187:
countermeasures had been applied. Let's assume that the frozen assets amount to €300 billion and that by invading
Ukraine Russia became obligated under international law to pay reparations to Ukraine for the damage caused, amounting to €800 billion. If there had been no freezing of assets, Russia's balance sheet (so to speak) would show a €300 billion asset and an €800 billion liability, with a net economic result of a €500 billion liability. On the other hand, if the frozen assets are transferred to Ukraine, Russia's liability to Ukraine would be reduced by that amount, resulting in the same net €500 billion liability on its balance sheet. Since Russia would thereby be placed in the same economic condition it would have occupied if no countermeasures had been applied this must be seen as consonant with the reversibility requirement, according to the RDI report and others. Looked at in a different way, freezing the €300 billion until Russia has complied with its reparation obligation to Ukraine has the same impact on Russia as transferring the €300 billion directly to Ukraine. According to this line of thinking, if there is a right to hold onto the €300 billion until Russia agrees to give it to Ukraine then it is absurd to say that the doctrine of reversibility is violated if it is transferred directly to Ukraine but it is not violated if the countermeasure is "reversed" and the money is transferred to Russia but under conditions that offset it against an amount that Russia would be required to pay Ukraine, as in one European Commission proposal.
105:
State to ensure cessation of the breach and reparation in the interest of the injured State or of the beneficiaries of the obligation breached", this falls short of authorizing third-party countermeasures. This is further made clear by the commentary to
Chapter II of Part Three of the ARSIWA (dealing with countermeasures), para. 8, which says, "This chapter does not purport to regulate the taking of countermeasures by States other than the injured State". Without access to countermeasures as an enforcement action, third party states would be limited to those remedies available under Article 48, which would be to make claims for cessation of the internationally wrongful act, and for non-repetition and/or reparation, but they would not be able to wield more potent weapons, such as the freezing of funds in their possession, since this would not be protected by Article 22 from charges of wrongfulness, as legitimate countermeasures are.
51:." Chapter V of Part Two of the ARSIWA describes six circumstances, if any of which is present, will preclude the wrongfulness of conduct that otherwise would render the state liable for breach of an international obligation. One of these is Article 22, which states that the wrongfulness of a countermeasure action is precluded if it is taken in accordance with Chapter II of Part Three of the ARSIWA (Articles 49 through 54), which deals with countermeasures. Therefore, a validly executed countermeasure renders wrongful conduct legal under international law so long as the necessary conditions for taking countermeasures are satisfied. These conditions are designed to ensure that countermeasures are restricted to the requirements of the situation and that there will be adequate safeguards against abuse, and they are described in the comments to Chapter II of Part Three:
191:
expectation of reversibility must yield to the more pressing need to pursue a countermeasure that would effectively induce Russia's compliance with international law." However, the
Stanford Law Review article claims that the comments to the ARSIWA show that the term "as far as possible" "does not create a loophole" to justify irreversible measures, but requires a state having a choice as to which countermeasure to implement, to choose one that is reversible. Others add that while the ARSIWA may have some flexibility on reversibility, it has no flexibility on the requirement that countermeasures be temporary, and confiscation is not temporary.
153:
obligation to pay reparations. In addition, the leading treatise on the question of third-party countermeasures concluded that, "third-party countermeasures have simply not been adopted to obtain any form of reparation". On the other hand, other legal analysts have presented arguments in favor of the legitimacy of countermeasures by third party states "aimed at stopping the ongoing failure to meet the obligation to make reparations".
178:) which asserted that, with respect to the confiscation of Russian assets, the countermeasure being taken is a suspension of the sovereign immunity that Russia normally enjoys. The report insists that the requirement of reversibility does not apply to the frozen assets but to the suspension of immunity, which can be reversed when Russia comes into compliance with its international obligations. Others have agreed. A
222:'reprisals' has been limited to action taken in time of international armed conflict; i.e. it has been taken as equivalent to belligerent reprisals. The term 'countermeasures' covers that part of the subject of reprisals not associated with armed conflict, and in accordance with modern practice and judicial decisions the term is used in that sense in this chapter."
