Executive summary

On 31 October 2022, a newly created, supposed NGO, the Institute for European Integrity (IEI), published an entry for the Open Dialogue Foundation (ODF) as part of its “NGO Watchlist.” IEI labelled the Foundation as an organisation with alleged “strong links to individual(s) sanctioned or criminally prosecuted by a European Union, United States or United Kingdom government.” IEI had never contacted the Foundation before its publication to ensure that their information was accurate and factually correct.
We believe that IEI was manipulated into publishing such a libellous entry by Stephen M. Bland, known to have been serving Kazakhstani propaganda for many years, aiming to undermine the legitimate human rights work of the Foundation. Therefore, below is a debunking of all the false claims about the Foundation included by Stephen Bland in IEI’s article.
The Foundation is known for its hard-line approach against human rights and the rule of law abusers. It has thus made many powerful enemies with virtually unlimited financial resources, used to harass the Foundation for its human rights work for many years. Since its founding, the statutory objectives of the Foundation include the protection of human rights, democracy, and the rule of law in the post-Soviet area. The Foundation initially focused its attention primarily on Kazakhstan, Russia, and Ukraine. Between 2016 and 2021 it also monitored the human rights situation in Moldova. Since July 2017, the Foundation has been campaigning in defence of the rule of law and human rights in Poland due to the rapidly deteriorating situation in the country and in other EU member states affected by illiberal policies implemented by their populist governments. The Foundation was one of the initiators of reforming INTERPOL and mutual legal assistance mechanisms which had become a transnational repression tool for authoritarian regimes such as Kazakhstan, Russia, Turkey, China, Azerbaijan, and Uzbekistan. Since 2011, in coalition with other activists and human rights defenders, the Foundation has been one of the pioneer organisations promoting the implementation of a personal sanctions regime in the EU to be used against human rights violators, corrupt officials, and oligarchs who enjoy impunity in their home countries.
Since Russia’s full-scale invasion of Ukraine in February 2022, ODF has become one of the leading international NGOs supporting Ukraine’s armed forces and one of the top NGOs supporting refugees from Ukraine in Poland, delivering over 6,5 million Euros worth of defensive gear and humanitarian aid.
However, in a clearly biased way, IEI – under the influence of Bland – has completely ignored the body of work accomplished by the Foundation over its more than 10-year history. Unfortunately, IEI has become yet another organisation for Bland, as a Kazakhstani regime proxy, used to attack the Foundation’s partner organisations and European politicians who have successfully defended hundreds of political prisoners in the region over the years and promoted personal sanctions for perpetrators. Traditionally, Bland’s claims come from highly unreliable sources: Kazakhstani and Russian regime propaganda, fakes produced by the former corrupt government of Moldova, and accusations from the highly criticised hybrid regime in Poland – all three states where ODF has defended human rights and the rule of law, and therefore, has entered in a direct conflict with the authorities (in the case of Moldova the conflict between the authorities and the Foundation was resolved with the fall of the corrupt rule of Vladimir Plahotniuc). The disinformation attacks of these regimes aim to falsely present the Foundation as a corrupt NGO financed by oligarchs and tied to Russia to undermine its credibility and discredit its reports. IEI’s allegations against the Foundation are consistent with those ongoing disinformation attacks.
As mentioned, it should also be noted that the entry on ODF is based on an article by Stephen M. Bland, a person with a long, documented history of activities aimed solely at discrediting the Foundation and supporting the Kazakhstani regime. We believe that, if it wants to stay true to its mission, IEI should conduct an internal investigation on why and how it was manipulated into publishing the article smearing the Foundation.
1. Foundation’s work and politically motivated attacks against the Foundation. Debunking of false claims and accusations.
1.1. Ukraine
1.1.01. Let My People Go Campaign: Nadezhda Savchenko’s case
One of the accusations of IEI against the Foundation is that the Foundation was “lobbying on behalf of [Ukrainian military pilot and political prisoner in Russia] Nadezhda Savchenko” and that “[s]hortly [after her release from the captivity in Russian], Savchenko set her sights on the “enemy” within, undertaking to undermine the Ukrainian state in a manner which directly fit Russia’s strategic narratives.” However, IEI fails to address any of its questions directly to the Foundation or even to conduct open-source research to see what kind of work the Foundation has done in connection with Savchenko’s case.
ODF feels very privileged that it had started the defence of Nadiya Savchenko [1], [2], Oleg Sentsov [1], [2], dozens of other Kremlin’s hostages back in 2014. In cooperation with the Ministry of Foreign Affairs of Ukraine, the Foundation organised the first international observation mission to visit Nadiya Savchenko and Oleg Sentsov in Russia. In 2016, the Foundation and the Centre for Civil Liberties (CCL, laureates of the 2022 Nobel Peace Prize) prepared a special report as a part of the #LetMyPeopleGo Campaign to release 28 Kremlin’s hostages that were illegally imprisoned in Russia and occupied Crimea based on political motives. The international campaign and special report included, i.a. military pilot Nadiya Savchenko, film director Oleg Sentsov, son of Mustafa Dzhemilev, Khaiser Dzemilev, and many other Ukrainians.
