sympathies with
Muslim extremism or because of fears of Chinese aims
in the Far East and Chinas massive demographic advan-
tage on the other side of the border.77 Political and nation-
al tensions over immigration show no signs of abating,
and questions about naturalization and the treatment of a
large population of immigrant and guest worker foreign-
ers are likely to remain central to debates about Russian
citizenship for a long time to come.
The dilemma is perhaps even more acute if we turn
 from unskilled low-wage labor to the questions of at-
tracting skilled labor and investors. In the aftermath of
the 1998 economic crisis, many foreign investors, em-
ployees, students, and others in the foreign community
left the country. Vladimir Putin then turned away from
the 1990s attempts to draw foreign investment and as-
serted control over key industries in the gas and oil sec-
tor through renationalization or acquisition by loyal
oligarchs. This model worked acceptably as natural re-
source prices climbed, but most economists agree that
even continuation of an undiversified, fossil-fuel export
economy will be difficult without a return to a more
open economy.
Citizenship policies are a small part of this larger set
of choices, but just as the changes in citizenship policy
of the 1860s and the 1920s were direct results of larger
economic policy choices, so too the future of citizenship
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and migration policies in the Russian Federation will be
closely linked to the general economic line. In the broad-
er picture, then, Russia continues to face a fundamental
dilemma about globalization. Whether it leans toward the
strategy launched in the 1860s and continued right up to
1914, or continues on the path toward an updated variant
of the Soviet autarkic path is one of the most important
questions Russia will face in the coming decades. Citi-
zenship and migration policies will be determined by the
choices Russia makes on this larger agenda.
But perhaps there will be no decisive choice between
these starkly different paths. The trend at the end of the
imperial era was toward finding ways to amalgamate
seemingly incompatible approaches by using citizenship
restrictions to allow certain groups in for temporary work
without allowing them to naturalize or acquire property,
by finding ways to facilitate Jewish and German emigra-
tion while preventing Slavic emigration. By introducing
citizenship policies of this type, the modernizing empire
was able to stay engaged with the world while pursuing
its ethno-national population priorities. Russia seems
to be moving in a comparable direction, seeking to find
ways to shape a workable amalgamation of sharply dif-
ferent policy approaches.
Notes
1. Exceptions include O.E. Kutafin, Rossiiskoe grazhdanstvo (Russian
Citizenship) (Moscow: Iurist, 2004); and Alexander Salenko, EUDO Citizen-
ship Observatory: Country Report. Russia (Florence: European University
Institute, July 2012), at http://eudo-citizenship.eu/admin/?p=file&appl=count
ryProfiles&f=Russia.pdf, accessed September 27, 2013.
2. Rogers Brubaker, Citizenship and Nationhood in France and Germany
(Cambridge, MA: Harvard University Press, 1992).
3. Andreas Fahrmeir, Citizenship: The Rise and Fall of a Modern Concept
(New Haven: Yale University Press, 2007); Fahrmeir, Citizens and Aliens:
Foreigners and the Law in Britain and the German States, 17891870 (New
York: Berghahn Books, 2000); Patrick Weil, How to Be French: Nationality in
the Making Since 1789 (Durham: Duke University Press, 2008).
4. James Kettner, The Development of American Citizenship, 16081870
(Chapel Hill: University of North Carolina Press, 1978).
5. For a bibliography of their works, see Vladimir E. Grabar, The History
of International Law in Russia: A Biobibliographical Study (New York: Oxford
University Press, 1990).
6. Both the concept of path dependency and the structure of most
historical narratives tend to emphasize the impact of the recent past and make
it difficult to bring comparable periods from the more distant past into the
analysis. One cannot simply treat seventy-five years of communism as an ir-
relevant aberration, but I argue that, as with religion, citizenship policy today
has a great deal more in common with prerevolutionary policy than with the
Soviet era. For interesting arguments along these lines, see Stefan Hedlund,
Russian Path Dependence (London: Routledge, 2005).
