April 24, 2013

II. The “Foreign Agents” Law

On July 20, 2012, less than three months after his inauguration, President Putin signed Law No. 121-FZ, which requires, among other things, organizations that receive foreign funding and engage in “political activities” to register as “foreign agents.”[8]

Before signing the law, on July 10 President Vladimir Putin promised a threefold increase in domestic funding for Russian nongovernmental organizations (NGOs), and in March 2013 he announced that two billion rubles (US$64.8 million) had been allocated for 2013 for this purpose.[9]

The new legislation further expanded the already extremely intrusive state control over NGOs that receive foreign funding as well as representative offices/branches of foreign organizations operating in Russia.[10]

Alexander Sidyakin, the United Russia deputy who sponsored Law No. 121-FZ (and the amendments to the public assembly law), said it did not aim at “prohibiting or restricting activities or undermining the rights of nongovernmental organizations but rather at helping to ensure transparency for those who act as foreign agents, to make that information clear for Russian citizens.”[11]  Other Duma deputies from United Russia said the law was aimed at curbing “foreign interference” in Russia’s affairs.[12]

Legal experts in Russia and abroad criticized the law’s overly broad scope for interpretation, the breakneck speed with which it was adopted, and the additional burdens it imposed on NGOs. It was also deplored by most of Russia’s leading human rights groups as part of an effort to tar advocacy groups as “spies” or “hidden enemies.”

Key Provisions

Scope

Law No. 121-FZ amends five laws regulating NGOs: the Law on Public Associations; the Law on Noncommercial Organizations; the Criminal Code; the Code of Criminal Procedure; and the Law on Counteracting Legalization (Money Laundering) of Incomes Received in a Criminal Way, and Financing Terrorism.[13]

Law No. 121-FZ applies to the various legal forms of Russian NGOs and introduces additional reporting requirements for representative offices or branches of foreign organizations.  It also exempts certain types of noncommercial organizations (NCOs): state corporations, state companies as well as NCOs established by them, state and municipal (including budgetary) institutions, political parties, religious organizations, associations of employers and chambers of commerce.[14]

The “Foreign Agent” Concept

The new law introduces the concept of an NGO “performing the functions of a foreign agent,” to refer to Russian noncommercial organizations or public associations that receive foreign funding and participate, including in the interests of its foreign funding sources, in “political activity” in Russia.[15]

The law covers funding received from a wide range of sources, including “foreign states [,] … international and foreign organizations, foreign citizens and persons without citizenship or persons authorized by them and [or] Russian legal entities that receive funds and other property from the same.”[16]

The law stipulates that an NGO is considered to be carrying out political activity if it “participates (including through financing) in organizing and implementing political actions aimed at influencing decision-making by state bodies intended to change state policy pursued by them, as well as in the shaping of public opinion for the aforementioned purposes.”[17] Such activities are considered political regardless of whether an organization is conducting them in the interest of the foreign entity that is funding them.[18]

The law also introduces a requirement to mark all “materials” published or distributed by NGOs acting as “foreign agents” as such.[19]

Registration of “Foreign Agents”

Law No. 121-FZ requires that NCOs and public associations apply to be included in the special registry of “foreign agents” when they submit their registration documents.[20] Registered organizations that intend to perform activities that fall under the scope of those performed by “foreign agents” must apply to be included in the registry “prior to commencing such activities.”[21]

The law does not establish clearly the registration procedure, specifying only that the procedure for the inclusion of NCOs into the registry as well as maintenance of the registry fall under the scope of responsibilities of a “designated agency,” which at the moment is the Ministry of Justice.[22] The law also does not set out how an organization can remove itself from the registry.[23]

Additional Reporting Requirements

Law No. 121-FZ requires NGOs that “perform the functions of ‘foreign agents’” to:

  • Maintain separate records for expenditure of funds received from foreign sources (in addition to the regular reporting on funding sources and expenditures that NGOs must submit to the Tax Service and the Ministry of Justice);
  • Submit reports on their management team and their activities twice a year (as opposed to yearly reports required of other NGOs);
  • Submit quarterly expense reports to a “designated body” (as opposed to yearly expense reports required of other NGOs);
  • Conduct a compulsory annual audit.[24]

