April 24, 2013

III. NGO Inspections

In the months after the “foreign agents” law was adopted, several organizations received warnings about inspections in connection with it and other grounds, but starting in early March 2013 the government launched a nationwide campaign of inspections of hundreds of NGOs, unprecedented in its scale and scope. The inspections were highly extensive, disruptive, and invasive, and seemed aimed at intimidating NGOs. As this report went to press the full outcome of the inspections was not known; at least two groups have been charged with failing to register as a “foreign agent,” and others have been fined on fire safety and other grounds.

Inspections and Warnings: Mid-October 2012 – March 5, 2013

Soldiers’ Mothers of St. Petersburg and Others

On December 5, 2012, the chief of St. Petersburg’s draft board, Sergey Kachkovsky, requested that the city prosecutor’s office determine whether the Soldiers’ Mothers of St. Petersburg disseminated “extremist” materials and failed to comply with the “law on foreign agents.”[70]

Kachkovsky described leaflets and books on conscientious objection and alternative civil service that the group’s staff members disseminated among conscripts at draft boards. He highlighted the fact that foreign donors financed the publications and alleged their dissemination aimed to “disrupt … the conscription process.”[71]

On February 1, 2013, the group’s chair, Ella Polyakova, received notice that the Ministry of Justice would inspect the organization on the request of the prosecutor’s office.

“They requested all our financial documents since 2010, even tried to request grant applications, but we refused to give these,” Polyakova told Human Rights Watch.[72] The inspection, which lasted until March 1, found two minor violations, both of which had nothing to do with either extremism or the law on “foreign agents”: the group’s emblem had not been officially registered, as required, and although registered in St. Petersburg as a regional NGO, it does work in other regions. The ministry said the Soldiers’ Mothers must amend its charter accordingly by June 2013 and that the inspection materials would be sent to the prosecutor’s office.[73]

On March 12 an officer of the Center for Combating Extremism also visited the organization at the prosecutor’s request, pursuant to Kachkovsky’s complaint. The officer told Polyakova that the group’s publications would be submitted for expert analysis for potential extremism.

“In all the 20 years of our organization’s work, when our Western colleagues asked me if we are persecuted by the authorities for our human rights activities, I confidently said ‘no,’” Polyakova wrote Human Rights Watch. But now, in the twenty-first year, it happened – surprisingly right after we got a grant from the regional administration and I personally became member of the Presidential Council for Civil Society and Human Rights…. And we can only guess who will come to check us next.”[74]

At this writing Poyakova had not received the results of the “extremism” inspection.[75]

On November 28, 2012 a regional department of the Ministry of Justice sent a warning to the Saratov branch of No to Alcoholism and Drug Addiction, a group that helps drug users and raises young people’s awareness about drug addiction.[76] The warning[77] alleged the organization failed to submit a report on foreign funding it received in 2011 and invoked article 2.6 of the NGO law, an amendment introduced by Law No. 121-FZ that had not yet entered into force.[78] The ministry denied the warning was in any way connected with the new “foreign agent” law and stated that the responsibility to report on sources of foreign funding “existed in the national law since 2006,”[79] and that the invocation of article 2.6 of the NGO law was “a technical mistake.”[80]

In February the ministry sent a letter to the organization’s Saratov branch stating that the warning was not entirely lawful.[81]  Following the incident, the Ministry of Justice reportedly requested that its regional offices coordinate implementation of the new law at the federal level.[82]

On February 21, 2013, a number of Duma deputies requested that the Investigative Committee and the prosecutor’s office conduct an inspection of Russia’s leading election monitoring watchdog group, Golos, to establish whether the group violates the law by receiving foreign funding without being registered as a “foreign agent.”[83]  At a roundtable discussion held at the Public Chamber of the Russian Federation, a Ministry of Justice official stated that the ministry received over 100 requests from individuals to deem Golos and a nongovernmental think-tank Levada Centre “foreign agents.” The official said the ministry rejected such requests because “inspections would take place only when there are indications not only that the organization gets foreign funding but also that it is extremist.”[84]