7. W.M. Reger IV, Baptizing Mars: The Conversion to Russian Ortho-
doxy of European Mercenaries During the Mid-Seventeenth Century, in The
Military and Society in Russia, 14501917, ed. Eric Lohr and Marshall Poe
(Leiden: Brill, 2002), 391; Richard Hellie, Enserfment and Military Change
in Muscovy (Chicago: University of Chicago Press, 1971).
8. For an important recent reevaluation of the significance of seventeenth-
century foreign trade, see Jarmo Kotilaine, Russias Foreign Trade and Eco-
nomic Expansion in the Seventeenth Century (Leiden: Brill, 2005).
9. Joseph T. Fuhrmann, The Origins of Capitalism in Russia: Industry
and Progress in the Sixteenth and Seventeenth Centuries (Chicago: Quadrangle
Books, 1972); Kotilaine, Russias Foreign Trade.
10. E. Zviagintsev, Slobody inostrantsev v Moskve XVII veka (Foreign
Settlements in Seventeenth-Century Moscow), Istoricheskii zhurnal 126, no.
2 (1944): 81. On the power of the Church vis--vis the tsar on policy toward
foreigners, see S.P. Orlenko, Vykhodtsy iz zapadnoi Evropy v Rossii: pravovoi
status i realnoe polozhenie (Immigrants from Western Europe to Russia: Their
Status Under Law and in Actual Practice) (Moscow: Drevlekhranilishche,
2004), 10268.
11. D.V. Tsvetaev, Protestanstvo i protestanty v Rossii do epokhi preobra-
zovanii (Protestantism and Protestants in Russia Before the Age of Enlighten-
ment) (Moscow, 1890), 329.
12. D.V. Tsvetaev, Obrusenie zapadnoevropeitsev v Moskovskom go-
sudarstve (The Russification of Western Europeans in the Muscovite State)
(Warsaw: Tip. Varshavskogo uchebnogo okruga, 1903), 12; Vladimir Gessen,
Poddanstvo Rossiiskoi imperii: Ego ustanovlenie i prekrashchenie (istoriko-
pravovoi analiz) (Subjecthood of the Russian Empire: Its Acquisition and Loss
[A Historical-Legal Analysis]) (St. Petersburg, 1909), 203; A.S. Muliukina,
Priezd inostrantsev v drevniuiu Rus (The Reception of Foreigners in Rus),
Zhurnal Ministerstva narodnogo prosveshcheniia (November 1907), 144.
13. The law was first promulgated in 1834, but it recognized administrative
practices going back much earlier (Russian State Archive for Military History
[RGVIA], f. 405, op. 6, d. 3933, l. 2).
14. Horace W. Dewey and Ann M. Kleimola, Suretyship and Collective
Responsibility in Pre-Petrine Russia, Jahrbcher fr Geschichte Osteuropas
18, no. 3 (1970): 33754.
15. Gustav Alef, Das Erlschen des Abzugsrechts der moskauer Bojaren
(The Loss of the Right of Departure of the Moscow Boyars), Forschungen zr
osteuropischen Geschichte 10 (1965): 3941. See the famous case of Patrick
Gordon, who was denied permission to leave several times; when he was finally
allowed to go, his wife remained behind as insurance that he would return
(Passages from the Diary of General Patrick Gordon in the Years 16351699
[New York: De Capo Press, 1968], 110).
16. M.I. Mysh, Ob inostrantsakh v Rossii (On Foreigners in Russia) (St.
Petersburg: A. Bekt, 1911), viviii.
17. Polnoe sobranie zakonov Rossiiskoi imperii (Complete Collection of
Laws of the Russian Empire, henceforth PSZ), 55 vols. (St. Petersburg: 1830
1916), 26, no. 1910, 59395; Erik Amburger, Die Anwerbung auslnderischer
Fachkrfte fr die Wirtschaft Russlands vom 15ten bis ins 19te Jahrhundert
(The Enlistment of Foreign Skilled Workers in the Russian Economy from
the Fifteenth to the Nineteenth Centuries) (Wiesbaden: Otto Harrassowitz,
1968), 7576.
