The International Strategic Action Network for Security (iSANS) has released its newest research report, “Transnational Repression in Belarus: A Brutal Tool of the Persecution of Dissent by the Lukashenka Regime”. The report aims to examine the scope of transnational repression (TNR) perpetrated by the Lukashenka regime and to classify the diverse mechanisms employed to silence its opponents forced to flee Belarus due to political persecution. Analytical rather than monitoring in nature, the report does not seek to compile exhaustive data on TNR-related human rights violations but instead presents illustrative examples of such violations to highlight the primary methods of TNR and the evolution of its practices.
The research underpinning this report draws on a wide range of sources, including scholarly articles, documents and reports produced by intergovernmental organisations or commissioned by them, reports from Belarusian and international non-governmental organisations, media and social media materials, and information obtained from private sources. The study reviewed hundreds of reports of human rights violations, with the vast majority of the data pertaining to the period after 2020. Information was also collected on the use of TNR tools by the Putin regime to highlight symmetries and synergies in the practices of both regimes.
iSANS has been monitoring TNR-related human rights violations for several years. The data collected during this period has informed a number of policy and analytical documents produced by iSANS, as well as its submissions to international human rights bodies. The production of the present report was necessitated by the recent escalation in the Lukashenka regime’s use of TNR practices, the increasing variety of instruments employed, and the inconsistent response from the international community to TNR-related human rights violations affecting Belarusians in exile which underscores the absence of a comprehensive understanding of the regime’s TNR activities.
The Lukashenka regime’s TNR instruments constitute a sophisticated and evolving arsenal, with its scope dramatically expanding following the 2020 protests, affecting thousands who fled the crackdown. All TNR tools are aimed at silencing and punishing exiled opponents and intimidating dissenters remaining inside the country. The Lukashenka regime employs various methods to involve other countries in its TNR practices, primarily through the abuse of the Interpol system and the submission of extradition requests based on fabricated criminal charges, often under terrorism and extremism legislation. The regime’s closest partnership is with Russia, but its cooperation with other states in the field of TNR is continually expanding. Symmetries between Belarus and Russia’s TNR practices underscore their strategic alliance, with shared legislation enabling TNR.
TNR by the Belarusian authorities targets civilian population, has a systematic nature and large scope, and is implemented on the basis of a state policy. Therefore, these actions may constitute a crime against humanity of persecution. Since they target Belarusians who fled to other countries which are parties to the Rome Statute, this crime falls under the jurisdiction of the International Criminal Court. As States Parties to the Rome Statute, concerned states could follow Lithuania’s suite and submit their own referrals to the ICC Prosecutor, emphasising that TNR by the Lukashenka regime may constitute a crime against humanity.
TNR by the Lukashenka regime not only threatens the rights and freedoms of Belarusians residing in various countries but also constitutes interference in the sovereignty of other states through a broad array of tactics designed to influence, manipulate, or undermine their domestic affairs, politics, or processes. Like other hybrid threats, TNR by Belarus raises significant security concerns for host states and the entire European region.
Approaches to countering TNR diverge between a human rights-based framework, emphasising human rights violations caused by TNR and host state’s obligations to address them, and a national security-focused lens viewing TNR as foreign interference. Balancing these two approaches is crucial to remedy violations while defending state interests. Challenges in addressing TNR include bureaucratic limitations in host states, where officials lack understanding of threats and obligations, often dismissing victims’ reports. Another barrier to addressing TNR-related human rights violations is the adoption of the “countering foreign interference” framework, which often treats human rights violation incidents as isolated events. This approach may prioritise measures against foreign influence, disproportionally impacting a broad segment of citizens from TNR-implementing states, many of whom are victims of TNR. This approach is clearly reflected in the current international response to the Lukashenka regime’s TNR practices. Although the international community has repeatedly highlighted human rights violations of Belarusians in exile in reports and statements, it has yet to fully recognise the scale of the regime’s efforts to suppress dissent beyond Belarus’s jurisdiction and develop adequate policy measures to address it.
The report concludes with detailed recommendations to intergovernmental bodies and states that are based on the need for urgent action and are grounded in a consolidated approach to TNR, which combines the goals of protecting the human rights of victims of repression and safeguarding state sovereignty. Comprehensive and thoughtful changes in addressing TNR are long overdue in legislation, policies, institution building, training, protection measures, investigation, cooperation with diaspora and more, both at the international and national level.
Below you can read the executive summary of the report as well as its conclusions and recommendations.
Full text of the report can be downloaded here.