March 2013: Inspection Campaign Gets Underway

In early March 2013 the office of the prosecutor general requested that lower-level prosecutors’ offices conduct inspections of dozens of NGOs and religious organizations in cooperation with officials from the Federal Tax Service, the Ministry of Justice, and other agencies. As of April 18, 2013, 246 organizations in 54 Russian regions reported to Agora that they had been inspected.[85] A Ministry of Justice official told the Russian Presidential Council for Civil Society and Human Rights that ministry officials participated in 528 prosecutor’s office inspections of NGOs in 49 regions, suggesting the true scale of the inspections. Many of the Russian organizations targeted accept some amount of foreign funding, and include groups working on human rights, environmental protection, government transparency, election monitoring, civic education, religious issues, and the like. Representative offices of foreign organizations, including Human Rights Watch, were also inspected.

On March 28, 2013, after the campaign of inspections had been under way for several weeks, the prosecutor general’s office published a statement giving two explanations for the campaign. It said that the inspections had been planned in 2012 to examine how NGOs were “implementing the law” in order to “identify positive and negative patterns, difficult issues and ways to resolve them.” It also said that the campaign was prompted by “information received” about “banned ultra-nationalist and radical religious organizations.”[86]  On April 4 the prosecutor general’s office acknowledged that the inspections were carried out in line with the law on “foreign agents” because “the funding is transferred, but in fact no one is registered [as a ‘foreign agent’].”[87] Answering a journalist’s question about whether the inspections will result in the identification of “foreign agent” NGOs, the deputy prosecutor general said, “Most probably, yes.”[88]

In most cases of which Human Rights Watch is aware the inspections were carried out by a team of prosecutorial, Ministry of Justice, and tax officials. Some teams also included agents from the Federal Security Service (FSB), the Federal Migration Service, the fire department, the health department, and other agencies.

The scope of the inspections was far-ranging. In almost all cases of which Human Rights Watch is aware, the prosecutor’s office representative presented organizations with a notice stating that the inspection would cover the organizations’ compliance “with current legislation.”[89] A document leaked to the media that provides instructions to local prosecutors’ offices for conducting inspections specifically urges them to analyze sources of foreign funding for the groups and their involvement in political activities, as well as any evidence of “extremism.”[90]

Intimidation

Inspections of some organizations that work on sensitive issues – for example on the North Caucasus, the Sochi Olympic Games, or police abuse – clearly aimed to intimidate, and in several cases the procedure more closely resembled a police raid than an inspection.

The inspection at Civic Assistance, a group in Moscow that assists migrants, included a representative from the Federal Migration Service who said upon arrival, “I’m going to check the documents of all non-Russians.” Then, according to the chair of Civic Assistance, the official started to selectively check the identity documents of some staff members based on what appeared to be no more than their physical appearance.[91] Five officials simply walked into the office of one NGO without knocking, having somehow passed through corridor doors requiring a magnetic key card.[92] The inspectors conducted a “visual examination” of the entire office, asked questions about, among other things, photographs on the walls.[93]

In at least three cases, camera crews from NTV, a television station known for its numerous shows seeking to discredit human rights activists and portray Russia’s political opposition as foreign-sponsored, arrived with the inspectors to film the inspections. The NTV news broadcast of the Memorial inspection alleged that Memorial may be in violation of the “foreign agents” law.[94]

It is not clear how NTV learned about the inspections since most government inspections in the current wave were unannounced; the prosecutor’s office explained this by saying that NTV is simply one of the media outlets officially accredited with the agency.[95]

Invasiveness

Several organizations stated on social media platforms that officials thoroughly examined the premises and attempted to probe more intrusively into the groups’ offices, searching libraries for “extremist” literature and requesting to look into computers.[96]

At least one NGO, Environmental Watch of the North Caucasus (EWNC), was forced to provide access to emails even though the inspectors had no warrant. The inspection team, which came to the group’s office in Maykop (1,400 kilometers south of Moscow) on March 27, did not present an inspection notice.[97] It was particularly interested in the organization’s activities related to preparations for the 2014 Olympic Games in Sochi.[98] They urged the group not to publish its report on environmental consequences of the Olympic preparations in order “not to harm the country.” When the group refused, inspectors said they would examine the computers for unlicensed software and look into the group’s email account, threatening to fine the organization if anyone tried to hinder them.