Lohr Russian Citizenship 13
 18. PSZ 7, no. 4378, 16774.
19. RGVIA, f. 401, op. 4/928, d. 60, l. 14; Vladimir M. Kabuzan, Emi-
gratsiia i reemigratsiia v Rossii v XVIIInachale XX vek (Emigration and Return
Migration in Russia from the Eighteenth to the Beginning of the Twentieth
Centuries) (Moscow: Nauka, 1998), 59.
20. PSZ 9, zak. sost. (1899), art. 821.
21. State Archive of the Russian Federation (GARF), f. 102, II deloproiz-
vodstvo (1884), d. 515; PSZ 14, no. 487 (O pasportakh [On Passports]).
22. GARF, f. 102, op. 76a, d. 1732, l. 7 (Po voprosu o prave pereseleniia
v Rossiiu inostrannykh evreev [On the Right of Foreign Jews to Resettle in
Russia]), sv. zak. t. 14 (1890), ust. pasp. st. 290 (st. 530 po prod. 1887); GARF,
f. 102, II deloproizvodstvo (1885 g.), op. 42, d. 435, l. 4 (governor-general of
Kiev, Podolia, and Volynia to Ministry of the Interior, July 9, 1885).
23. M.A. Lozin-Lozinskii, Priniatie v russkoe poddanstvo (Naturaliza-
tion of Russian Subjects), Pravo, no. 4 (1898): 1015; no. 1 (1899): 2229;
no. 2 (1899): 7984.
24. For a collection of such cases, see GARF, f. 102, op. 76a, d. 1732.
25. N.L. Tudorianu, Emigratsionnaia politika i zakonodatelstvo Rossii v
nachale XX veka (Emigration Policies and Laws of Russia at the Beginning
of the Twentieth Century) (Chiinu: Ministry of Education and Science
of the Republic of Moldova, 2000), 4; Hannelore Burger, Passwesen und
Staatsbrgerschaft (Passports and State Membership), in Grenze und Staat:
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soiuznykh respublik o pravovom polozhenii inostrannykh fizicheskikh i iuridi-
cheskikh lits (Legislation and International Agreements of the USSR and Allied
Republics on the Legal Position of Foreign Physical and Juridical Individuals)
(Moscow: RSFSR Peoples Commissariat of Justice, 1926), 23.
37. Ibid., 93.
38. On the welcoming attitude toward previously oppressed religious
groups, see the correspondence between diplomatic officials and groups of
Molokane and other sects in California about a potential return migration
(GARF, f. r364, op. 1, d. 2, ll. 52158).
39. Z.S. Bocharova, Russkie bezhentsy: Problemy rasseleniia, vozvrash-
cheniia na Rodinu, uregulirovaniia pravovogo polozheniia (19201930-e gody).
Sbornik dokumentov i materialov (Russian Refugees: Problems of Settlement,
Return to the Homeland, and Regulation of Their Legal Position (1920s1930s).
A Collection of Documents and Materials) (Moscow: ROSSPEN, 2004), 22.
40. Andrea Graziosi, Foreign Workers in Soviet Russia, 192040: Their
Experience and Their Legacy, International Labor and Working-Class History
33 (Spring 1988): 41. Several group immigrationsincluding the Armenians,
Finns, and Galicianswere not handled by the Council of Labor and Defense
(Sovet truda i oborony, STO) and thus do not appear in these statistics.