In addition, the law requires foreign organizations that operate in Russia through their representative offices or branches to conduct a compulsory annual audit by a Russian auditing company and submit the results of the audit to a designated agency, which must publish the results online and distribute them to the media.[25]

Additional Governmental Inspections and Oversight

Law No. 121-FZ law allows Russian authorities to conduct annual planned inspections of organizations “that perform functions of ‘foreign agents.’” [26] For all other legal entities, including NCOs, planned inspections take place once every three years.[27]

The law expands grounds for conducting unannounced inspections to cases in which:

  • The “foreign agent” does not comply with an official warning to remedy a violation by the set deadline;
  • The designated agency receives information from individual citizens, legal entities, or mass media alleging that the “foreign agent” might be involved in “extremist” activities;
  • The designated agency receives information from state or municipal authorities that that an organization that performs the functions of a “foreign agent” violated Russian law;
  • The designated agency receives a request to conduct an unannounced inspection from a prosecutor’s office.[28]

The law also authorizes government agencies to inspect the registered representative or branch offices of foreign organizations.[29] In January 2013 the Ministry of Justice proposed amendments that, if adopted, would expand the grounds for unannounced inspections for all NGOs in the same manner.[30]

The new law requires the designated agency to provide the Duma with annual reports on the former’s monitoring of “foreign agent”’ activities, including the latter’s involvement in “political activities” and information on funding sources and expenditures.[31]

Finally, the law introduces new measures to monitor all revenue received from foreign sources if the amount is equivalent to or exceeds 200,000 rubles (approximately US$6,500).[32]

Penalties

Suspension

The new legislation allows authorities to suspend the activities of an organization that “performs functions of a foreign agent” but failed to register as one and freeze its assets for up to six months.[33] The suspension decision, issued by the “designated agency,” can be appealed. The law further stipulates that the “foreign agent” whose activities have been suspended will be given a deadline, up to six months, to remedy the violation by applying to be included in the registry of “foreign agents” and can resume its activities once it has been added to the registry.[34]

The suspension decision can be made entirely at the discretion of the “designated agency” (presumably, the Ministry of Justice). The International Center for Not-For-Profit Law, an expert organization that promotes the improvement of the legal framework regulating NGOs, noted in its overview of the law, “It is easy to imagine a disagreement between the MoJ and an NCO on what constitutes a ‘political activity’ in which the NCO insists that its activities are purely youth (which are excluded from the scope of ‘political activities’ under the Law), and an MoJ official insisting that its activity is ‘political.’”[35]

Administrative and Criminal Liability

Amendments to Russia’s administrative and criminal codes introduced harsh administrative and criminal sanctions for organizations and their leaders who fail to comply with Law No. 121-FZ.[36]

Failure to submit relevant activity reports and other information on time or provision of “incomplete or erroneous information”[37] is punishable by a warning or fines of up to 30,000 rubles (approximately $980) for individuals and up to 300,000 rubles (approximately $9,700) for legal entities.[38]

Failing to register as a “foreign agent” is punishable by a maximum fine of 300,000 rubles for individuals and up to 500,000 rubles (approximately $16,280) for organizations.[39]

The law also established a maximum fine of 300,000 rubles for individuals and up to 500,000 for organizations for failure to mark materials published or distributed by a “foreign agent” as such.[40]

Law No. 121-FZ added two new offenses to the Criminal Code relating to all NGOs. First, article 239 of the Criminal Code, as amended, established criminal liability for creating and managing a noncommercial organization or a representative office or branch of a foreign organization whose “activities are connected with inciting citizens to refuse to fulfill their civil duties” or commit other unlawful acts.[41] The law does not provide a clear definition of what constitutes such activities. Furthermore, the text of the law does not specify whether the “disobedience” must, in fact, take place for the law to be applied. Criminal penalties for this new type of offense range from a fine of up to 200,000 rubles (approximately $6,500) to up to three years in prison.[42] Participation in and “propaganda” for such activities can lead to a fine of up to 120,000 rubles (approximately $3,900) or a maximum two-year prison term. [43]

Secondly, a new article, article 330.1 of the Criminal Code, introduces a new type of offense: intentional or “malicious” failure to submit documents necessary for the inclusion of the organization in the registry of “foreign agents.”[44] This is punishable by a fine of up to 300,000 rubles or a maximum two-year prison sentence.[45]

Controversy about Implementation

As detailed below, Law No. 121-FZ left Ministry of Justice officials and NGOs alike confused about how aspects of the “foreign agents” law would be implemented and especially about how the term “political activity” would be interpreted. On several occasions Ministry of Justice officials expressed uncertainty about its competence and willingness to implement it.