The Foundation was actively engaged in the support campaign for Nadiya Savchenko by promoting the so-called “Savchenko List” of political prisoners in the European Parliament and the national parliaments of the EU member states. It presented proposals of individual targeted sanctions against Russian officials involved in human rights violations. The Verkhovna Rada of Ukraine adopted the bill “On the implementation of personal sanctions against individuals responsible for the illegal detention of Nadiya Savchenko” based on the Foundation’s “Savchenko List”. The Foundation has also countered Russian attempts to disseminate false information about the cases of the Kremlin’s hostages.
Numerous Ukrainian and international organisations have supported the #LetMyPeopleGo Campaign: People in Need, Euromaidan Press, Euromaidan Warszawa, Ukrainian Helsinki Human Rights Union, Kharkiv Human Rights Protection Group, the Ministry of Foreign Affairs of Ukraine, Ukrainian Ombudsman Office, etc. In 2015, the Atlantic Council awarded Nadiya Savchenko the Freedom Award.
In 2016, after more than two years in Putin’s captivity, Savchenko was released and brought home to Ukraine. According to IEI’s allegations against the Foundation, “Savchenko set her sights on the “enemy” within, undertaking to undermine the Ukrainian state in a manner which directly fit Russia’s strategic narratives.” However, Savchenko’s political position after her release is outside of the scope of the Foundation’s work. IEI fails to see a distinction between the protection of human rights in politically motivated cases and the actions and/or political position of victims of human rights violations. Human rights defenders are not responsible for the political actions/position of victims of human rights violations, and any behavior and/or statement of a victim of human rights violations (especially after their defence has finished) should not be imputed to human rights defenders.
1.1.02. Fake statement about SBU’s allegations against Lyudmyla Kozlovska, president of the Foundation.
On its website, IEI repeats a false allegation that “[i]n 2018, the Security Service in Ukraine opened an investigation into Kozlovska for actions ‘aimed at changing the territory or state border of Ukraine’”. The allegation was debunked still in 2018 by Ukraine’s Security Service itself.
In fact, Bland, on behalf of IEI, regurgitates a false statement first published on the website of a Ukrainian pseudo-media outlet “Stop Corruption” (www.stopcor.org) on October 10, 2018, claiming that on September 25, 2018, the Department of the Security Service of Ukraine (SBU) in the Zakarpattya region city of Uzhhorod initiated an investigation against Lyudmyla Kozlovska, president of the Foundation.
Just like IEI, “Stop Corruption” falsely claimed that “the SBU said that [the Foundation] the defender of the rights of international financial swindler Mukhtar Ablyazov was accused of violating a number of articles of the Criminal Code”. This disinformation further circulated in various media outlets, including Polskie Radio, Moldovan, and Kazakhstani news outlets that IEI quotes. The Foundation considered this statement a part of the coordinated smear campaign against the Foundation. On 2 November 2018, the Head of the Investigation Department of Ukraine’s Security Service Directorate in Zakarpattia Province sent a letter to the Foundation, confirming that the claims made by “Stop Corruption” were false. Several independent media outlets also debunked the manipulation [1], [2]. Yet again, IEI fails to conduct basic open-source research to see whether this allegation against the Foundation had any merit. In its verdict of 10 August 2022, the Obolon District Court of Kyiv found the information posted in 2018 on the website www.stopcor.org in one of the publications to be unreliable and degrading to Kozlovska’s honour, dignity, and business reputation. The court ordered the beneficial owner of the website, the NGO “Stop Corruption” (and not the nominal owner of the website), to pay Kozlovska moral compensation of UAH 50.000 and to publish a refutation on its website within 10 days from the date the decision enters into force.
1.1.03. Foundation’s other projects in Ukraine
While falsely accusing the Foundation of corruption and lack of integrity, IEI twisted the work that the Foundation has done with respect to a former Kremlin’s hostage and completely ignored all other projects that the Foundation has been doing in Ukraine in that period, from its support for the Revolution of Dignity (Maidan) to the Lustration Project, among many other, all easily found on the website of the Foundation. Furthermore, since Russia’s full-scale invasion of Ukraine in February 2022, the Foundation raised and delivered over 6,5 million Euros worth of defensive gear and humanitarian aid to support Ukraine’s defenders and refugees from Ukraine.
1.1. Foundation’s work in Kazakhstan
Bland, under the shield of IEI, bluntly accuses the Foundation of having “ties to fugitive Kazakh businessman Mukhtar Ablyazov” as he has been doing for years, serving Kazakhstani propaganda. However, Bland traditionally does not disclose the nature of those alleged “ties” that “run deep,” according to his claims. It is also noteworthy that after some time, when Bland’s propaganda is exposed, he tends to delete such articles:

On behalf of IEI, Bland makes the following statement: “one has to question why the [Foundation] has been identified as the Registrant of the website mukhtarablyazov.org since September 2014,” probably hinting that this website is a proof of some nefarious relations between the Foundation and Mukhtar Ablyazov. However, IEI as an institution fails to address any of its questions directly to the Foundation or even to conduct open-source research to see what kind of work the Foundation has done in connection with Kazakhstan or specifically regarding the political persecution of Mukhtar Ablyazov.