“As we had nothing secret in our emails, we decided to give them access to our account,” Andrey Rudomakha, EWNC’s coordinator, told Human Rights Watch.[99] Officials from the prosecutor’s office and the Center for Combating Extremism went through EWNC’s email account for 1.5 hours and left the office. EWNC plans to file a complaint regarding the inspector’s actions including for violation of the right to privacy.[100]

Inspections at the St. Petersburg offices of the Konrad Adenauer and Friedrich Ebert foundations, the foundations of two German political parties, provoked a diplomatic row as the inspectors confiscated computers belonging to the former to allegedly examine them for unlicensed software. The equipment was returned after a demarche made by the German Ministry of Foreign Affairs.[101]

While inspectors asked some organizations to produce only a standard set of registration, founding, tax, and financial documents, other inspections were more intrusive and demanding.  For example, in St. Petersburg, inspectors asked the Memorial Anti-Discrimination Centre to prove its staff had been vaccinated for smallpox and that the organization has plans for “extinguishing rats and utilizing solid waste.”[102] The environmental group Bellona was cited for, among other things, lacking a diary of emergency drills and failing to measure the air quality in the office work stations.[103]

Women of the Don is an NGO in Novocherkassk that carries out educational and peace building programs in the North Caucasus. Officials from the prosecutor’s office, FSB, police (including the economic crimes department), tax, health, and fire inspectorates inspected the group’s office on March 12. The group’s chair, Valentina Cherevatenko, said in an interview with the news portal Caucasian Knot,

Firemen checked documents, fire extinguishers, the fire alarm, and wooden parts the building. Health inspectors examined the ventilation, presence of cold and hot water, and asked for lung X-rays of our staff members (as we have public office hours). The police checked our computers for unlicensed software, asked about our work with children and licenses for educational activity. The tax inspectorate checked financial documents and asked lots of questions about sources of funding and expenses. The prosecutor studied the content of our projects. The FSB officer didn’t ask any questions – I had an impression that he oversaw the inspection by the others, and he also a great interest in our library.[104]

Most inspections covered a three-year period, which meant enormous volumes of paper had to be copied, stapled, and certified by organizations’ representatives. For instance, Memorial (Moscow) submitted in total 8,766 pages of documents (for all its five separate legal entities) for inspection, and the Foundation for Freedom of Information in St. Petersburg – 4,506 pages, or 23 kilograms of paper. NGOs had to use their own paper and ink cartridges for this purpose.

The inspections were in many cases disruptive and demanding. In some cases the inspections lasted only several hours, but in others they were drawn out over a period of days. Officials from the prosecutor’s office, for example, spent a total of seven working days at Memorial, inspecting the organizations’ five legal entities. NGOs also spent significant time in the weeks following the initial inspection responding to follow-up requests. The chair of Women of the Don, for example, was summoned five times to the prosecutor’s office to “give explanations” in connection with the inspection.[105] On April 4 Civic Assistance was told to provide a significant number of additional documents, including texts of speeches made at Civic Assistance events, by the next day.[106]  In at least two regions, prosecutors requested that NGOs submit, in addition to the standard package of documents, analyses of their public activities.”[107]

Some inspection teams were polite and respectful, but in other cases they were not.  Yuri Vdovin, deputy director of Citizens’ Watch in St. Petersburg said, “The first thing they said was ‘Give us everything and do it right now.’ We told them that a week before our executive director died … and [we had not] replaced him. Secondly, our accountant’s mother died today, so she would not be present…” The officials refused the group’s request to postpone the inspection by four days.[108]

Outcome of Inspections

It is not clear what the overall impact of the inspections will be. One possibility is that organizations could receive official warnings for being in violation of any relevant Russian law. This is a serious matter: as noted above, two official warnings accumulated over an indefinite period can serve as grounds for a court to close an organization. Another potential outcome could be that charges will be brought, for example, on “extremism” allegations, or for failing to comply with the “foreign agents” law.