Implementation became a subject of rare public disagreement among governmental bodies. For example, at a January 2013 roundtable discussion in the Duma a United Russia deputy asked the minister of justice why the law was not being implemented.[46] In his response, the minister criticized the new law as being in “direct contradiction with the spirit of Russia’s NGO legislation” and said that it did not vest the Ministry of Justice with authority to use “repressive” methods, such as additional inspections and extra reporting requirements, necessary to implement it. He also stated that the Ministry of Justice lacked jurisdiction to identify the sources of NGO funding or assess whether NGO activities are “political.”

On February 14, 2013, President Putin told a meeting of Foreign Security Service (FSB) officials, with the foreign minister, justice minister, and Constitutional Court chair present, that he expected the law to be implemented. Putin said, “We have a set of rules and regulations for NGOs in Russia, including rules and regulations about foreign funding. These laws, naturally, should be enforced. Any direct or indirect interference in our internal affairs, any form of pressure on Russia, on our allies and partners is inadmissible.”[47]

Two weeks later the authorities launched an unprecedented, broad series of inspections of NGOs (see below).

Sanctions against Organizations for Failing to Register as a “Foreign Agent”

At this writing, in the context of the government inspection campaign of NGOs described below, Russian authorities had filed administrative charges against two organizations for failing to register as a “foreign agent.” In early April the Ministry of Justice filed charges against the election monitoring group Golos, citing a letter from the Russian Federal Financial Monitoring Service (Rosfinmonitoring) stating that the organization had received €7,728 on December 13, 2012. It also cited a media interview in which the organization’s director, Lilia Shibanova, discussed the group’s work to promote electoral reform.[48]

Shibanova told Human Rights Watch that Golos stopped accepting foreign funding before Law No. 121-FZ entered into force and that Golos ordered the bank to reject the funds referred to in the letter, an honorarium for the Norwegian Helsinki Committee’s Sakharov Prize.[49] Golos and Shibanova face maximum fines of 500,000 and 300,000 rubles respectively, and should a court rule in the ministry’s favor, the organization would either be forced to register as a “foreign agent” or would be further sanctioned under Law No. 121-FZ.[50]

On April 16, 2013, the prosecutor’s office filed administrative charges against the Kostroma Center for Public Initiatives Support, an NGO in Kostroma (about 300 kilometers northeast of Moscow). The local prosecutor’s office cited the fact that the group received funding from the United States and that its charter and activities showed that it “sought to affect public opinion about state policy in the Russian Federation” as evidence of the group’s “foreign agent” status. As evidence of the latter, the prosecutor pointed to a February 2013 seminar on US-Russian relations the group had held in which a US embassy staff member participated. [51]

The Kostroma prosecutor’s office also issued a warning to the Kostroma Committee of Soldiers’ Mothers that because it receives foreign funding and had reported on election violations during the December 2011 parliamentary vote (even though this was a year before the adoption of 121-FZ), it could be held responsible for failing to register as a “foreign agent.”  The prosecutor’s office noted that the committee’s election monitoring work “was aimed at forming an image of election commissions and other agencies involved in organizing elections … [which] is considered involvement in political activity.”[52]

NGOs Refuse to Register as Foreign Agents

At the time of this writing, Human Rights Watch is not aware of a single Russian group that has registered as a “foreign agent.” Some adopted a wait-and-see approach; others refused on principle to consider doing so.[53] For example, Lev Ponomarev, head of For Human Rights, one of Russia’s largest human rights groups, said, “We will never be anyone’s agents and we will not abide by these new rules. We are agents of Russian citizens. We will continue to receive foreign funding and we will continue to say that openly.”[54]

