AS/Jur (2023) 17 repression through targeted sanctions and diplomatic consequences; press for increased transparency at INTERPOL, as well as reforms to domestic procedures for the use of INTERPOL notices where necessary to ensure such notices are not misused; take into account other countries’ practices of transnational repression when considering bilateral security agreements, extradition treaties, foreign aid, and information-sharing practices; and impede, including through export controls and licensing restrictions, the misuse of surveillance technologies for digital transnational repression. 20 3. Practices and cases of transnational repression in Europe 15. The above reports referred to cases of transnational repression as a global phenomenon, with many of them occurring or originating in the territories of current and former member States of the Council of Europe. For the purposes of the present report, I will describe below some notable cases and practices of transnational repression occurred in Europe in recent years. 3. 1. Russia 16. The poisoning of Alexander Litvinenko could be regarded as the best-known example of transnational repression. Mr Litvinenko, a Russian ex-spy who defected to United Kingdom intelligence and a prominent critic of Russian President Vladimir Putin, died in November 2006 in London, three weeks after being poisoned by radioactive polonium-210. Investigations in the United Kingdom found that two Russian citizens acting under the direction of the FSB (Federal Security Service) poisoned him with the "[probable approval] by Mr. [Nikolai] Patrushev, then head of the FSB, and also by President Putin." 21 In September 2021, the European Court of Human Rights (the Court) found the Russian Federation responsible for the targeted killing of Mr Litvinenko and the lack of an effective investigation into his death.22 17. The assassination of Mr. Litvinenko was one in the long list of suspicious deaths or physical attacks against Russian dissidents settled in the United Kingdom. In June 2017, BuzzFeed News reported23 other cases connected to a “wider campaign of Kremlin-sanctioned killing around the world” 24. This investigation identified at least fourteen suspected assassinations and several failed murder attempts, threats, or other forms of repression directed against Russian dissidents settled abroad, mainly in the United Kingdom, and notably linked to the so-called inner circle of Boris Berezovsky. 18. Igor Ponomarev, former Russian ambassador to the United Nations’ International Maritime Organization, collapsed and died after a night at the opera in London in October 2006, two days before the poisoning of Mr Litvinenko. It was reported that Mr Ponomarev, who also, as it happens, met with Litvinenko soon after he had been poisoned, had an upcoming appointment to meet with a security consultant investigating connections between the Russian security service and Italian politicians. 19. Reporter Daniel McGrory died suddenly in February 2007, five days before the airing of an NBC documentary in which he reported on the polonium that poisoned Mr Litvinenko. Another person interviewed for that documentary, US security expert Paul Joyal, was shot and seriously wounded on his driveway by unknown assailants soon after the documentary was broadcasted. NBC reported these two incidents as “mysterious”. 20. Yuri Golubev, the co-founder of Yukos with Mikhail Khodorkovsky, a political opponent of Mr Putin, was found dead in January 2007 at his flat in London. Shortly before his death, he had returned from China via Moscow earlier than planned, saying he was not feeling well. The death was classified as unsuspicious, but Russia’s Prosecutor General declared that there were “all grounds to suppose” that Golubev had been killed.25 21. In November 2012, Alexander Perepilichnyy, a Russian financier, died suddenly while jogging near his home in Surrey, England. He disclosed and passed evidence on a $230 million money-laundering operation 20 Declaration of Principles to Combat Transnational Repression | Freedom House. Sir Robert Owen, the Inquiry Chairman, published his Report into the death of Alexander Litvinenko on 21 January 2016. 22 Carter v. Russia, No. 20914/07, 21 September 2021. 23 From Russia With Blood: 14 Suspected Hits On British Soil That The Government Ignored (buzzfeednews.com) 24 H. Blake, From Russia with Blood: The Kremlin’s Ruthless Assassination Program and Vladimir Putin’s Secret War on the West (First edition, 2019). 25 Yury Golubev, 64, a Founder of Yukos Oil, Dies - The New York Times (nytimes.com) 21 10