5HSRUWRQ5XVVLD naturalisation based on the simplified procedure was only possible for Kyrgyz citizens born in Russia or who permanently lived on the territory of Russia until 21 December 1991. According to the bilateral agreement the right to naturalisation (within three months from the date of submission of documents) was given to any Kyrgyz citizen who had permanent residence in Kyrgyzstan (on 15 December 1990) or Russia (on 9 November 1997). Thus, we can dispute the placatory statements of the Russian authorities that denunciation of the bilateral agreement would not have significant consequences for Kyrgyz citizens who want to obtain Russian citizenship. Behind these actions other motives may be hidden, such as the desire to close the border of Russia to migrants of a non-Russian nationality. Some evidence to support this conclusion comes from the press release of the Russian Government on 1 March 2012. According to official statistics, the total number of Kyrgyz citizens who have obtained Russian citizenship based on the simplified naturalisation procedure is estimated at 300,000. There is also information regarding the proportion of the citizens granted Russian citizenship by this simplified naturalisation procedure, namely 60% of Kyrgyz nationality, 20% of Uzbek nationality and 20% of Russian nationality.57 Most likely this disproportion forced the Russian authorities to make this aspect of their immigration policy stricter. 5.2.3 Loss of citizenship According to the provisions of the 1993 Russian Constitution (art.6 (3), a citizen of the Russian Federation may not be deprived of his or her citizenship or of the right to change it. Thus, the legal mechanism for the deprivation of citizenship no longer existed. However, Chapter 3 of the 2002 Citizenship Law does provide grounds for the termination of Russian citizenship. The only reason which is de facto applicable in the citizenship practice in the Russian Federation is voluntary loss of Russian citizenship. According to the Article 19 of the 2002 Law, a person residing in the territory of the Russian Federation may renounce their Russian citizenship voluntarily. Renunciation of Russian citizenship by a person residing in the territory of a foreign state must be done by means of a voluntary expression of his or her will according to the simplified procedure. Loss of Russian citizenship of a child who has one parent who is a Russian Federation citizen and whose other parent is a foreign citizen or whose sole parent is a foreign citizen shall be effected in the simplified procedure upon an application filed by both parents or upon an application filed by the sole parent. Under the terms of the 2002 Citizenship Law (art.21), there is also an additional option for termination of citizenship, the Choice of another Citizenship in the case of a change of the border of the Russian Federation. Thus, when territorial transformations occur as a result of a change of the State Border of the Russian Federation under an international treaty of the Russian Federation, citizens of the Russian Federation residing in the territory which has undergone the above transformations shall be entitled to retain or change their citizenship in accordance with the terms of this international treaty. However, this provision remains hypothetical at present. 5.2.4 Dual/multiple citizenship According to the Russian Constitution (art.62), a citizen of the Russian Federation may hold citizenship of a foreign state (dual citizenship) according to federal law or an international agreement of the Russian Federation.58 The possession of foreign citizenship by a citizen of the 57 Now it is more difficult for citizens of Kyrgyzstan to obtain Russian citizenship. RBK. 21.03.2012. [3+&,-&"&= K1+%1911 /#(#+6 .$),"## ./&/6 +)..12"&=1. ?5K. 21 =&+/& 2012 %)-&.] http://top.rbc.ru/politics/21/03/2012/642810.shtml 58 Russia has concluded only two international agreements regarding dual citizenship: the Treaty between the Russian Federation and the Republic of Tajikistan regarding regulation of the issues of dual citizenship (07.09.1995), and the 56&$6(8'2&,7&5‹$XWKRU