2

by Defendants, who have worked both inside and outside of government channels for the purpose of unjustly enriching themselves at the expense of Ukrainian citizens. 2.

Since Viktor Yanukovych assumed office as President of Ukraine in February

2010, at least 12 of his administration’s

senior political opponents

—

former Prime Minister Yulia Tymoshenko and 11 senior o fficials in her administration - have been arbitrarily arrested, detained, and prosecuted on unfounded, politically-motivated criminal charges in violation of international law. These political persecutions have been carried out at the direction of Defendant Viktor Pshonka,

Ukraine’s

Prosecutor General, with the knowledge, consent, and material support, if not at the request, of the remaining Defendants and their agents and co- conspirators, in an attempt to quash political op position in Ukraine and unjustly enrich Defendants at the expense of Ukrainian citizens. 3.

The current regime

’s

political persecution of its opponents has been facilitated by a number of measures instituted by the Yanukovych Administration to consolidate power in the executive branch and weaken judicial independence, in what has been described by international observers as a move towards a more authoritarian state. 4.

The international community has strongly criticized the Yanukovych Administration for allowing the criminal law to be used in this man ner as a tool to achieve political ends. The

United States has repeatedly “reiter

ate[d] its concern about the appearance of politically-

motivated prosecutions of opposition figures in Ukraine,” stating, “[w]hen the senior

leadership of an opposition party is the focus of prosecutions, out of proportion with other political figures, thi

s creates the appearance of a political motive.”

See

Exhibit 1

. The European Union (EU) likewise issued a resolution decrying the selective prosecution o f Tymoshenko and

other members of Ukraine’s political opposition and calling for comprehensive reform

s that