Executive summary
Transnational repression (TNR) has recently become a tool of choice for authoritarian regimes to suppress voices and activities of their critics outside their territorial jurisdiction. There is no single definition of TNR at the level of international treaties. The lack of a common definition has impeded the development of evidence-based and comprehensive policy responses to TNR, thereby allowing the phenomenon to expand.
Targets of TNR have broadened from traditional dissidents – such as human rights defenders, journalists, and political opponents – to include academics, legal professionals, diaspora communities, and supporters of victims. TNR is manifested through a variety of tactics, ranging from violence, harassment, and surveillance of individuals and organisations to the adoption of restrictive extraterritorial laws with arbitrary application, designed to capture whole communities. All TNR tools are aimed at silencing and punishing exiled opponents and intimidating dissenters remaining inside the country. Coercion-by-proxy, which constitutes the actual or threatened use of physical or other sanctions against people within the territorial jurisdiction of a state for the purpose to repress target persons residing outside, enables regimes to achieve this aim at low cost without regime agents even needing to leave their territory.
While globalisation, internet development and migration enable exiles’ activism, they also serve as drivers of TNR’s growth. Regimes actively abuse international cooperation in justice and security. International cooperation is central to TNR, with perpetrators enlisting host states for detentions and renditions, leveraging economic ties, weak rule of law, and regional affiliations. Authoritarian clusters, such as those involving Belarus, Russia, and Central Asia, reinforce practices through shared security interests and ideologies, forming networks that amplify TNR’s reach and effectiveness.
Approaches to countering TNR diverge between a human rights-based framework, emphasising human rights violations caused by TNR and host state’s obligations to address them, and a national security-focused lens viewing TNR as foreign interference. Balancing these two approaches is crucial to remedy violations while defending state interests. A potential to integrate these two approaches into a consolidated policy has been demonstrated at both national and international levels.
Challenges in addressing TNR include bureaucratic limitations in host states, where officials lack understanding of threats and obligations, often dismissing victims’ reports. Another barrier to addressing TNR-related human rights violations is the adoption of the “countering foreign interference” framework, which often treats human rights violation incidents as isolated events. This approach may prioritise measures against foreign influence, disproportionally impacting a broad segment of citizens from TNR-implementing states, many of whom are victims of TNR.
Digital TNR has transformed the landscape, employing spyware, hacking, disinformation, location tracking, and DDoS attacks, amplified by the use of artificial intelligence for surveillance, content moderation, and generative propaganda. These intertwine with traditional methods, facilitating coercion and chilling speech. The mere threat of digital TNR drives activists toward self-censorship.
The increase in the number of known TNR cases and the development of research in this area have led to a surge of attention to the threat of TNR in the international community. In this sense, 2024 undoubtedly became a key year for recognising TNR as a global threat of a complex nature and consequences it entails for human rights.
Specifically addressing the Lukashenka regime’s TNR practices, international bodies have repeatedly highlighted human rights violations of Belarusians in exile in reports and statements. Regional responses, such as Council of Europe and OSCE documents, recognise Belarus’s extraterritorial practices as threats to the rule of law and human rights. However, the international community has yet to fully recognise the scale of the regime’s efforts to suppress dissent beyond Belarus’s jurisdiction. This repression not only threatens the rights and freedoms of Belarusians residing in various countries but also constitutes interference in the sovereignty of other states through a broad array of tactics designed to influence, manipulate, or undermine their domestic affairs, politics, or processes. Like other hybrid threats, TNR perpetrated by Belarus raises significant security concerns for host states and the entire European region.
The lack of an unequivocal reaction to the TNR practices by the Lukashenka regime at the UN level may be due to the fact that UN bodies focus primarily on information available in the public domain and at the disposal of human rights NGOs. They may not consider the context of TNR when recording violations of the rights of Belarusians in exile or may not be fully aware of TNR. The context of TNR by Belarus is not adequately disclosed even by organisations for which TNR is one of the main research areas. Meanwhile, ignoring systematic TNR actions by Belarus leads to misunderstanding of its strategy and hinders the development of effective policies to combat it. The increasing momentum in the regime’s actions violating human rights within the territories of other states while undermining their sovereignty testifies to its confidence in impunity and requires an active response from the international community, including intergovernmental organisations, governments, and civil society of democratic states, especially those with significant Belarusian diasporas. The absence of an urgent and strong response will not only stimulate further escalation of TNR by Belarus but could encourage more non-democratic regimes to adopt this path.
