On September 9, 2015, the Federal Service for Supervision of Communications, Information Technology and Mass Communications (the “Roskomnadzor”) reported on its website that it blocked an extensive online database of more than 1.5 million Russian citizens for violations of Russian Federal Law No. 242-FZ 2014, commonly known as the Data Localization Law. With the new Russian Data Localization Law having taken force only recently (September 1 2015), a question was how active the regulator would be with enforcing the law. While the Roskomnadzor announced that it will not be conducting compliance checks of technology companies such as Facebook, Google and Twitter before January 2016 at the earliest, it was unclear whether this would be the general approach. It is clear now that it was not and the Data Localization law is being enforced along with the Law on Personal Data as the Roskomnadzor works its way through its annual inspection plan. The blocked site that was the subject of this first enforcement action, http://abonenty-chast2.pw, reportedly contained personal information such as name, birth date, address, phone number and workplace and was hosted outside of Russia. The site also was placed on a register of violators of the Data Localization Law. No further details were provided by the Roskomnadzor on the action.

According to a statement released by the Roskomnadzor on September 2, the following multinational companies have already agreed to comply with the law’s data localization requirements: Samsung, Lenovo Group Ltd., AliExpress, Booking.com, PayPal, eBay Inc., Uber Technologies Inc. and Citibank. The Roskomnadzor has also been engaging in discussions with Google, Facebook and Twitter. Russian newspaper Kommersant reported on September 10 that Apple entered into a contract with the Russian data center IXcellerate to move Russian citizens’ personal data to Russia. Kommersant also reported that IXcellerate was engaged by Booking.com to host their data on Russian citizens.