So far, at the time of the writing, most organizations had not learned the outcome of their inspections. Some had learned the partial outcome. For example, according to Agora, the prosecutor’s office informed the Institute for Media Development – Siberia, based in Novosibirsk, that the group’s letterhead logo had not been properly registered. The city prosecutor’s office ordered a district prosecutor’s office to identify how and why this violation had happened and to determine how the organization should be disciplined.[109]

Several organizations have been cited for fire safety and health violations, and at least two have been fined for similar violations.[110]

NGO Challenges to the Inspections

The prosecutor’s office has the authority to conduct unannounced inspections only when it has received allegations that the organization to be inspected has violated the law.[111] It is not clear whether prosecutors received credible allegations relating to hundreds of NGOs all over Russia, whether such allegations were received just prior to the inspection wave, or whether they had collected such allegations for many months.

A 2011 instruction issued by the prosecutor general’s office requires that officials carry out their oversight work of government bodies and other organizations without groundless interference, without duplicating other state bodies’ functions, and without excessive demands for documents and information, particularly when such information is available publicly or through other government offices.[112]

At least eight human rights NGOs refused to cooperate with the inspections, claiming they were unlawful.[113] Lev Ponomarev, head of three of these groups, is now facing three administrative prosecutions for failing to meet the prosecutor’s demands; each prosecution bears a potential fine of 3,000 rubles.[114]  One of the three NGOs’ main arguments was the fact that they had already undergone planned inspections by the Ministry of Justice just one month before, as had several other organizations inspected during the campaign.[115]

Several organizations have sued the prosecutor’s office in relation to the unannounced inspections. For example, Memorial filed a complaint on April 8, 2013 with the Zamoskvoretsky District Court claiming that the inspection was excessively broad in scope and that the prosecutor’s office refused to state the factual grounds that had triggered the inspection.[116]

Golos

The organizations that make up the election-monitoring network Golos, which documented election violations in the November 2011 parliamentary vote, are among those hardest hit by the inspection wave.[117] On February 21, 2013, the Federal Tax Service paid a sudden visit to Golos’s partner organizations in Samara, Chelyabinsk, and Novosibirsk. In Samara, tax officials handed the partner organization’s head a four-page list of required documents.

The Federal Tax Service began inspecting the head office of Golos, in Moscow, a year ago, on April 4, 2012, and as this report went to print the organization was awaiting the inspection outcome report.[118] Nearly all the group’s contractors have also been inspected during this period. The results of the inspections were still not known at this writing.

As of April 10, 2013 all of the seven inter-regional foundations of the Golos network were subjected to tax inspections.[119] As part of these inspections, many individuals who cooperated with Golos as election observers were summoned for questioning as witnesses “to a tax crime.”[120] The election observers were in many cases interrogated not by tax officials, but by officers of the Center for Combating Extremism, who asked questions about their personal involvement in election observation, the content of Golos trainings, and the like.[121]

On March 28, representatives of the prosecutor’s office and the Ministry of Justice inspected the regional branch of Golos in Samara, bringing with them a correspondent and a cameraman of the regional television channel Gubernia.[122]

On April 3 the deputy director of Golos, Grigory Melkonyants, was summoned by a neighborhood police officer in Moscow to pick up an inspection notice issued by the prosecutor’s office. He arrived at the station to discover an NTV film crew waiting for him, which then followed Melkonyants to the metro station asking him why Golos has not registered as a “foreign agent.”[123] Apart from Golos and the inter-regional foundation with the same name, the prosecutors separately requested documents from the editorial office of the Civic Golos newspaper, whose correspondents covered elections. On April 8 the three groups submitted all the requested documents.[124]