The Lukashenka regime’s TNR instruments constitute a sophisticated and evolving arsenal, with the scope dramatically expanding after the 2020 protests, affecting thousands who fled the crackdown. In absentia trials on trumped-up charges in extremism or terrorism have become routine, enabling remote convictions and property confiscations that dispossess families and serve as punitive deterrence.
Harassment of relatives of exiled opponents has long been a coercive tool of first choice for authoritarian regimes. A number of examples of coercion-by-proxy referred to in the report demonstrate that over the past few years this practice has been implemented by the Lukashenka regime on a systematic and massive scale. The repertoire of methods for applying pressure on relatives of exiles is not limited to searches, arrests, and criminal prosecution and includes interrogation at the border of Belarus with the European Union and collecting genetic material (saliva) from Belarusians crossing the border.
Mobility impediments entrap victims through passport invalidations, consular service denials, and border restrictions, leaving Belarusians in legal limbo and vulnerable to human rights violations. Despite the apparent consensus among international bodies on the need to take urgent measures to support Belarusians in obtaining valid personal documents, only a few countries have taken relevant practical steps.
The recent growth of TNR actions by Belarus is supported by the wide availability of surveillance technology, through which it can effectively monitor, discipline, and punish dissenters abroad. There are serious reasons to suspect that Pegasus software is used to spy on activists in exile. Another method to gather information on individuals in exile, including evidence that may be used in future criminal proceedings against them conducted in absentia, involves hacking private chatbots and correspondence or creating fraudulent chatbots for solidarity initiatives and monitoring projects.
For several years, the Belarusian authorities and their propagandists have publicly threatened activists abroad with passport cancellation, arrests, kidnapping, and coerced return. Contradictory messages from security officers who harass exiles through social networks give the impression that their goal is not to persuade those who have left to return or, conversely, not to return, but to instil in them a sense of the regime’s constant attention and to undermine their psychological state. Direct threats are complemented by other actions aimed at destroying the trust of exiles in those around them, including luring emigrants into cooperation with secret services.
The use of violence by the Lukashenka regime as a tool of TNR has a long history. It is also used against people who have left the country in recent years. Abductions and coerced returns, often via deceptive lures or forced renditions, highlight the escalating boldness of the regime’s TNR tactics. The authorities do not hide their involvement in the abduction and coerced return of exiles to Belarus. On the contrary, they use successful cases to demonstrate their strength and intimidate those who have left.
The co-optation of individuals by the Lukashenka regime to monitor and report on activities of the Belarusian diaspora and organisations in exile is implemented in three ways: by recruiting individuals with no direct ties to the opposition to carry out one-time assignments, by employing “spies” who carry out espionage activities for a long-term undercover work, and by forcing cooperation with the regime on exiles.
The Lukashenka regime employs various methods to involve other countries in its TNR practices, primarily through the abuse of the Interpol system and the submission of extradition requests based on fabricated criminal charges, often under terrorism and extremism legislation. These efforts are facilitated by bilateral agreements on criminal cooperation and multilateral treaties. Interpol’s red notices for arrest and extradition, blue notices for information gathering, and diffusions for direct notifications between states are vulnerable to abuse due to insufficient initial scrutiny, limited funding for reviews, and a lack of transparency in statistics or rejection explanations. In “cooperation in criminal matters” the regime’s closest partnership is with Russia, which fulfils 80% of extradition requests from Belarus, frequently leading to detentions, forced expulsions, or informal transfers in defiance of international human rights safeguards. This collaboration extends to mutual support in prosecutions and database sharing within the CIS framework, where Belarusians are automatically added to Russian wanted lists, suspending statutes of limitations.
Russia is not the only country that extradites and provides information about persons located on its territory to Belarus. The “high-risk” zone for Belarusian in exile includes the CIS countries, most of which maintain close ties with Belarus. The regime’s cooperation with other states in the field of TNR is continuously expanding.
Symmetries between Belarus and Russia’s TNR practices underscore their strategic alliance, with shared legislation enabling TNR. Both employ in absentia trials to convict exiles on political charges, often with property confiscations as punishment. Harassment of relatives is a core tactic, using family members as leverage through arrests or threats, evident in Russian cases paralleling Belarusian coercion-by-proxy. Further parallels include extradition abuses and mobility restrictions, where passports are revoked and consular services denied, trapping dissidents abroad. Russia innovates with AI-enhanced digital surveillance and leads in physical attacks, indicating a potential model for Belarus’s evolving violence. This collaboration forms an authoritarian network, exchanging “extremist” lists and facilitating mutual extradition orders, amplifying threats to exiles and challenging international norms.