41. Resolution of the Council of Peoples Commissars, O konfiskatsii
vsego dvizhimogo imushchestva grazhdan, bezhavshikh za predely RSFSR
(On the Confiscation of All Movable Property from Citizens Who Have Fled
Beyond the Boundaries of the RSFSR), Dekrety Sovetskoi vlasti (Decrees of

Passwesen, Staatsbrgerschaft, Heimatrecht und Fremdengesetzgebung in der
sterreichischen Monarchie 17501867 (The Border and the State: Migration
Documents, State Citizenship, Residency Laws, and Foreign Law in the Aus-
trian Monarchy, 17501867), ed. Waltraud Heindl and Edith Saurer (Vienna:
Bhlau, 2000), 139.
26. Nancy L. Green and Franois Weil, eds., Citizenship and Those Who
Leave: The Politics of Emigration and Expatriation (Urbana: University of
Illinois Press, 2007), 162.
27. A. Ia[novskii], Pasport zagranichnyi (The Foreign Passport), Entsik-
lopedicheskii slovar (Encyclopaedic Dictionary) (St. Petersburg: I.A. Efron,
1897), 44:92527; Tudorianu, Emigratsionnaia politika, 11; V.G. Chernukha,
Pasport v Rossii, 17191917 (The Passport in Russia, 17191917) (St. Peters-
burg: Liki Rossii, 2007), 253; Vadim Kukushkin, From Peasants to Labourers:
Ukrainian and Belarusan Immigration from the Russian Empire to Canada
(Montreal: McGill-Queens University Press, 2007), 58.
28. Russian State Historical Archive (RGIA), Pechatnye zapiski (Printed
Notes [P.Z.]) 2530, 5 (Ministry of Trade and Industry, Department of Naval
Commerce, July 8, 1909, Po voprosu ob obrazovanii mezhduvedomstvennogo
soveshchaniia dlia vyrabotki zakona ob emigratsii [On the Establishment of
Interagency Sessions to Work Out an Emigration Law]); RGIA, P.Z. 2531,
Ocherk istorii i sovremennogo sostoianiia otkhoda na zarabotki za granitsu
v Zapadnoi Evrope i v Rossii (An Essay on the History and Contemporary
Situation Regarding Emigration for Work Abroad in Western Europe and in
Russia).
29. GARF, f. 102, II deloproizvodstvo (1890 g.), d. 104, ch. 3, l. 18 (Warsaw
governor-general to Ministry of the Interior, February 28, 1894).
30. Tudorianu, Emigratsionnaia politika, 13.
31. V.V. Engel, Evreiskii vopros v russko-amerikanskikh otnosheniiakh:
Na primere pasportnogo voprosa, 18641913 (The Jewish Question
in Russo-American Relations: A Case Study of the Passport Question,
18641913) (Moscow: Nauka, 1998), 4243.
32. On this point, see Dietmar Neutatz, Die deutsche Frage im
Schwarzmeergebiet und in Wolhynien: Politik, Wirtschaft, Mentalitten und
Alltag im Spannungsfeld von Nationalismus und Modernisierung (18561914)
(The German Question in the Black Sea Region and in Volynia: Politics,
Economy, Mentalities, and Everyday Life in the Context of Nationalism and
Modernization (18561914)) (Stuttgart: Franz Steiner, 1993).
33. Engel, Evreiskii vopros, 4243; A. Ginzburg, Emigratsiia evreev iz
Rossii (Jewish Emigration from Russia), Evreiskaia entsiklopediia (Jewish
Encyclopedia) (Moscow: Terra, 1991), 26467.
34. Kukushkin, From Peasants to Labourers, 57.
35. GARF, f. 102, op. 76a, d. 1569, l. 25 (Zhurnal EKO, August 10,
1893).
36. Vladimir V. Egorev, Georgii N. Lashkevich, Mark A. Plotkin, and Boris
D. Rozenblium, Zakonodatelstvo i mezhdunarodnye dogovory Soiuza SSR i
the Soviet Authorities) (Moscow: Gos. izd. politicheskoi literatury, 1977),
11:24546.