231:
For example, sovereign immunity protects states from outright seizures of sovereign assets. As the comments to ARSIWA Part Two
Chapter V make clear, another state seizing such assets would expose itself to a well-founded claim for the breach of an international obligation unless it is able to raise a
199:
Those arguing that it is an illegitimate countermeasure to confiscate
Russian assets and deliver them to Ukraine for purposes of reparations also argue that the same principle governs investing the frozen assets and turning over investment gains to Ukraine. On the other hand, some analysts claim that
190:
The RDI report adds that countermeasures must be reversible "as far as possible", and that this is not an absolute and inflexible requirement. "Accordingly, even if transfer of Russia's sovereign assets did not fully comport with the reversibility principle, this would be a prime example in which the
161:
One potential countermeasure would be for a state to freeze assets in its possession until the state at fault complies with its international obligations. The question arises as to whether it would be a legitimate countermeasure for a third-party state to outright confiscate assets in its possession
326:
says, "All
Members shall refrain in their international relations from the threat or use of force against the territorial integrity or political independence of any State, or in any other manner inconsistent with the Purposes of the United Nations." The UN General Assembly on 2 March 2022 adopted a
166:
points out that the purpose of a countermeasure is to induce compliance with international law and not to act as punishment for violations. As such, a countermeasure must be temporary and capable of being reversed if the violating country resumes its compliance with international law. However, once
27:
not involving the use of force. In other words, it refers to non-violent acts which are illegal in themselves, but become legal when executed by one state in response to the commission of an earlier internationally wrongful act by another state in order to induce that state to comply with its legal
221:
According the comments to
Chapter II of Part Three of the ARSIWA (dealing with countermeasures): "As to terminology, traditionally the term 'reprisals' was used to cover otherwise unlawful action, including forcible action, taken by way of self-help in response to a breach. More recently, the term
186:
The RDI report claims that even if reversibility referred to the economic effects of the suspension rather than to the suspension itself, the transfer of frozen assets to Russia would still satisfy reversibility since Russia will be placed in the same economic condition it would have been in if no
36:
Under the doctrine of countermeasures, a state that has been injured by an internationally wrongful act may take an action that would otherwise be unlawful (the countermeasure) against the state that committed the wrongful act in order to induce that state to comply with its legal obligations. The
104:
article, while ARSIWA Article 48(1) says that it is permissible for a third-party state to make claims on another state, including claims for reparation, when "acting in the interest of the injured party", and while ARSIWA Article 54 allows third-party states "to take lawful measures against that
63:
Since they are intended "to procure cessation of and reparation for" an "internationally wrongful act and not by way of punishment", countermeasures must be "temporary in character and must be as far as possible reversible in their effects in terms of future legal relations between the two states
204:
to use the interest and profits from frozen
Russian assets to benefit Ukraine was said to take the position that these revenues "do not constitute sovereign assets and do not have to be made available to the Central Bank of Russia under applicable rules", and therefore delivering them to Ukraine
269:
that has developed over the years, and according to the comments to
Article 54, para. 6, at the time of their drafting (2001) there was insufficient evidence in international law that a third-party right to take countermeasures had been established, so in a compromise Article 54 was added as a
182:
article calls this "...too clever by half. The reversibility requirement cannot be circumvented so easily." It argues that since transferring the assets to
Ukraine is not reversible the countermeasure does not serve to induce compliance, undercutting "the very raison d'ĂŞtre of countermeasures
152:
obligation, supporting a right of third-party states to implement countermeasures. Some legal analysts believe that it is not (though it arises from a breach of one), while others say that it may not be, rendering dubious the legitimacy of countermeasures by third party states to enforce an
137:
order that the "Russian Federation shall immediately suspend the military operations that it commenced on 24 February 2022 in the territory of Ukraine", third-party states are entitled for that reason to take countermeasures in order to bring Russia into international compliance.
695:
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that "appears to be sufficiently widespread, representative as well as consistent" showing that a significant number of states have used and relied on third-party countermeasures and the concept has not been rejected by a significant number of
73:
Countermeasures "must not involve any departure from certain basic obligations (art. 50, para. 1)," in particular obligations concerning threat of force, protection of fundamental human rights, and "peremptory norms of international
640:
167:
assets have been transferred to the wronged state this can no longer be reversed, rendering the countermeasure permanent, and its purpose punitive. This is the prevailing view and it has much support.
67:
The injured state must have already "called upon the state committing the wrongful act to discontinue its wrongful conduct or to make reparation", but the request was refused. (art. 52, para. 1).