Two days later, on April 10, the Ministry of Justice filed documents with a court alleging Golos had violated the law by failing to register as a “foreign agent.” On the same day, the prosecutor’s office contacted the group again requesting that it submit copies of additional documents, including financial documents – all in originals – by April 11.[125]

Meanwhile, on April 11, Golos’s office landlord notified the group, without explanation, that it would have to leave the office before the end of the month.[126]

[70] Human Rights Watch interview with Ella Polyakova, director, Soldiers’ Mothers of St. Petersburg, St. Petersburg, January 30, 2013.

[71] Letter of December 5, 2013, on file with Human Rights Watch.

[72] Human Rights Watch telephone interview with Ella Polyakova, February 26, 2013.

[73] St. Petersburg Main Directorate of the Ministry of Justice of the Russian Federation, “Report on the inspection of the St. Petersburg regional public human rights organization, ‘Soldiers’ Mothers of St., Petersburg,’” no. 13, March 1, 2013, on file with Human Rights Watch.

[74] Human Rights Watch email correspondence with Ella Polyakova, March 23, 2013.

[75] Ibid.

[76] Official website of No to Alcoholism and Drug Addiction, http://www.nan.ru/?f=fond/ (accessed January 29, 2013). The fund has been operating in Russia since 1987 and it has over 60 branch offices nationwide.

[77] Warning issued by the Saratov Ministry of Justice to the Saratov branch of No to Alcoholism and Drug Addiction, November 28, 2012, http://openinform.ru/fs/j_photos/openinform_387.pdf (accessed April 19, 2013).

[78]  “Ministry of Justice disarms a foreign agent [Минюст обезвреживает иностранного агента],” Kommersant, December 13, 2012, http://www.kommersant.ru/doc/2088739 (accessed January 29, 2013).

[79] “Explanation of the Russian Ministry of Justice on issuance of a warning to the charitable foundation ‘No to Alcoholism and Drug Addiction’ [Разъяснения Минюста России по факту вынесения предупреждения отделению благотворительного фонда ‘Нет алкоголизму и наркотикам’],” Ministry of Justice of the Russian Federation, http://minjust.ru/node/2701?theme=minjust?theme=minjust (accessed March 3, 2013).

[80] Roundtable on implementation of the Federal Law “On Non-commercial Organisations” relating to registration as “foreign agents,” organized by the Independent Council for Legal Expertise, Moscow, February 26, 2013.

[81] “The Ministry of Justice acknowledged unlawful warning to the Saratov office of ‘No to Alcoholism and Drugs’ on the ‘foreign agents’ law [Минюст признал неправомерным предупреждение саратовскому отделению НАН по закону ‘об иностранных агентах’],” Social Information Agency, February 5, 2013, http://www.asi.org.ru/asi3/rws_asi.nsf/va_WebPages/9E7F0F144777293244257B090038FE3CRus (accessed March 2, 2013).

[82] “Will the regions be required to coordinate the implementation of the ‘agents’ law with Moscow?  [Регионы обязали согласовывать применение закона об ‘агентах’ с Москвой?]”Human Rights in Russia, February 5, 2013, http://www.hro.org/node/15707, (accessed March 2, 2013).

[83] “The Ministry of Justice declined to inspect foreign funding of ‘Golos’ [Минюст отказался проверять иностранное финансирование «Голоса»],” Golos, March 1, 2013, http://www.golos.org/news/6935 (accessed March 3, 2013); Maksim Korolev, “‘Golos’ is suspected of violation the law on NGOs [«Голос» подозревают в нарушении закона об НКО],” Izvestia, February 22, 2103, http://izvestia.ru/news/545401 (accessed March 3, 2013).