In fact, since 2010, the Foundation has been defending victims of human rights violations in Kazakhstan committed by the regime of Nursultan Nazarbayev (and, recently, of his nominee Kassym-Jomart Tokayev). The Foundation has contributed to defending the lives of more than 9000 victims of political prosecution and freeing over 200 political prisoners, including Mukhtar Ablyazov. It appears that Bland purposely fails to mention in the IEI’s article that Kazakhstan is internationally recognised as an authoritarian regime severely violating human rights and civil freedoms (Freedom House, Amnesty International [1], [2], Human Rights Watch, U.S. State Department, U.S. Helsinki Commission, UN OHCHR, European Parliament). Mukhtar Ablyazov, a nuclear physics engineer by training, has been in opposition to the authoritarian regime in Kazakhstan for over 20 years.
The Foundation is one of the leading experts on the issues of politically motivated human rights violations in Kazakhstan, as well as on issues of torture, political prisoners, freedom of assembly, and freedom of speech. The Foundation’s 89 reports and 135 statements & opinions related to Kazakhstan brought human rights abuse cases to the attention of the U.S. Congress, White House, UN, EP, EEAS, foreign ministries, and national parliaments of the EU member states. The Foundation’s expertise served as one of the primary information sources for drafting the U.S. State Department’s “Kazakhstan 2018 Human Rights Report”.
The Foundation also launched #ActivistsNotExtremists, a social media campaign & watchdog group that collects information on violations by the regime and provides legal and humanitarian support to victims of human rights violations and politically motivated persecution. It has grown to include more than ten human rights groups and thousands of activists from Kazakhstan. The Foundation’s regularly-updated “Servants of the Regime” report, which currently constitutes an evidence-based list of 364 human rights violators in Kazakhstan, resulted in a resolution of the European Parliament calling for personal sanctions against Kazakhstani officials. The Servants of the Regime report is based on the information and evidence from 1119 victims of political persecution from 37 cities in Kazakhstan, as well as documents, administrative and criminal case materials, as well as photo and video evidence. The Foundation’s latest list of political prisoners includes 105 people. Each case is described and verified by the Foundation. This body of human rights advocacy work turned the Foundation and its representatives into one of the primary international targets of Kazakhstan’s regime.
1.2.01. Politically motivated persecution of Mukhtar Ablyazov by the Kazakhstani regime.
With respect to Mukhtar Ablyazov, the Foundation recognises Kazakhstan’s persecution of Mukhtar Ablyazov as politically motivated. Mukhtar Ablyazov has dedicated his life to opposing the dictatorial regime in Kazakhstan since resigning in 1999 as Kazakhstan’s Minister of Energy, Industry and Trade. He was jailed after co-founding the leading democratic opposition party there in 2001. While in prison from 2002 to 2003 he was tortured and had most of his wealth unlawfully expropriated by the regime. Amnesty International, Human Rights Watch, the European Parliament, the OSCE, and the U.S. State Department denounced the charges against Ablyazov as politically motivated and his trial as unfair. Following international pressure, Ablyazov was freed in 2003.
In subsequent years Ablyazov intensively but discretely supported the political opposition and independent media in Kazakhstan. In 2009, the political conflict with the regime escalated. This escalation resulted in the forcible nationalisation of BTA Bank, which Mukhtar Ablyazov headed and in which he owned about 80% of shares. As the bank was being seized, Ablyazov left Kazakhstan. Since 2009, Kazakhstan has hired an army of lawyers, lobbyists and PR consultants to launch actions against Ablyazov in numerous jurisdictions worldwide, destroying his business and reputation to have him extradited to Kazakhstan.
The Foundation started defending Mukhtar Ablyazov, as well as those who were persecuted by the regime in Kazakhstan for their association with Ablyazov, in May 2013, after his wife and six-year-old daughter were illegally abducted from Italy to Kazakhstan on board of a private jet chartered and paid for by Kazakhstan’s embassy. On 18 July 2013, the United Nations issued a press release stating: “The circumstances of the deportation give rise to the appearance that this was in fact an extraordinary rendition.” The Foundation considers any kidnapping of a wife and child of a political opponent as an outrageous case of transnational repression. As a result of the pressure of the international community, including human rights defenders such as our Foundation, on 27 December 2013, the two hostages were released by Kazakhstan. They were able to return to Italy, where, in April 2014, they were granted political asylum.
In 2009, Russia and Ukraine posted INTERPOL notices for Ablyazov’s arrest, assisting Nazarbayev’s regime in its campaign against its principal political opponent. In July 2013, Ablyazov was arrested in France and spent three and a half years under extradition arrest. Lacking an extradition treaty or convention arrangements with Kazakhstan, after Ablyazov’s arrest and detention, the French authorities submitted only the Ukrainian and Russian extradition requests for consideration by the French courts. All of the extradition cases targeting Ablyazov were based on embezzlement-related charges. The Foundation, as well as Human Rights Watch, Amnesty International, the Committee for the Protection of Illegally Accused Persons, FIDH, Centre for Civil Liberties, and Human Rights Information Centre, believed that oppositionist Mukhtar Ablyazov should be extradited neither to Ukraine nor to Russia due the threats of torture, an unfair trial and unlawful interference by Kazakhstan.