42. Zoia S. Bocharova, Dokumenty o pravovom polozhenii Russkoi emi-
gratsii 192030-kh godov (Documents on the Legal Position of the Russian
Emigration in the 1920s1930s), in Istochniki po istorii adaptatsii rossiiskikh
emigrantov v XIXXX vv. Sbornik statei (Sources on the History of the Ad-
aptation of Russian Emigrants in the Nineteenth and Twentieth Centuries: A
Collection of Articles) (Moscow: Russian Academy of Sciences, Institute of
Russian History, 1997), 6364; George Ginsburgs, The Soviet Union and
the Problem of Refugees and Displaced Persons, 19171956, American
Journal of International Law 51, no. 2 (1957): 32930; Russkaia voennaia
emigratsiia 20-kh40-kh godov: Dokumenty i materialy (The Russian Military
Emigration of the 1920s1940s: Documents and Materials) (Moscow: Geia,
1998), vol. 1, 81.
43. Vladimir V. Egorev, Pravovoe polozhenie fizicheskikh i iuridicheskikh
lits SSSR za granitsei (sistematizirovannye materialy s kommentariiami) (The
Legal Status of Physical and Juridical Individuals of the USSR Abroad [System-
atized Materials with Commentary]) (Moscow: RSFSR Peoples Commissariat
of Justice, 1926), 3035.
44. Timothy A. Taracouzio, The Soviet Union and International Law: A
Study Based on the Legislation, Treaties, and Foreign Relations of the Union
of Socialist Soviet Republics (New York: Macmillan, 1935), 121; M.A. Plotkin,
Legal Status of Foreigners in the USSR (Moscow: USSR Chamber of Com-
merce, 1934), 22.
45. GARF, f. r-393, op. 41, d. 18 (Protocols from the Sessions of the Pre-
sidium of VTsIK on Naturalization and on the Implementation of the VTsIK
Decree of December 15, 1921, on the Deprivation of Russian Citizenship).
46. Peter Gatrell, War, Population Displacement, and State Formation in
the Russian Borderlands, 19141924, in Homelands: War, Population, and
Statehood in Eastern Europe and Russia, 19181924, ed. Nick Baron and
Gatrell (London: Anthem Press, 2004), 26; Iurii Aleksandrovich Poliakov, ed.,
Naselenie Rossii v XX veke (The Population of Russia in the Twentieth Century)
(Moscow: ROSSPEN, 2000), 1:13442; Bocharova, Russkie bezhentsy, 20.
47. GARF, f. r-393, op.43a, d. 1722, ll. 34 (NKVD Circular to Governors
on Rules for Repatriates Returning as a Result of Amnesty According to the
Decree of December 15, 1921).
48. GARF, f. r-393, op. 43a, d. 1651, l. 77 (Head of Administrative Depart-
ment NKVD L.P. Diakonov, Secret Note, September 29, 1928); Henning Bauer,
Andreas Kappeler, and Brigitte Roth, eds., Die Nationalitten des Russischen
Reiches in der Volkszhlung von 1897 (The Nationalities of the Russian Empire
in the Census of 1897) (Stuttgart: Franz Steiner, 1991), 32B:211.
49. Graziosi, Foreign Workers, 43.
50. The French Revolution, Peter Sahlins has convincingly shown, came
in the midst of fundamental changes that started in the mid-eighteenth century
and concluded in 1818. The American Revolution was an important event in the

14 Problems of Post-Communism November/December 2013

 history of U.S. citizenship but certainly not transformative. See Peter Sahlins,
Unnaturally French: Foreign Citizens in the Old Regime and After (Ithaca:
Cornell University Press, 2004).
51. Gennadii P. Dolzhenko, Istoriia turizma v dorevoliutsionnoi Rossii
i SSSR (The History of Tourism in Prerevolutionary Russia and the USSR)
(Rostov: Izd. Rostovskogo universiteta, 1988), 150; Dennis B. Shaw, The
Soviet Union, in Tourism and Economic Development in Eastern Europe and
the Soviet Union, ed. Derek Hall (London: Belhaven Press, 1991), 137.