Human rights and advocacy groups, confused by vague definitions and the lack of clear procedural steps stipulated in the law, requested that the Ministry of Justice shed some light on the implementation procedure.  In September 2012, for example, Agora filed an official request to the Ministry of Justice asking for clarifications on the legal definition of “political activity” as well as an explanation of whether Agora could be considered a “foreign agent.”. [55] The ministry responded in writing that it was not “authorized” to answer such questions and that “based on the provided information” it could not establish whether Agora qualified as a “foreign agent.”[56]

In December 2012 the human rights group Shield and Sword, in Novocheboksarsk (700 kilometers east of Moscow) requested that the Ministry of Justice add the group to the registry of “foreign agents” in order to test how the law worked. [57] The group explained in a public statement, “We do not, of course, consider ourselves ‘foreign agents’ … Russian NGOs don’t know and don’t understand how to apply or comply with this law.” [58] In January the ministry declined to register the organization as a “foreign agent” because the “aims and purposes of the group’s political activities” did not contradict Russia’s “overall state policy and were not directed at changing it.” [59]

Potential Impact on Freedom of Expression and Association

On February 6, 2013, 11 leading Russian human rights NGOs lodged a complaint with the European Court of Human Rights against Russia alleging that the “foreign agents” law violated their rights to freedom of association and expression protected under the European Convention on Human Rights. Furkat Tishaev, the Memorial lawyer who submitted the complaint on behalf of the 11 human rights NGOs, told Human Rights Watch,

The law itself is a source of violation of the applicants’ rights by labeling NGOs as foreign agents if they receive foreign funding and influence public opinion with a view to change state policy. Apart from the risk of arbitrary prosecution due to the law’s vague wording, NGOs will inevitably suffer from damages to their professional reputation if labeled as foreign agents. In fact, the overwhelming majority of the Russian native speakers consider the term of foreign agent as referring to a spy or even a traitor.[60]

As if to confirm the sentiment expressed above, on the night before the “foreign agents” law came into force, unknown individuals sprayed graffiti reading, “Foreign agent! ♥ USA” on the buildings hosting the offices of three prominent NGOs in Moscow, including Memorial.[61]

Other critics of Law No. 121-FZ also underscored its ambiguity and broad scope for interpretation that could lead to its selective use to retaliate against or silence independent election monitors and groups that work on controversial human rights issues.

Russia’s Presidential Council for Civil Society and Human Rights published an independent expert assessment stating that the law’s provisions legitimized state interference with the nongovernmental sector “beyond the limits” allowed by Russia’s domestic legislation and international obligations, and provided grounds for the state to discriminate against certain noncommercial entities based on their funding sources.[62] It warned that the vagueness of such terms as “political activities,” “influencing decision-making by state bodies in order to change state policy,” or “shaping public opinion” could lead to overly broad interpretation of the law by law enforcement agencies and courts.[63]

In a July 2012 statement, the UN High Commissioner for Human Rights Navi Pillay expressed concern about the “worrying shift in the legislative environment” caused by the series of legislative amendments, including Law No. 121-FZ. Pillay warned that the new laws will have a “detrimental effect” on human rights in Russia.[64]

Council of Europe Secretary General Thorbjørn Jagland pointed out the law’s use of language that had “very negative historic connotations” and criticized Russian legislators for not allowing enough time for reflection and public debate on the draft. Jagland mentioned the positive role that the Council of Europe played in bringing Russia’s existing legislation regulating NGOs in line with democratic standards and reminded Russia of its international obligations as a member of the Council of Europe and a party to the European Convention on Human Rights.[65]

An October 2012 resolution by the Parliamentary Assembly of the Council of Europe (PACE) stated that the new restrictive laws, including Law No. 121-FZ, were “potentially regressive in terms of democratic development” and urged the authorities “not to make use of them in this harmful way.”[66] In June 2013 the Venice Commission is expected to issue an opinion on the law.[67]

Catherine Ashton, the EU high representative for foreign affairs and security policy said the March 2013 inspection wave seemed aimed at “further undermining civil society activities.” She said the inspections and the series of recently adopted laws “constitute a trend that is deeply troubling.”[68] Ashton had previously criticized Law No. 121-FZ, noting the difficulties that Russian NGOs face in obtaining domestic funding and the negative connotations of the term “foreign agent.”[69]

[8] The State Duma voted on the law on July 13, 2012, the Federation Council approved it on July 18, 2012, it was published on July 23, 2013, and it entered into force on November 21, 2012. Federal Law “On Making Amendments to Certain Legislative Acts of the Russian Federation Regarding the Regulation of Activities of Noncommercial Organizations Performing the Functions of Foreign Agents,” No. 121-FZ, 2012,  Rossiyskaya Gazeta, http://www.rg.ru/2012/07/23/nko-dok.html (accessed April 14, 2013).