On 9 December 2016, the French Council of State (Conseil d’État) recognised the political nature of the extradition request from Russia, stating that the latter was acting on behalf of Kazakhstan. Ablyazov was immediately released. In the 9 December 2016 decision, the Council of State declared the following:
…Whereas, by virtue of a fundamental principle recognised by the laws of the Republic, the State shall refuse the extradition of a foreigner when it is requested for a political purpose; whereas, according to Article 3 (§2) of the European Convention on Extradition, extradition shall not be granted “if the requested Party has substantial grounds for believing that a request for extradition for an ordinary criminal offence has been made for the purpose of prosecuting or punishing a person on account of his race, religion, nationality or political opinion, or that that person‘s position may be prejudiced for any of these reasons”…
…whereas all circumstances in this case show clearly that Ablyazov‘s extradition to Russia was sought for a political purpose; therefore, such extradition could not be lawfully granted… [Emphasis added]
In proceedings at the Council of State that ran for over a year (from November 2015 to December 2016), France’s supreme administrative court concluded that Kazakhstan, Ukraine and Russia had acted in concert seeking to prosecute Ablyazov, using embezzlement allegations, for a political purpose.
Mukhtar Ablyazov now lives in exile in France. He is a founder of the peaceful political movement “Democratic Choice of Kazakhstan” (DCK), banned in Kazakhstan as an extremist organisation. He is present daily on social networks (FB, YouTube, Instagram and most recently Telegram), commenting on every political and socio-economical event in the country, educating his followers and organizing political protests in the country. DCK and the peaceful “Street Party” political movement (Koshe Partiyasy), related to Ablyazov according to the Kazakhstani government, are persecuted as the two most prominent opposition movements in the country (European Parliament Resolutions [1], [2], Freedom House, Human Rights Watch, PACE, RFE/RL, Bertelsmann Stiftung). Despite that, hundreds of thousands of people in Kazakhstan subscribe to Ablyazov’s accounts and interact with him daily, at the risk of being arrested in their country and convicted for “supporting an extremist organisation”. The authorities in Kazakhstan have considered Ablyazov a direct threat to the regime for years.
On 10 July 2017, INTERPOL cancelled all Red Notices that had been issued for Ablyazov’s arrest. After an exhaustive examination of Ablyazov’s file, which included seeking additional information from Kazakhstan, Ukraine, and Russia, INTERPOL determined that the BTA Bank-related allegations against Ablyazov were predominantly political. Therefore, the Red Notices were cancelled for non-compliance with rules on political abuses of INTERPOL.
After Ablyazov’s release from extradition arrest in France, Kazakhstan did not cease its politically motivated prosecution of Ablyazov. Moreover, it has intensified its negative PR campaign and lobbying efforts.
For example, as reported by the French media, “on October 7, 2019, Kassym-Jomart Tokayev wrote a “confidential” letter to President Macron. He reminded him of the “volume of commercial exchanges” between our two countries – more than 50 billion dollars in recent years – before talking about a completely different subject: “At the same time, with this letter, I would like to draw your attention to a very important problem. At present, Ablyazov, a citizen of Kazakhstan, a fugitive from justice, the head of a transnational criminal community whose main activity is carried out in France and Europe, the mastermind of the murder of his former banking partner, lives in Paris.” A man who uses “money stolen from the people of Kazakhstan, as well as influence on decision-makers and human rights defenders [to] create an image of a political refugee.” “Mr. President, I believe that this situation is harmful to both our countries,” the dignitary concluded. On behalf of the Republic of Kazakhstan, I hereby request that you order the prompt detention of Mr. Ablyazov and his delivery to the Kazakh authorities”.”
On 29 September 2020, the French National Asylum Court granted Ablyazov political asylum. Yet, in an unprecedented move, on 8 December 2022, the same French National Asylum Court cancelled Ablyazov’s political asylum. Ablyazov publicly stated that he would appeal this decision.
The Foundation posted all information on Mukhtar Ablyazov’s case that the Foundation was reviewing, all its reports on his case and all cases related to him on mukhtarablyazov.org to (1) ensure full transparency of our work on the case and (2) reduce the number of DDoS attacks that the Foundation’s main website suffered each time any information related to Ablyazov was posted there. After Ablyazov was released by the French Council of State in December 2016, management of the website was handed over to members of Ablyazov’s family.
Similarly, we had to create separate websites with respect to the case of a former political prisoner from Kazakhstan, Vladimir Kozlov, as well as with respect to our investigation of the Zhanaozen massacre in Kazakhstan in 2011, and the Foundation’s subsequent investigation of mass torture cases committed by the authorities of Kazakhstan.
1.2.02. Politically motivated persecution of Viktor Khrapunov and his family
Again, without any merits, IEI claimed that “[a]nother convicted criminal the [Foundation] have campaigned on behalf of the fugitive former Mayor of Almaty, Viktor Khrapunov, and his family.” There was no campaign on the part of the Foundation with respect to the Khrapunov’s case. This is another false claim of IEI.