TNR by Belarus targets civilian population, has a systematic nature and large scope, and is based on a state policy. Therefore, these actions may constitute a crime against humanity of persecution. Since it targets Belarusians who fled to other countries which are parties to the Rome Statute, this crime falls under the jurisdiction of the International Criminal Court. As States Parties to the Rome Statute, concerned states could follow Lithuania’s suite and submit their own referrals to the ICC, emphasising that TNR by the Lukashenka regime may constitute a crime against humanity.
Recommendations in the report are based on the need for urgent action and are grounded in a consolidated approach to TNR, which combines the goals of protecting human rights of the victims of repression and safeguarding state sovereignty. Comprehensive and thoughtful changes in addressing TNR are long overdue in legislation, policies, institution building, training, protection measures, investigation, cooperation with diaspora and more, both at the international and national level.
Conclusuons and recommendations
The review of the use of various practices of transnational repression (TNR) by the Lukashenka regime demonstrates the regime’s determination to silence its critics both within and outside Belarus’ jurisdiction, as well as its confidence in impunity for its actions. Acts of TNR by Belarus constitute serious breaches of international human rights law.
TNR by the Belarusian authorities targets civilian population, has a systematic nature and large scope, and is implemented on the basis of a state policy. Therefore, these actions may constitute a crime against humanity of persecution. Since they target Belarusians who fled to other countries which are parties to the Rome Statute, this crime falls under the jurisdiction of the International Criminal Court.
Moreover, abuse of international legal cooperation agreements, infiltration of the regime’s agents into the territory of other states and their actions against the Belarusian diaspora represent a hybrid threat to the European legal order.
Our recommendations are based on an understanding of the need for urgent action and are grounded in a consolidated approach to TNR, which combines the goals of protecting human rights of the targets of repression and safeguarding state sovereignty. In adopting a consolidated approach to transnational repression (TNR), it is critical to avoid an overemphasis on security measures at the expense of a human rights-based approach. Prioritising the prevention of foreign interference through restrictive instruments designed to counter the infiltration of agents and hostile actions by perpetrating states, such as the Lukashenka regime, risks fostering a climate of suspicion toward all exiled nationals from the country in question, including Belarusians. This approach may lead to the restriction of their rights and access to legal status, thereby exacerbating the pressures they already endure from their home state.
It is high time for the international community to take active steps to address the problem of transnational repression by the Lukashenka regime. Comprehensive and thoughtful changes in addressing TNR are long due in legislation, policies, institution building, training, protection measures, investigation, cooperation with diaspora organisations and more both at the international and national level.
To inter-governmental organisations:
- put the issue of transnational repression (TNR), including TNR by the authorities of Belarus, high on your agenda and treat it as a multi-dimensional problem and a specific threat to human rights and security of states;
- review and revise relevant documents to acknowledge the TNR nature of certain state actions and include additional guarantees against TNR;
- develop and adopt a declaration or a resolution on the inadmissibility of TNR and on combating it,whichwouldcontain a comprehensive definition of TNRand the basicprinciples of counteringitand would serve as abasisforthe development of unified national approaches. The definition of TNRshouldfocusnot only on the types of actions of the offendingstate,butonitspurpose,aswell as on the transnationaleffect of theseactions, and emphasise both violation of human rights of the targets of repression and the undermining of state sovereignty;
- develop comprehensive global and regional strategies for tackling TNR, grounded in a consolidated approach combining the goals of protecting human rights of the targets of repression and safeguarding state sovereignty;
- establish special bodies with the mandate to conduct research on TNR at a regional/global level, establish contacts with diaspora communities and relevant NGOs, systematically monitor manifestations of TNR, including TNR by Belarus, strongly react to specific cases, and develop recommendations or guidelines for member states on combating, preventing, and eradicating TNR;
- take into consideration systematic TNR practices by Belarus when considering Belarus involvement and initiatives within international bodies.