100:
during the drafting of the ARSIWA, "The ARSIWA do not directly address whether non-injured states invoking the responsibility of a breaching state...can take countermeasures." According to a
738:
527:
Bills, Amanda (2020-03-14). "The Relationship between Third-party Countermeasures and the Security Council's Chapter vii Powers: Enforcing Obligations erga omnes in International Law".
183:
doctrine." Reversibility is a key requirement, the article insists, without which there is likely to be a "rapidly proliferating unlawfulness" bringing many undesirable consequences.
93:, a European country in possession of funds belonging to Russia might wish to freeze those funds until Russia agrees to cease its aggression against Ukraine and pay reparations.
200:
confiscating just the income or interest on the frozen funds would not violate the requirement that countermeasures be reversibile. A proposal announced 12 December 2023 by the
641:"The Contribution Of International Humanitarian Law To The Development Of The Law Of International Responsibility Regarding Obligations Erga Omnes And Erga Omnes Partes"
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in order to cause another state to be held responsible for a breach of an international obligation and obligated to pay reparations. For example, in the case of the
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455:
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Article 31(1) says, "The responsible State is under an obligation to make full reparation for the injury caused by the internationally wrongful act."
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States were motivated by a belief that they were legally compelled to accept the legitimacy of third-party countermeasures by reason of a rule of
771:
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As a result of significant risks of abuse associated with the use of third-party countermeasures, and strong opposition in the
845:
Moiseienko, Anton (17 April 2023). "The Freezing and Confiscation of Foreign Central Bank Assets: How Far Can Sanctions Go?".
430:
902:
291:
954:
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shield to such claims, which can be accomplished if any one of six "circumstances precluding wrongfulness" is present:
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43:(ARSIWA), "are considered by courts and commentators to be in whole or in large part an accurate codification of the
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1008:
Tribe, Laurence H.; Tolentino, Raymond P.; Harris, Kate M.; Erpenbach, Jackson; Lewin, Jeremy (17 September 2023).
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Countermeasures must be "directed at the responsible state and not at third parties (art. 49, paras. 1 and 2)."
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109:
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44:
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obligation, giving third party states the right to take countermeasures against the aggressor state.
595:"Second report on identification of customary international law by Michael Wood, Special Rapporteur"
20:
403:"Draft articles on Responsibility of States for Internationally Wrongful Acts, with commentaries"
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563:
372:
1142:"Confiscating Russia's Frozen Central Bank Assets: A Permissible Third-Party Countermeasure?"
564:"Collective Countermeasures in Cyberspace – Lex Lata, Progressive Development or a Bad Idea?"
120:("owed to the international community as a whole") obligations. Once such a rule emerges, a
1010:"The Legal, Practical, and Moral Case For Transferring Russian Sovereign Assets to Ukraine"
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86:
48:
38:
8:
705:. Cambridge University Press (CUP). p. 727. Archived from the original on 2022-11-05
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AuslÄ, R; Ö, Ndisches; Vö, ffentliches Recht und (2022-09-15).
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492:
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resolution declaring Russia to be in violation of this provision of the UN Charter.
1189:"The New Frontiers of European Sanctions and the Grey Areas of International Law"
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entitling third-party states to apply countermeasures to enforce compliance with
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Third-party countermeasures concern the rights of a non-injured state to invoke
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175:
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1062:"Multilateral Asset Transfer: A Proposal for Ensuring Reparations for Ukraine"
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1038:[Let's guarantee that Russia will pay for Ukraine's reconstruction].
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862:
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270:"saving clause" to be used if and when such a right became established under
878:"UK to keep Kremlin assets frozen until Russia pays compensation to Ukraine"
481:"Dispute Settlement and Countermeasures in the International Law Commission"
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447:
40:
Articles on the Responsibility of States for Internationally Wrongful Acts
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1091:"Frozen Russian Assets and the Reconstruction of Ukraine: Legal Options"
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Max-Planck-Institut für ausländisches öffentliches Recht und Völkerrecht
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431:"A Legal Approach to the Transfer of Russian Assets to Rebuild Ukraine"
115:
1036:"" Garantissons que la Russie paiera la reconstruction de l'Ukraine ""
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194:
772:"Countermeasures and the Confiscation of Russian Central Bank Assets"
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The question remains whether the obligation to pay reparations is an
24:
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and deliver them to the wronged state as reparations. An article in
371:
Hathaway, Oona A.; Mills, Maggie; Poston, Thomas M. (2023-11-08).