[84] “Reputational Risks [Репутационные риски],” The Civic Chamber of the Russian Federation, February 26, 2013, http://www.oprf.ru/press/news/2013/newsitem/20653 (accessed March 3, 2013).

[85] The list of prosecutors’ inspections compiled by Agora can be found at http://openinform.ru/fs/j_photos/openinform_405.pdf.

[86] “Regarding inspections of public and religious associations and other noncommercial organizations’ implementation of the law [О проверке исполнения законодательства общественными, религиозными объединениями и иными некоммерческими организациями],” Prosecutor General of the Russian Federation, March 28, 2013, http://genproc.gov.ru/smi/news/genproc/news-81834/ (accessed March 31, 2013). Notably, a Ministry of Justice official on February 25 said at a roundtable discussion that the ministry would examine compliance with the “foreign agents” law through planned, not “unannounced” inspections. See “The Ministry of Justice has not performed unplanned inspections of NGOs for the law on foreign agents [Минюст не проверял внепланово НКО по закону об иностранных агентах],” RIA Novosti, February 25, 2013, http://ria.ru/society/20130225/924566033.html (accessed April 3, 2013).

[87] “Prosecutor General: NGOs receive funding from abroad, but no one has registered [Генпрокуратура: НКО получают финансирование из-за рубежа,но соответствующую регистрацию никто не прошел], Gazeta, April 4, 2013, http://www.gazeta.ru/politics/news/2013/04/04/n_2834401.shtml (accessed April 19, 2013).

[88] “Russian NGOs receive funding from abroad without registration [Российские НКО получают финансирование из-за рубежа без регистрации],” RIA Novosti, April 4, 2013, http://ria.ru/incidents/20130404/930940022.html (accessed April 11, 2013).

[89] For example, when Human Rights Watch’s representative office in Moscow was inspected on March 27, 2013, the prosecutor’s office representative presented such a notice. Notice of the Moscow city prosecutor’s office, no. 27-2-4-2013, March 25, 2013, signed by Deputy City Prosecutor A.Y. Zakharov, on file with Human Rights Watch.

[90] Document published on Gazeta, http://static.gazeta.ru/nm2012/docs/zadanie_prokuroru.pdf (accessed April 18, 2013).

[91] Human Rights Watch email correspondence with Svetlana G., chair, Civic Assistance, April 4, 2013. By non-Russians, the official apparently meant non-ethnic Russians, as opposed to non-Russian citizens.

[92] Human Rights Watch telephone interview with A.A., NGO representative, name and date of interview withheld at interviewee’s request.

[93] Ibid.

[94] These included Memorial (see “Russia: New Pressure on Civil Society,” Human Rights Watch news release, March 21, 2013, http://www.hrw.org/news/2013/03/24/russia-new-pressure-civil-society), Amnesty International, For Human Rights, and Golos. In addition, the Samara regional television station, Gubernia, arrived with officials for the inspection of Golos-Samara.

[95] Aleksandr Litoi, “‘Foreign agents’ provoked a confrontation with prosecutors [«Иностранные агенты» вызвали прокуроров на разборки],”RBC daily, March 26, 2013,

http://www.rbcdaily.ru/society/562949986360386 (accessed March 26, 2013).

[96] Human Rights Watch telephone interview with A.A., NGO representative, name and date of interview withheld at interviewee’s request.

[97] Human Rights Watch telephone interview with Andrey Rudomakha, coordinator, EWNC, April 3, 2013.

[98] “Wave of inspections-harassment reaches Environmental Watch of the North Caucasus [Волна проверок-преследований со стороны властей докатилась до экологической вахты по северномы кавказу],” Environmental Watch of the North Caucasus, March 28, 2013, http://ewnc.org/node/11141 (accessed March 28, 2013). The inspection team included officials from the prosecutor’s office, the Center for Combating Extremism, and the FSB.

[99] Human Rights Watch telephone interview with Andrey Rudomakha, April 3, 2013.

[100] Ibid.