To states with regard to countering TNR:
- develop a comprehensive definition of TNR and adopt legislation to address gaps in responses to TNR, including criminalisation of the full range of TNR conduct;
- develop comprehensive national strategies for tackling TNR, grounded in a consolidated approach combining the goals of protecting human rights of the targets of repression and safeguarding state sovereignty;
- develop evidence-based policy recommendations;
- create specialised units in relevant law enforcement bodies to address TNR cases and ensure prompt and effective investigation, provide necessary training and resources to them;
- establish a specific government agency to comprehensively address the issue of TNR to provide a clear contact point for targets to lodge complaints and receive support, to monitor and report on the situation of instances of TNR taking effect within the state’s jurisdiction; and to provide advice to other state agencies;
- produce and distribute clear guidelines to relevant agencies and services about the process of handling reports on TNR and TNR-related human rights violations and providing protection to its targets;
- undertake awareness-raising efforts aimed at public officials who come into contact with victims of TNR and make decisions affecting their interests, including the police, migration services, prosecutors, judges, intelligence services, government services for the protection of human rights, as well as civil society organisations and the general public;
- ensure government officials who may encounter perpetrators or victims of TNR receive the training necessary to recognise and respond to the problem;
- engage with diaspora communities and relevant civil society groups;
- undertake a coordinated effort with other concerned states to establish cooperation between government bodies dealing with TNR;
- take active steps in pursuing further reforms of the Interpol and other mechanisms of international cooperation on legal matters;
- support Interpol by complying with its decisions by deleting data in national databases where the Commission for the Control of Interpol’s Files has decided to delete a red notice or a diffusion;
- apply additional vetting to red notices and diffusions from the governments that are known to engage in TNR;
- use targeted sanctions as a tool to constrain and punish the perpetrators and enablers of TNR, and highlight their actions to a wider international audience;
- work towards accountability through national proceedings based on accepted principles of extraterritorial and universal jurisdiction.
To states with regard to countering TNR by the Lukashenka regime:
- monitor and study incidents of TNR by the Lukashenka regime with regard to Belarusians in exile, broadly interpreting TNR based on the goals of the perpetrating state as well as on the transnational effect of these actions;
- reflect information on TNR by Belarus in country reports on human rights and report it in communication with inter-governmental organisations;
- resist and oppose abuse of international mechanisms of cooperation on criminal matters by the Lukashenka regime as part of its TNR actions; in particular, deny requests for extradition of Belarusians at risk of politically motivated persecution, especially those in asylum or international protection procedures, holding humanitarian visas, or with a similar status; apply additional vetting to extradition requests and Interpol notices by Belarus;
- review counterintelligence and law enforcement information-sharing practices and ensure that they effectively disseminate data about threats stemming from TNR by Belarus;
- review extradition, legal cooperation, readmission and return, and intelligence-sharing agreements with Belarus, and revise or terminate these agreements;
- build resilience against the use of spurious terrorism and extremism charges against Belarusians to distort host countries’ asylum and extradition processes;
- facilitate, in accordance with international obligations, the acquisition of alternative travel and identity documents to ensure that exiled Belarusians who cannot visit their home country safely to renew their passport, have access to essential services in the country of residence and the freedom of movement;
- undertake legislative efforts aimed at unambiguous regulation of the status of alien’s travel document as an identity document;
- undertake awareness-raising efforts aimed at government officials in your country about the recognition of an alien’s travel document as an identity document for citizens of Belarus, guaranteeing their access to essential services in the country of residence and the freedom of movement;
- review the processes for issuing warnings of threats of the use of TNR and assigning police protection to Belarusian exiled individuals targeted by TNR, and provide assistance in relocation when necessary;
- establish appropriate mechanisms for exiled Belarusian human rights defenders, journalists, and opposition activists to receive permanent legal status when needed and without excessive administrative obstacles;
- review asylum processes and include details on the use of TNR in the information about Belarus that is consulted during reviews of asylum or international protection applications to ensure that exiled dissenters are not denied legal status as a result of illegitimate criminal charges levelled against them in Belarus;
- limit the use of temporary and subsidiary forms of protection for asylum seekers and instead grant them full refugee status, decreasing exiled dissenters’ reliance on identification documents from their home country, which can be cancelled or expire; facilitate family reunification, reducing the threat of coercion by proxy;
- develop specific outreach strategies to connect relevant authorities with offices of Belarusian democratic forces and Belarusian diaspora communities;
- continue supporting Belarusian civil society organisations in exile, including those providing psychosocial assistance to victims of human rights violations;
- financially support TNR awareness-raising, media literacy, and cybersecurity skills programmes implemented by civil society groups;
- as States Parties to the Rome Statute, follow Lithuania’s suite and submit your own referrals of the situation in Belarus and neighbouring countries to the ICC Prosecutor on the basis of new information, emphasising that TNR by the Lukashenka regime may constitute a crime against humanity of persecution.
Full text of the report can be downloaded here.
Материал доступен на русском языке: Транснациональные репрессии в Беларуси: жестокий инструмент преследования инакомыслия режимом Лукашенко