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A rule, such as one allowing third-party countermeasures, becomes
930:"Rebuilding Ukraine Will Be Costly. Here's How to Make Putin Pay"
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739:"Central Bank Immunity, Sanctions, and Sovereign Wealth Funds"
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Countermeasures must be "non-forcible (art. 50, para. 1 (a))."
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However, it is widely believed that a rule has emerged under
1214:"E.U. Moves to Tap Frozen Russian Assets to Help Ukraine"
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Some legal analysts believe that since Russia defied the
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821:"The Unintended Consequences of Seizing Russian Assets"
797:"The Unintended Consequences of Seizing Russian Assets"
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903:"Proposals to Seize Russian Assets to Rebuild Ukraine"
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744:. George Washington University Law Review. p. 31
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491:(3). American Society of International Law: 471–477.
955:"How to Make Russia Really Pay for Invading Ukraine"
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Confiscation of income or interest on frozen assets
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70:Countermeasures "must be proportionate (art. 51)."
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616:"Customary International Law – International Law"
205:would not violate the reversibility requirement.
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722:: CS1 maint: bot: original URL status unknown (
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373:"War Reparations: The Case for Countermeasures"
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1116:"Sanctions, Confiscation, and the Rule of Law"
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571:Cooperative Cyber Defence Centre of Excellence
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1212:Pronczuk, Monika; Nelson, Eshe (2023-12-12).
666:Hook, Kristina; Diamond, Yonah (2023-08-23).
324:United Nations Charter Article 2, paragraph 4
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1096:. International Lawyers Project. p. 30
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737:Brunk, Ingrid (Wuerth) (18 February 2023).
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668:"The case for seizing Putin regime assets"
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770:Brunk, Ingrid (Wuerth) (2023-05-03).
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703:American Journal of International Law
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174:(RDI) released a report (lead author
1146:Netherlands International Law Review
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261:The ARSIWA are a compilation of the
64:(arts. 49, paras. 2 and 3, and 53)."
1060:Ziskina, Yuliya M. (14 June 2023).
1034:Thouvenin, Jean-Marc (2022-05-02).
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529:Nordic Journal of International Law
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14:
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1140:Kamminga, Menno T. (2023-04-18).
1114:Moiseienko, Anton (2023-01-19).
876:Wintour, Patrick (25 May 2023).
379:. Stanford Law Review. p. 7
1089:Moiseienko, Anton (July 2022).
978:Strobel, Gabriel (2023-09-17).
928:Criddle, Evan (30 March 2022).
795:Demarais, Agathe (2023-11-27).
696:"TRADING WITH A FRIEND'S ENEMY"
694:Moiseienko, Anton (July 2022).
593:Wood, Michael C. (2014-05-22).
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429:Zelikow, Philip (2022-05-12).
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135:International Court of Justice
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1187:Bismuth, RĂ©gis (2022-05-18).
1120:Groupe d'études géopolitiques
953:Stephens, Bret (2023-09-19).
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287:if two requirements are met:
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1015:. Renew Democracy Initiative
98:International Law Commission
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300:customary international law
285:customary international law
272:customary international law
263:customary international law
110:customary international law
91:Russian invasion of Ukraine
81:Third-Party Countermeasures
45:customary international law
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1159:10.1007/s40802-023-00231-7
172:Renew Democracy Initiative
541:10.1163/15718107-bja10003
479:Schachter, Oscar (1994).
241:countermeasures (art. 22)
980:"Making Putin Pay – RDI"
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21:public international law
847:SSRN Electronic Journal
302:obliging them to do so
244:force majeure (art. 23)
170:In September 2023, the
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238:self-defense (art. 21)
157:Confiscation of assets
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126:
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1152:(1). Springer: 1–17.
562:Roguski, Przemysław.
535:(1). Brill: 117–141.
855:10.2139/ssrn.4420459
456:"World Court Digest"
267:state responsibility
87:state responsibility
49:state responsibility
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849:. Elsevier BV: 40.
639:Longobardo, Marco.
250:necessity (art. 25)
202:European Commission
180:Stanford Law Review
102:Stanford Law Review
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959:The New York Times
909:. 29 December 2022
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