52. Anne E. Gorsuch and Diane P. Koenker, eds., Turizm: The Russian
and East European Tourist Under Capitalism and Socialism (Ithaca: Cornell
University Press, 2006); V.E. Bagdasarian, ed., Sovetskoe zazerkale: inostrannyi
turizm v SSSR v 19301980-e gody (Behind the Soviet Looking Glass: Foreign
Tourism in the USSR in the 1930s1980s) (Moscow: Forum, 2007).
53. Shawn Salmon, To the Land of the Future: A History of Intourist and
Travel to the Soviet Union, 19291991 (Ph.D. diss., University of California,
Berkeley, 2008).
54. Alan Dowty, Closed Borders: The Contemporary Assault on Freedom
of Movement (New Haven: Yale University Press, 1987), 7475; G.A. Razina,
N.I. Rotova, and Iu.V. Sigachev, Ne priznaem vashego prava na akt nasiliia
nad nami: k istorii lisheniia sovetskogo grazhdanstva g. P. Vishnevskoi i M.L.
Rostropovicha (We Will Not Recognize Your Right to Enact Violence Against
Us: On the History of P. Vishnevskaia and M.L. Rostropovichs Deprivation
of Soviet Citizenship), Istoricheskii arkhiv 5 (1993): 16186.
Downloaded by [King's College London] at 14:44 26 April 2016
55. Judith Matz and Margery Sanford, Separated Soviet Families (Miami:
South Florida Conference on Soviet Jewry, 1976).
56. Hall, Tourism and Economic Development, 2226.
57. Victor Zaslavsky and Robert Brym, Soviet Jewish Emigration and Soviet
Nationality Policy (London: Macmillan, 1983), 1, 12.
58. Olga Chudinovskikh et al., SOPEMI (Continuous Reporting System
on Migration) Report: The Russian Federation. Country Report, 2010, 89, at
www.migrationinformation.org/DataHub/countrydata/files/RussianFederation-
CountryReport_SOPEMI2010.pdf, accessed September 27, 2013.
59. Despite this constitutional right, local authorities have managed to
continue to sharply limit the legal ability of citizens to settle where they wish.
See Matthew Light, Regional Migration Policies in Post-Soviet Russia: from
Pervasive Control to Insecure Freedom (Ph.D. diss., Yale University, 2006).
60. Ibid., 74.
61. Chudinovskikh et al., SOPEMI Report, 92.
62. Light, Regional Migration, 9; Lowell Barrington, Erik S. Herron,
and Brian D. Silver, The Motherland Is Calling: View of Homeland Among
Russians in the Near Abroad, World Politics 55, no. 2 (2003): 290313; Oxana
Shevel, National Identity and International Institutions: Refugee Policies in
Post-Communist Europe. A Comparative Study of the Russian Federation,
Ukraine, the Czech Republic, Poland, 19902001 (Ph.D. diss., Harvard
University, 2003). A June 17, 1993, law specifically allowed former Soviet
citizens to naturalize without renouncing their prior citizenship (Shevel, The
Politics of Citizenship Policy in Post-Soviet Russia, Post-Soviet Affairs 28,
no. 1 [2012]: 121).
63. Ineta Ziemele, State Continuity and Nationality: The Baltic States and
Russia (Leiden: Martinus Nijhoff, 2005).
64. Shevel, The Politics of Citizenship Policy, 12930; Shevel, National
Identity, 15; Light, Regional Migration, 11.
65. Mikhail A. Alexseev, Immigration Phobia and the Security Dilemma:
Russia, Europe, and the United States (Cambridge: Cambridge University
Press, 2006).
