Memorandum for the Prosecution of the Crime of Aggression Committed Against Ukraine

This Memorandum for Prosecution sets out how Russia’s conduct against Ukraine constitutes the crime of aggression and represents a continuous pattern of unlawful use of force from 2014 until today. It builds on a Model Indictment published by Open Society Justice Initiative in April 2022, and now covers a broader time period, starting with the 2014 occupation of Crimea and military intervention of Donbas, to the full-scale invasion that commenced in February 2022 and continues until today.  

The Memorandum for Prosecution demonstrates how Vladimir Putin, Nikolai Patrushev, Sergei Shoigu, Sergei Naryshkin, Valentina Matviyenko, Sergei Beseda, Sergei Lavrov, and Valery Gerasimov were involved in the initiation, planning, preparation, and execution of acts of aggression. This Memorandum for Prosecution also addresses Belarus’ role in facilitating Russia’s unlawful use of force. 

Prepared by the Justice Initiative, the hope is that it gives impetus to national investigations currently underway and eventually by the Special Tribunal on the Crime of Aggression by demonstrating that it is feasible to build a solid case against Vladimir Putin and other senior leaders. 

This Memorandum for Prosecution was originally published on Just Security.