The case of the former mayor of Almaty Viktor Khrapunov was one of 50 cases from various countries described in the report on the abuse of INTERPOL and extradition requests. A coalition of human rights organisations, namely, the Foundation, the Italian Federation for Human Rights, the Arrested Lawyers Initiative, the Human Rights Defenders e.V. (HRD) and the Kharkiv Institute for Social Research, included the Krapunov’s case, as well as the case of Ablyazov, in the joint report “They’ve Come For You: Misuse of Extradition Procedures and Interstate Legal Assistance.”
The case of Khrapunov and his family is one of the glaring examples of how the authoritarian Kazakhstani regime abuses mechanisms of international cooperation for political purposes. INTERPOL recognised that the persecution of the Khapunov’s family was politically motivated and Red Notices were cancelled for non-compliance with INTERPOL’s rules against political abuses. Switzerland twice refused to extradite the Khrapunov’s family to Kazakhstan and granted them political asylum after establishing there was a well-founded fear of persecution in Kazakhstan. Moreover, the Tribunal Federal (the equivalent of a supreme court in Switzerland) issued a ruling that cancelled the Swiss money laundering investigation based on Kazakshtan’s allegations against the Khrapunov’s family. Kharpunov and his family were completely acquitted by Swiss law on the merits. The only place where Khrapunov’s family was convicted was Kazakhstan, which, according to the latest Freedom House report, is designated as a “consolidated authoritarian regime” with a Democracy Percentage of 6 out of 100. The trial of Khrapunov’s family in Kazakhstan cannot be considered fair and impartial.
1.2.03. Use of private intelligence consultancies & lobbying operations by Kazakhstan
It is well documented that aiming to fight its key political opponent Mukhtar Ablyazov, the regime in Kazakhstan spends millions of dollars by hiring hordes of lawyers, detectives, lobbyists, and PR professionals all over the world (Washington, Paris, London, etc.). The central objective of this sprawling war machine is to deny the political nature of Mukhtar Ablyazov’s involvement by portraying him as a crook who, after having dishonestly enriched himself, seeks to hide his greed by posing as a political opponent. The Kazakhstani authorities have used a host of lawyers and lobbyists to interfere with Western law enforcement and judicial systems to effectively strip Ablyazov of his refugee status and silence him forever in one way or another.
To achieve said objectives, the regime in Kazakhstan organizes, directly or indirectly, constant attacks on everyone who dares to defend Mukhtar Ablyazov by pointing out political motivations for his persecution. Kazakhstan organizes, directly or indirectly, constant smear campaigns against the Foundation and its management to undermine the Foundation’s credibility.
The Kazakhstani government has retained PR companies to promote its narrative of economic progress and political stability, challenge the perception that Kazakhstan is a politically repressive state, and implicitly delegitimise its political opponents in exile. It has employed international communications and strategy companies, reportedly including Portland Communications, Tony Blair Associates, BGR Gabara, and Media Consulta. The Kazakhstani authorities have calculated that improved formal and informal political connections with Western governments will assist them in limiting the options for political opponents to gain asylum or operate freely abroad, as well as to undermine the work of human rights activists and/or organisations, like the Foundation. In that aim, they appear to have been at least partially successful.
The Kazakhstani authorities have used these private intelligence companies, law firms, consultants and PR companies to mount a remarkably ambitious campaign in multiple jurisdictions in Europe to trace, prosecute and seek to extradite Mukhtar Ablyazov and many of his associates. In doing so, the Kazakhstani government – and its various agents – have often become involved in activities that appeared to go beyond the scope of legitimate lobbying and prompted allegations of attempts to exert improper influence in civil, criminal and extradition proceedings.
Leaked emails published by the Le Temps newspaper (Geneva) outline one PR campaign, FTI Consulting, a U.S. investigative and public relations firm, proposed to the Kazakh Ministry of Justice, which involved a plan to fund an ‘independent’ report by an anti-corruption NGO in Switzerland to target Mukhtar Ablyazov. FTI Consulting put forward plans to manipulate search engines through “search engine optimisation” (“SEO”) in favour of the Kazakh government’s narrative:
“the objective will be to use SEO to change the results generated when one searches “Mukhtar Ablyazov” in search engines such as Google from “persecuted political dissident” to “fraudster who stole US$10bn from a bank and abused the protections of Western Europe”.
In June 2013, Swiss parliamentarian Christa Markwalder tabled a number of questions in parliament on relations between Kazakhstan and Switzerland, including raising the case of Viktor Khrapunov. A subsequent media investigation established that the questions destined for the Swiss parliament had actually been drafted by Burson-Marsteller, a PR company, acting on behalf of a pro-Nazarbaev political party, Ak Zhol. A former Swiss ambassador also reportedly lobbied on behalf of the Ministry of Justice of Kazakhstan in the Khrapunov case.
1.2.04. Current work and methodology of working in Kazakhstan
Over the years, the Foundations defended hundreds of politically persecuted from Kazakhstan, wrote 89 reports and 135 statements & opinions, and conducted numerous public events to shed light on serious human rights violations of the authorities of Kazakhstan. However, on behalf of IEI, Bland reduced all work of the Foundation to some baseless allegations planted by the authorities of Kazakhstan through its agents.
