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Thanks for your response. I've had a quick skim of the acts that ARE in force and I don't see anything expressly prohibiting adoption of a child who is a foreign national. This refusal to issue a letter... have they actually cited a material reason or is it simply a case of SA bureaucracratic feetdargging?
ETA: What I understand from the Russian side (info via the Russian embassy in Bern) is that the local authorities' input basically consists of a home study by a qualified official from the welfare department (or an accredited social worker), which SA seems to be issuing to foreigners adopting South African babies as well as South Africans adopting locally without any distinction being drawn between the groups, and a letter from the embassy in Moscow.
Granted, I've only done a cursory skim of the SA legislation, but according to the Russians (here in Bern) prospective foreign adopters are subject to the same procedure in Russia regardless of where they are from, meaning that all you need is a home study from your country's welfare department and "a letter from the embassy in Moscow stating that a visa will be granted to the child, provided that he or she meets the requirements for a visa." So basically, once you have the home study (which is the same for all adopters in South Africa) it becomes a visa issue.
I'll have to do a proper reading over the weekend, but the way it looks from my reading of the SA law as it stands, the welfare department doesn't (as yet) have the authority to make distinctions between local and foreign adoptions. Any thoughts?