[101] “Press statement of the Konrad Adenauer Foundation on events in Russia [Актуальное заявление пресс-службы Фонда Конрада Аденауэра по поводу событий в России],” Konrad Adenauer Foundation, March 28, 2013, http://www.kas.de/ru-moskau/ru/publications/33949/ (accessed March 28, 2013).

[102] “Inspection of St. Petersburg Memorial Society [Проверки в Петербургском обществе ‘Мемориал’],” Cognita!ru, March 26, 2013, http://www.cogita.ru/ (accessed March 26, 2013).

[103] “St. Petersburg NGOs prepare to be fined hundreds of thousands of rubles [Петербургские НКО готовятся оштрафовать на сотни тысяч рублей],” Neva 24, April 2, 2013, http://www.neva24.ru/a/2013/04/01/Peterburgskie_NKO_gotovjat/ (accessed April 2, 2013).

[104] Natalia Krainova, “Security officials started inspections of NGOs in the Rostov oblast [В Ростовской области силовики начали проверки НКО],” Kavkazsky Uzel, March 16, 2013, http://www.kavkaz-uzel.ru/articles/221512/ (accessed March 16, 2013).

[105] The chair of Women of the Don shared this information at the April 15, 2013 meeting of the Presidential Council for Civil Society and Human Rights. A Human Rights Watch consultant attended the meeting.

[106] Human Rights Watch email correspondence with Svetlana Gannushkina, chair, Civic Assistance, April 6, 2013.

[107] See “Baikal area human rights activists describe their political activity in detail to prosecutors [Забайкальские правозащитники подробно описали прокурорам свою политическую деятельность],” Open Information Agency,http://openinform.ru/news/pursuit/29.03.2013/28246/ (accessed April 18, 2013); Letter from O.V. Parshikov, head, regional prosecutor's office Division for Oversight of the Observance of Laws on Federal security, Interethnic relations and Countering Extremism to the Youth Human Rights Movement No. 27-14-2013, April 2, 2013.

[108] Aleksandr Karev, “St. Petersburg. Attack on NGOs [Петербург. Наступление на НКО],” Novaya Svoboda, March 21, 2013, http://www.svobodanew.com/%D0%BF%D0%B5%D1%82%D0%B5%D1%80%D0%B1%D1%83%D1%80%D0%B3-%D0%BD%D0%B0%D1%81%D1%82%D1%83%D0%BF%D0%BB%D0%B5%D0%BD%D0%B8%D0%B5-%D0%BD%D0%B0-%D0%BD%D0%BA%D0%BE/ (accessed March 21, 2013).

[109] “After prosecutors’ inspections, NGOs start to get fined [После прокурорских проверок НКО начали штрафовать],” Open Information Agency, April 1, 2013, http://openinform.ru/news/pursuit/01.04.2013/28256 (accessed April 3, 2013).

[110] Ibid. The Church of the Virgin Mary, a Catholic church in Novocherkassk (1,000 kilometers south of Moscow), and Women of the Don (also in Novocherkassk) have been issued a fines. Others cited for fire safety and health violations include Citizen’s Watch and Bellona in St. Petersburg, and Jerry Rubin’s Club in Moscow.

[111] Federal Law “On the prosecutor’s office in the Russian Federation,” No. 2202-1, 1992, http://base.consultant.ru/cons/cgi/online.cgi?req=doc;base=LAW;n=133796, art. 21.

[112] Order of the Prosecutor General “On exclusion of the practice of the prosecutorial supervision of evidence unwarranted in interference of state and local authorizes and other bodies and organizations” [Указание Генпрокуратуры “Об исключении из практики прокурорского надзора фактов необоснованного вмешательства в деятельность органов государственной власти, органов местного самоуправления, иных органов и организаций”], No. 236/7, 2011, http://base.consultant.ru/cons/cgi/online.cgi?req=doc;base=EXP;n=521692.

[113] These include Shield and Sword, Agora, For Human Rights, Foundation for the Defense of Prisoners, Human Rights Hotline, International Standard Foundation (Ufa), ECOSOCIS Foundation (Voronezh), and the International Youth Human Rights Movement.