Only during 2022, the Foundation, as a part of the Coalition of Kazakhstani human rights NGOs, completed 7 special reports based on data, video and photo materials from eyewitnesses, activists, human rights defenders, peaceful protesters from more than 60 cities and villages in Kazakhstan where protests were held [1], [2], [3], [4], [5], [6], [7]. Co-authors of some of these reports, Raigul Sadyrbayeva and Aiya Sadvakasova, had been arrested under politically motivated criminal cases for their human rights activities during massive repression against peaceful protesters in January 2022. The reports are also based on the data provided by victims of torture and mass shootings, their relatives and lawyers, and on the news published by local and international media outlets. The reports contain lists of political prisoners, victims of torture and mass shootings in January 2022, known as the KANTAR Tragedy, victims of political persecution, including Kazakhstani human rights defenders, and Karakalpakstani civil activists (at risk of extradition to Uzbekistan) – identified by human rights defenders:
- There are 105 political prisoners in Kazakhstan
- At least 17 human rights defenders are being subjected to political persecution
- More than 10,000 people were subjected to arbitrary detention and torture during the January events. There is reason to believe that most of them were tortured or ill-treated after their detention.
The above lists are not exhaustive.
For more than 10 years, the Foundation has been presenting its expert opinion on human rights in Kazakhstan, obtaining first-hand information. The Foundation includes in its reports information and links received from participants of the human rights monitoring Facebook group #IHaveAChoice #ActivistsNotExtremists, administered by the Foundation with support from the Qaharman Human Rights Protection Foundation and the 405 Human Rights Movement. The Foundation collects information from the regions of Kazakhstan in cooperation with human rights defenders from the Human Rights Initiative “Bostandyq Kz,” Human Rights Movement “Veritas,” Human Rights Movement “Femina Virtute,” Human Rights Movement “Article 14,” Human Rights Movement “Elimay” and Public Association “We are Against Torture.” The group #IHaveAChoice #ActivistsNotExtremists, consisting of more than 9,100 participants from different cities in Kazakhstan, was established to collect information and provide assistance to victims for their participation in peaceful protests. Reports of the Foundation were referred to in the conclusions on the human rights situation in Kazakhstan made by the UN [1], [2], [3], the European Parliament, PACE, the U.S. State Department, and human rights organisations [1], [2], [3], [4]. All of these make the Foundation a formidable enemy for the regime in Kazakhstan.
The Foundation has been systematically exposing the surrender of national interests by the Tokayev-Nazarbayev regime to the Kremlin over recent years, exposing Tokayev’s schemes to help Putin circumvent international sanctions for a full-scale military invasion of Ukraine [1], [2], [3].
1.3. Moldova
On behalf of IEI, Bland raised several baseless allegations in connection with the Foundation’s work in Moldova. In particular, Bland repeated Vlad Plahontiuc’s propaganda that the Foundation “was a lobbyist on behalf of a Moldovan businessman Vyacheslav Platon” providing reference to the report which exposed the falsification of the investigation on the most high-profile financial crime in the history of Moldova – the theft of around USD 1 billion from Moldova’s banking system in 2012-2014 by Plahotniuc’s regime.

The study mentioned by Bland is not only based on the available official documents and requests to relevant institutions, authorities, Moldovan and international media investigations, NGO reports, and statements of independent experts, but also includes interviews and consultations with:
- Alexandru Slusari, the vice-president of the Parliament and former President of the Parliamentary Commission of Inquiry, to elucidate all the circumstances of the robbery of the banking system of Moldova and investigate bank fraud (later referred to as “Slusari Commission”);
- Veaceslav Negruta, an expert on the topic of the theft of the billion, having worked at Transparency International – Moldova, where he extensively covered this topic. He held the position of Economic Advisor to President Maia Sandu at the time of publishing this report;
- Denis Cenusa, a researcher at Institut für Politikwissenschaft, Justus-Liebig-Universität in Germany and an associated expert at Think-Tank Expert-Group and “Energy Security” Program Director there;
- Representatives of local NGOs – Centre for Policy and Reforms (CPR), which provided us with useful guidelines for formulating well-structured requests for information, tailored by their experts, on access to information and Transparency International – Moldova.
- Local investigative media – Ziarul de Gardă.
Using manipulative language, Bland also alleges that the Foundation has been involved in some money laundry and criminal activists in connection to the Foundation’s work in Moldova. As a basis for its allegations, Bland yet again used different shields, this time – the IEI to repeat Plahotniuc’s propaganda about “a Moldovan parliamentary report” and a defamatory article in Sunday Times that was allegedly written on the basis of that report. Bland used the name of the IEI to go even further, alleging that the Foundation was paid from the stolen USD 1 billion “for lobbying services in the European Parliament and at the Parliamentary Assembly of the Council of Europe, portraying Platon as a victim of “political oppression”.