[9] “Putin asked the cabinet of ministers to increase the funding for domestic non-commercial organizations to 3 billion rubles [Путин просит кабмин увеличить госфинансирование НКО до 3 млрд рублей],” RIA Novosti, July 10, 2012, http://ria.ru/economy/20120710/696276630.html (accessed January 15, 2013); “More than 2 billion rubles is allocated in 2013 to support the activities of NGOs – Kremlin[На поддержку деятельности НКО в 2013 году выделяется более 2 млрд рублей – Кремль],” Interfax, March 30, 2013, http://www.interfax.ru/russia/news.asp?id=298526 (accessed April 3, 2013).

[10] See Human Rights Watch, Choking on Bureaucracy, and Human Rights Watch, Russia – An Uncivil Approach to Civil Society, vol. 20, n0. 1(D), June 2009, http://www.hrw.org/reports/2009/06/16/uncivil-approach-civil-society.

[11] “Putin asked the cabinet of ministers to increase the funding for domestic non-commercial organizations to 3 billion rubles [Путин просит кабмин увеличить госфинансирование НКО до 3 млрд рублей],” RIA Novosti, July 10, 2012, http://ria.ru/economy/20120710/696276630.html (accessed January 15, 2013).

[12] For example, Dmitry Vyatkin said, “Interference in Russian politics by other foreign states has reached significant proportions and that cannot be ignored,” echoing this major theme in Russian foreign and domestic policy. “The law does not prohibit but creates a responsibility to inform [Закон не запрещает, а обязывает информировать],” United Russia, November 21, 2012 http://er.ru/news/2012/11/21/zakon-ne-zapreshaet-obyazyvaet-informirovat/ (accessed January 25, 2013). See also discussion below in “Rhetoric against So-Called Foreign Influence.” The law’s supporters also asserted, mistakenly, that the law was a more lenient version of the US Foreign Agent Registration Acts (FARA). FARA covers organizations and individuals that operate under direction and control of a foreign principle. FARA does not equate receiving foreign funding, in part or in whole, with being under the direction and control of a foreign principle. Finally, FARA relates to a small set of institutions and individuals that operate at the behest of foreign entities, and its effects on those entities are minimal. See “Russia: Reject Proposed Changes to Rules on Foreign-Funded NGOs,” Human Rights Watch news release, July 13, 2012, http://www.hrw.org/news/2012/07/13/russia-reject-proposed-changes-rules-foreign-funded-ngos.

[13] Federal Law “On Making Amendments to Certain Legislative Acts of the Russian Federation Regarding the Regulation of Activities of Noncommercial Organizations Performing the Functions of Foreign Agents,” No. 121-FZ, 2012, http://base.consultant.ru/cons/cgi/online.cgi?req=doc;base=LAW;n=132900 (accessed February 2, 2013).

[14] Federal Law No. 121- FZ of 2012, art. 2, para. 1(a)-1(b).

[15] Ibid, art.2, para. 2.

[16]  Open joint stock companies with state participation and their subsidiaries are exempted. Ibid.

[17] Ibid.

[18] Certain activities are exempted, including those in the areas of science, culture, the arts, health protection, protecting persons with disabilities, protecting plant and animal life, and charity work. For the full list of excluded activities, see Federal Law No. 121-FZ of 2012, art. 2, para 2.

[19] Ibid, art. 2, para. 4.

[20] Ibid, art. 2, para. 3(a).

[21] Ibid, art. 2, para 5(k).

[22] Ibid, art. 2, para. 3(b).

[23] See, for example “You can only exit feet first [Выход только вперед ногами],” Kommersant, December 3, 2012, http://www.kommersant.ru/doc/2081599 (accessed January 4, 2013).