[114] “Lev Ponomarev ignores legal requirements, Moscow prosecutors filed 3 cases on administrative offenses [В отношении Льва Пономарева, проигнорировавшего законные требования прокуратуры г. Москвы, возбуждены 3 дела об административном правонарушении],” Prosecutor General of the Russian Federation, March 28, 2013, http://genproc.gov.ru/smi/news/genproc/news-81849/ (accessed March 28, 2013).

[115] Human Rights Watch interview with Elena Panfilova, head, Transparency International, Russia.

[116] Memorial, “Statement challenging the action and decision of the Moscow City Prosecutor’s office (in accordance with chapter 25 of the Civil Procedure Code of the Russian Federation) [Заявление об оспаривании действий и решений Прокуратуры г. Москвы (в порядке гл. 25 ГПК РФ)],” http://www.memo.ru/uploads/files/968.pdf (accessed April 9, 2013).

[117] The Golos network includes Golos in Defense of Voters’ Rights and Inter-Regional Public Foundations in Support of Civil Society Development: Golos-Center, Golos-Volga region, Golos-Urals, Golos-Siberia, Golos-North-West, and Golos-South. Golos was also the target of an intense government harassment campaign in the 2011-2012 election cycle. See “Stop Harassing Election Monitors, Release Demonstrators,” Human Rights Watch news release, December 6, 2012 http://www.hrw.org/news/2011/12/05/russia-stop-harassing-election-monitors-release-demonstrators.

[118] “Chronicles of the inspection of ‘Golos’ [Хроника проверок «ГОЛОСа»], April 10, 2013, http://golos.org/news/7008 (accessed Aril 12, 2013).

[119] Ibid.

[120] Human Rights Watch telephone interview with Grigory Melkonyants, April 17, 2013.

[121] Ibid; “Coordinator of ‘Golos’ in Samara Ludmila Kuzmina appealed to the ombudsman [Координатор «Голоса» в Самаре Людмила Кузьмина обратилась к омбудсманам],” Parkgagarina.ru, April 1, 2012, http://parkgagarina.info/novosti/6428-koordinator-golosa-v-samare-lyudmila-kuzmina-obratilas-k-ombudsmanam.html (accessed April 15, 2013); Comment posted by Nikolai Sorokin on April 11, 2013, to Facebook, https://www.facebook.com/nvsorokin/posts/399651123466219 (accessed April 15, 2013); Ludmila Kuzmina, “Whose ears stick out from the tax examination? [Чьи уши торчат из налогового допроса?],” post to LiveJournal, March 26, 2013, http://ludmila-kuzmina.LiveJournal.com/392338.html (accessed April 15, 2013).

[122] Comment posted by Ludmila Kuzmina on March 28, 2013, to Facebook, https://www.facebook.com/golos.samara/posts/549965168377342 (accessed April 15, 2013).

[123] Comment posted by Grigory Melkonyants on April 3, 2013, to Facebook, https://www.facebook.com/grigory.melkonyants/posts/506286149408694 (accessed April 15, 2013); “Melkonyants: NTV staff walked behind me to the subway and asked me call them ‘Surkov’s propaganda’ [Мельконьянц: сотрудники НТВ шли за мной до метро и просили назвать их сурковской пропагандой],” TVrain.ru, April 3, 2013, http://tvrain.ru/articles/melkonjants_sotrudniki_ntv_shli_za_mnoj_do_metro_i_prosili_nazvat_ih_surkovskoj_propagandoj-340278/ (accessed April 15, 2013).

[124] “Chronicles of the inspection of ‘Golos’ [Хроника проверок «ГОЛОСа»],” Golos, April 10, 2013, http://golos.org/news/7008 (accessed April 12, 2013).

[125] Ibid.

[126] Human Rights Watch telephone interview with Grigory Melkonyants, April 17, 2013.