In fact, the Foundation has been determined to support Moldova on its path towards democracy and European values. Since 2016, the Foundation has supported the current pro-EU president Maia Sandu and the pro-democratic opposition in their quest to reclaim the state from its corrupt oligarch ruler Vladimir Plahotniuc. The Foundation worked closely with the Moldovan civil society, mainly on the issues of corruption, abuse of international cooperation mechanisms and the problem of politically motivated persecution, and independence of the judiciary. The Foundation cooperated with MEPs and EU high-level officials, as well as local CSOs and opposition leaders, such as Andrei Năstase & Maia Sandu, then pro-EU opposition party leaders. Both of them spoke in the European Parliament upon the Foundation’s invitation. Later, Andrei Năstase became a deputy Prime Minister, while Maia Sandu – the Prime Minister. Currently, she serves as President of the country.
We believe that the Foundation’s work led directly to introducing a functioning democracy in Moldova, as well as opening the market to foreign investors and ensuring the safety of their interests. Since 2016, the Foundation has prepared a number of briefings for EU institutions, including the EP, EC & EEAS, concerning the political developments, shortcomings in the justice system, and the backsliding of the anti-corruption reforms in Moldova – thus becoming the EC’s primary source of information on the matter.
The Foundation submitted 11 reports and 17 statements and opinions on the situation in Moldova to the EU, UN, Council of Europe, and OSCE. The Foundation is especially proud for co-authoring a study commissioned by a political group of the European Parliament on the investigation into Moldova’s “theft of the century,” exploring the most high-profile financial crime in Moldova’s history by Plahotniuc regime, which took place between 2012 and 2014, and examines the context as well as the progress in the investigation. Thus, it is particularly ironic for us that Bland abused the IEI initiative to unfoundedly attack the Foundation for participation in money laundering and was paid by a perpetrator of the theft.
During the period of Moldovan oligarch Vladimir Plahotniuc’s total control of the state institutions, the Foundation successfully advocated the freezing of the 100-million-euro EU macro-financial assistance to Moldova, linking it with the strict conditions on the fight against corruption and money laundering, the de-politicisation of public administration, an independent judiciary, the freedom of the media and a broad political consensus on an electoral system change.
The Foundation has also carried out advocacy campaigns calling for sanctions against specific human rights perpetrators from Moldova and Kazakhstan, including former Moldovan de facto ruler Vladimir Plahotniuc. The Foundation’s extensive advocacy for reforming Moldova into a real democracy and setting it on a path towards the EU has therefore made us the prime target for its corrupt former ruler Vladimir Plahotniuc.
1.3.01. Confidential parliamentary report to discredit the pro-European then-opposition in Moldova
The so-called Moldovan parliamentary report that Bland refers to in its allegations against the Foundation was prepared on the direct orders of oligarch Vladimir Plahotniuc as a tool to discredit the pro-European then-opposition [1], [2]. Given the IEI’s ambition to expose corrupt regimes and their negative consequences for the EU, ironically, it finds itself involved in spreading propaganda for the most corrupt regime. On 4 October 2018, members of the Parliament of then-ruling Pahotniuc’s Democratic Party (PDM) established a parliamentary commission specifically “to investigate Open Dialogue Foundation’s and ODF President Lyudmyla Kozlovska’s interference in the domestic affairs of the Republic of Moldova as well as its funding of opposition parties.” The report prepared by the ruling PDM party accused the Foundation, Lyudmyla Kozlovska, and key members of the opposition of various serious crimes, including high treason, espionage, money laundering, and sabotage. Without any evidence, the report claimed that both pro-European opposition parties were financed by the Foundation (!) with sums of hundreds of millions of dollars (!), which ODF supposedly channelled from the Kremlin.
The committee itself was boycotted by the opposition and lambasted as a “farce” by the opposition leaders. Independent Moldovan news outlets considered the report nothing more than a tool to attack the opposition parties [1], [2], [3], [4].
Political persecution of the Foundation and Lyudmyla Kozlovska received widespread international criticism, which was expressed, in particular, by President of the ALDE in the European Parliament Guy Verhofstadt, U.S. Deputy Assistant Secretary of State George Kent, and twenty-six PACE members.
Interestingly enough, the non-public, confidential, politicised parliamentary report was quickly leaked to two individuals, Carlos Alba and Jordan Ryan, who just like Bland wrote a defamatory article against the Foundation on its basis. The article was published in the Scottish edition of the Sunday Times newspaper under various titles as a black-PR piece. Those supposed journalists, who turned out to be a PR professional and a pro-Brexit campaigner, never contacted the Foundation or any person attacked in the report to verify the allegations. IEI has never checked the basis of the Sunday Times article and listed its allegations as proven.
Meanwhile, all the charges contained in the report there were dropped by the country’s Prosecutor General as politically motivated [1], [2] after the U.S. imposed personal sanctions on Vladimir Plahotniuc and his family members, and the power in the country was transferred to the legitimately elected current pro-European government. In October 2022, the super-oligarch was sanctioned again by the U.S. Government as an “instrument of Russia’s global influence campaign” in Moldova.
It is worth noting that Polish media revealed that the Polish authorities shamelessly worked together with their Moldovan counterparts controlled by Plahotniuc to discredit the Foundation and its managers. At the same time, the Polish authorities continue to use the same old Moldovan false allegations, reprinted by Sunday Times as advertising, to attack the Foundation and even prosecute Bartosz Kramek, one of the Foundation’s leaders.