[24] Federal Law No. 121-FZ of 2012, art. 2, para. 5(a)-(g).

[25] Ibid, art.2, para. 5(d).

[26] Ibid, art. 2, para 5(g).

[27] Federal Law “On Rights Protection of Legal Entities and Individual Entrepreneurs during State and Municipal Control (Supervision) Actions,” No. 294-FZ, 2008, http://base.consultant.ru/cons/cgi/online.cgi?req=doc;base=LAW;n=137706;fld=134;dst=4294967295;rnd=0.5719579736143712;from=133508-0 from December 2008, as amended (accessed on March 2, 2013), art. 9, para. 2.

[28] Federal Law No. 121-FZ of 2012, art. 2, para, 5(g).

[29] Ibid, art.2, para. 5(z).

[30] “Ministry of Justice expands the list of grounds for unplanned inspections [Минюст расширяет перечень оснований для внеплановых проверок НКО],” Vedomosti, January 30, 2013, http://www.vedomosti.ru/politics/news/8535751/nekommercheskoe_opasno (accessed February 15, 2013).

[31] Federal Law No. 121-FZ of 2012, art. 2, parа. 5(n).

[32] Ibid, art. 4.

[33] Ibid, art. 2, para. 5(z), 5(i).

[34] Ibid.

[35] “Overview of the draft law No. 121- FZ  ‘On Making Amendments to Certain Legislative Acts of the Russian Federation Regarding the Regulation of Activities of Noncommercial Organizations Performing the Functions of Foreign Agents’ [Обзор Федерального закона от 20 июля 2012 года №121-ФЗ «О внесении изменений в
отдельные законодательные акты Российской Федерации в части регулирования  деятельности некоммерческих организаций, выполняющих функции иностранного  агента»],” The International Center for Not-for-Profit Law, August 10, 2012, http://lawcs.ru/images/doc/overview-of-the-russian-foreign-funding-law.pdf (accessed  March 1, 2013).

[36] Federal Law “On introducing amendments to the Administrative Code of the Russian Federation,” No. 192 – FZ, 2012, http://www.rg.ru/2012/11/14/koap-dok.html (accessed January 21, 2013).

[37] Ibid, art. 1, para. 3.

[38] Ibid.

[39] Ibid, art. 1, para. 4.

[40] Ibid, art. 1 para. 4(2).

[41] Federal Law No. 121-FZ of 2012, art. 3 para. 1(2).

[42] For the full list of penalties, see Federal Law No. 121-FZ of 2012, art. 3 para. 1(2).

[43] Ibid, art. 3, para. 1(3).

[44] Ibid, art. 3, para. 2.

[45] Ibid, art. 3, para. 2.

[46] “Head of the Ministry of Justice criticized the law on ‘foreign agents’ [Глава Минюста раскритиковал закон об ‘иностранных агентах’],” Novaya Gazeta, January 16, 2o13, http://www.novayagazeta.ru/news/62237.html (accessed January 30, 2013).

[47] “Meeting of the board of the Federal Security Service [Заседание коллегии Федеральной службы безопасности],” President of Russia, February 14, 2013, http://www.president.kremlin.ru/transcripts/17516 (accessed February 16, 2013).

[48] Human Rights Watch telephone interview with Lilia Shibanova, executive director of Golos, and Grigory Melkonyants, deputy director of Golos, April 9, 2013.

[49] Ibid.

[50] Ibid.

[51] “Prosecutor’s office calls an NGO ‘foreign agent’ for meeting with a political advisor from the US Embassy [Прокуратура признала НКО «иностранным агентом» за встречу с политическим советником посольства США],” Open Information Agency, April 16, 2013, http://openinform.ru/news/pursuit/16.04.2013/28328/ (accessed April 17, 2013).

[52] “Prosecutor’s office calls Soldiers Mothers’ Committee a foreign agent for exposing election violations [Прокуратура назвала иностранным агентом Комитет солдатских матерей за выявленные нарушения на выборах],” Open Information Agency, April 17, 2013, http://openinform.ru/news/pursuit/17.04.2013/28340/ (accessed April 17, 2013).