66. Shevel, The Politics of Citizenship Policy, 13334; Svetlana Gan-
nushkina, O polozhenii inostrannykh grazhdan v Rossii posle izmeneniia
zakonodatelstva v oblasti grazhdanstva i pravovogo polozheniia inostrannykh
grazhdan. Vozmozhnosti legalizatsii (On the Position of Foreign Citizens in
Russia after the Changes to the Law on Citizenship and the Legal Positino of
Foreign Citizens: Possibilities for Legalization), in Priobretenie grazhdanstva
RF i legalizatsiia inostrannykh grazhdan v Rossii (The Acquisition of Russian
Citizenship and the Legalization of Foreign Citizens in Russia), ed. E.A. Bo-
brov, Iu.Ia. Chadrina, and the Memorial Center for Human Rights (Moscow:
R. Valent, 2005).
67. Light, Regional Migration, 92.
68. Shevel, The Politics of Citizenship Policy, 128.
69. Chudinovskikh et al., SOPEMI Report, 89; RUSSIA: Citizenship
Laws Raise Concerns Across CIS, Oxford Analytica Daily Brief Service
(October 9, 2008).
70. Independent International Fact-Finding Mission on the Conflict in
Georgia: Report Commissioned by the European Union Council, chaired by
Heidi Tagliavini (September 2009), 2:14684. The Tagliavini report strongly
argues that the populations of South Ossetia and Abkhazia were given a rea-
sonable six-month period to opt out of ascribed collective naturalization as
Georgian citizens according to a 1993 law. Given that Georgia had a strong
ban on dual citizenship, the report argues that international and Georgian law
both prohibited recognition of these populations as Russian citizens unless
they were formally released from Georgian citizenship.
71. The policy has also faced practical barriers, including the desire of many
to use their Russian citizenship as a means to migrate to the Russian Federa-
tion. Various administrative measures have attempted to deprive these new
citizens of the ability to acquire a residence permit in the Russian Federation,
but such actions undermine the international status of this category of passport
and have proven difficult to enforce. See Rebecca Chaimberlain-Creanga and
Lyndon Allin, Acquiring Assets, Debts, and Citizens: Russia and the Micro-
Foundations of Transnistrias Stalemated Conflict, Demokratizatsiya 18, no.
4 (2010): 32956; and Florian Mhlfried, Citizenship at War: Passports and
Nationality in the 2008 RussianGeorgian Conflict, Anthropology Today 26,
no. 2 (2010): 813.
72. Shevel, The Politics of Citizenship Policy, 13840.
73. Georgi Lomsadze, Reports: Russia Stops Converting Armenian Com-
patriots into Russians, Tamada Tales: A Daily Feast of News from the South
Caucasus (December 5, 2012), at www.eurasianet.org/node/66254, accessed
September 27, 2013.
74. Grigory Ioffe and Zhanna Zayonchkovskaya, Immigration to Rus-
sia: Why It Is Inevitable, and How Large It May Have to Be to Provide the
Workforce Russia Needs, NCEEER Working Paper no. 824-05g (January
21, 2010), 13; Nicholas Eberstadt, Russias Peacetime Demographic Crisis:
Dimensions, Causes, Implications (Washington, DC: National Bureau of Asian
Research, 2010).
75. V.V. Obolenskii, Mezhdunarodnye i mezhkontinentalnye migratsii
v dovoennoi Rossii i SSSR (International and Intercontinental Migration in
Prewar Russia and the USSR) (Moscow: Central Statistical Administration of
the USSR, 1928), 108, 110.
76. One of the most active far right groups, the Movement Against Illegal
Immigration, was banned by the Moscow City Court in April 2011 for inciting
ethnic hatred (see www.dpni.org, accessed September 27, 2013). See Marlne
Laruelle, ed., Russian Nationalism and the National Reassertion of Russia (New
York: Routledge, 2009); and Viktor A. Shnirelman, Porog tolerantnosti:
ideologiia i praktika novogo rasizma (On the Edge of Toleration: Ideology and
Practice of the New Racism) (Moscow: Novoe literaturnoe obozrenie, 2011).
77. Alexseev, Immigration Phobia.
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Lohr Russian Citizenship 15