[53] Comment by Oleg Orlov of Memorial: “It is stupid to register as a foreign agent” [Глупо регистрироваться в качестве иностранного агента],” Gazeta.ru, July 23, 2012, http://www.gazeta.ru/politics/2012/07/23_a_4690769.shtml (accessed March 3, 2013); “Alexeeva: Moscow Helsinki Group will not register as a foreign agent [Алексеева: МХГ не будет регистрироваться как иностранный агент],” Grani.ru, July 2, 2012, http://grani.ru/Politics/Russia/m.198776.html (accessed November 17, 2012).

[54] “For Human Rights movement will ignore the law on NGOs-foreign agents – Ponomarev [Движение ‘За права человека’ будет игнорировать закон об НКО-агентах – Пономарев],” Interfax, July 21, 2012, http://www.interfax.ru/society/news.asp?id=256750 (accessed April 15, 2013).

[55] Taicia Bekbulatova, “The foreign agents law is written illegibly [Закон об иностранных агентах написан неразборчиво],” Kommersant, September 4, 2012, http://www.kommersant.ru/doc-rss/2014910 (accessed January 5, 2013).

[56] Ibid; also see Pavel Chikov’s Facebook page at http://www.facebook.com/#!/photo.php?fbid=439690952771021&set=a.171541582919294.45156.100001903601702&type=1&theater.

[57] “First NGO in Russia that decided to become a ‘foreign agent’ [В России первая НКО решила войти в реестр «иностранных агентов],” ZonaPrava.org, December 21, 2012, http://zonaprava.org/news/2149.html (accessed December 25, 2012).

[58]Ibid.

[59] “Russia’s Ministry of Justice did not find legal grounds to include ‘Shield and Sword’ into the registry of foreign agents [Минюстом России не установлено достаточных правовых оснований для внесения ЧРПОО «Щит и Меч» в реестр НКО-иностранных агентов],” Ministry of Justice of the Russian Federation, January 22, 2013, http://minjust.ru/node/4433 (accessed January 29, 2013).

[60] Human Rights Watch telephone interview with Furkat Tishaev, March 8, 2013.

[61] “Human rights defenders said the office of Memorial in Moscow was attacked by vandals [Правозащитники заявили что вандалы атаковали здание ‘Мемориала’ в Москве]” Interfax, November 21, 2012, http://www.interfax.ru/russia/news.asp?id=276974 (accessed January 14, 2013).

[62] “Expert conclusion on the draft law ‘On making amendments to certain legislative acts of the Russian Federation regarding the regulation of activities of noncommercial organizations performing the functions of foreign agents’ [Заключение на проект Федерального закона «О внесении изменений в отдельные законодательные акты Российской Федерации в части регулирования деятельности некоммерческих организаций, выполняющих функции иностранного агента»],” Presidential Council for Civil Society and Human Rights,

http://www.president-sovet.ru/structure/group_detst/materials/zaklyuchenie_na_proekt_federalnogo_zakona_o_nko.php (accessed January 10, 2013).

[63]Ibid.

[64] “Pillay concerned about series of new laws restricting human rights in Russian Federation,” United Nations Office of the High Commissioner for Human Rights, July 18, 2012, http://www.ohchr.org/EN/NewsEvents/Pages/DisplayNews.aspx?NewsID=12366&LangID=E (accessed February 13, 2013).

[65] “Secretary General alarmed by proposed NGO legislation in Russia,” Council of Europe, July 7, 2012, http://hub.coe.int/en/web/coe-portal/press/newsroom?p_p_id=newsroom&_newsroom_articleId=1050615&_newsroom_groupId=10226&_newsroom_tabs=newsroom-topnews&pager.offset=120 (accessed February 14, 2013).

[66] Parliamentary Assembly of the Council of Europe, “The honoring of obligations and commitments by the Russian Federation,” Res. 1896 (2012), October 2, 2012, http://assembly.coe.int/ASP/XRef/X2H-DW-XSL.asp?fileid=19116&lang=EN from (accessed March 5, 2013).

[67] “Venice Commission to evaluate laws on ‘foreign agents’ and treason,” Rights in Russia, February 19, 2013, http://hro.rightsinrussia.info/archive/ngos/foreign-agents/coe/venice (accessed March 8, 2013).

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