1.3.02. Politically motivated persecution of Vyacheslav Platon
What Bland, on behalf of IEI, calls the Foundation’s “lobbying on behalf of Vyacheslav Platon” was, in fact, a part of the Foundation’s campaign for personal sanctions against Vladimir Plahotniuc and an EU macro-financial aid freeze to Moldova for human rights violations. The Foundation, together with Maia Sandu and other Moldovan civil activists and members of the opposition, advocated for dozens of victims of political persecution and political prisoners in Moldova. The Foundation made a report on every political prisoner in Moldova at that time [1], [2].
Vyacheslav Platon is a whistle-blower, one of a dozen examples of politically persecuted by Plahotniuc’s regime, after his will to give evidence against the influential oligarch Vladimir Plahotniuc. In Platon’s case, the Foundation paid particular attention to how dangerously Moldovan corruption was spreading across the border to Ukraine. Vladimir Plahotniuc was friends with then-Ukrainian president Petro Poroshenko and did not want Platon to testify against Plahotniuc. Due to Plahotniuc’s influence over Ukrainian law enforcement bodies, Platon was stripped of his Ukrainian citizenship and extradited to Moldova without a court decision. After Maia Sandu became a democratically elected president, the General Prosecutor reconsider Platon’s case, charges against him were dropped, and Vyacheslav Platon, just as all other political prisoners, was released from prison. Nevertheless, IEI has not made any attempts to conduct any pre-publication verification with the Foundation in connection with its work in Moldova.
1.4. Abuse of International Cooperation Mechanism: political abuse of INTERPOL and Extradition Requests
In the article of IEI, Bland once again accused the Foundation of “lobbying for” Nail Malyutin, a whistle-blower and a witness that wanted to provide testimony against Gazprom’s interests and Russia’s former president and close aide to Putin, Dmitriy Medvedev. Malyutin was aware of the illicit activity of Medvediev’s circle, refused to be part of it, and, for this reason, became a target. One of the examples of such false claims Bland wrote in 2019 under the shield of the website https://www.indrastra.com/.

Malyutin’s case was considered to be politically motivated and was monitored by the Foundation, together with over 50 other cases of abused INTERPOL notices and extradition requests. Some of those cases were included in the joint report of a coalition of human rights organisations, namely, the Foundation, the Italian Federation for Human Rights, the Arrested Lawyers Initiative, the Human Rights Defenders e.V. (HRD), and the Kharkiv Institute for Social Research, – “They’ve Come For You: Misuse of Extradition Procedures and Interstate Legal Assistance.”
It has been well documented that Russia systemically breached articles 3, 5, 6, and 13 of the European Convention on Human Rights. Lyudmyla Kozlovska, president of the Foundation, as well as Lyudmila Alexeyeva, chair of the Moscow Helsinki Group, Lev Ponomarev, executive director of the All-Russian Movement “For Human Rights,” Zoya Svetova, Russian journalist and human rights activist, and Svetlana Gannushkina, chairman of the Civic Assistance Committee, urged the Ministry of Justice of Austria to prevent the extradition of Nail Malyutin to Russia.
What is particularly striking is that Bland used publications and statements originating by the Russian state in his IEI article [1], [2] as the basis for his allegations against the Foundation concerning a case in which high-ranking Russian officials had been exposed. Bland also remained silent on the international human rights campaign the Foundation conducted in defence of the Kremlin hostages and the campaign for personal sanctions against Putin. At the same time, the IEI itself didn’t question why Bland completely ignored the expert opinion of respected human rights defenders like Memorial and Moscow Helsinki Group, who had exactly the same rationale that the Foundation had to protest against Nail Malyutin’s extradition to Russia.
1.5. Poland
Bland, on behalf of IEI, bluntly repeats Polish propaganda that was debunked in numerous court decisions without revealing any reasons why the Foundation and its leadership, who are Polish human rights defenders, are so viciously targeted by the current authorities of Poland. That demonstrates a complete lack of professional integrity.
Since the mass protests in defence of the rule of law and constitution in Poland in July 2017, the focus of the Foundation has been on preserving Poland’s independent judiciary and prosecution service. The Foundation has launched an international advocacy campaign to protect independent judges, prosecutors and lawyers, as well as civic movements and activists – especially those persecuted by the Polish authorities. The Foundation also works to draw attention to hate crimes in Poland. For instance, the Foundation has organised:
- a series of high-level meetings for persecuted judges and prosecutors, including with European Commission Vice-President Věra Jourová and Justice Commissioner Didier Reynders, Equality Commissioner Helena Dalli, as well as with numerous MEPs that led, most notably, to three hearings for the Civil Liberties committee;
- several hearings in the European Parliament, on every 6 months [1], [2], [3], [4], [5];
- the Foundation reports and data are included in the EC’s annual Rule of Law Report, EU Justice Scoreboard, PACE resolutions and UN reports;
- meetings on Capitol Hill, at the U.S. State Department, and with U.S. NGOs such as the Brookings Institution, German Marshall Fund, and Atlantic Council;
- hearings on the declining situation in Poland in the Parliamentary Assembly of the Council of Europe and at the OSCE.
The Foundation has submitted several appeals to the European Commission on the declining rule of law situation in Poland, signed by the world’s leading scholars and judicial associations, as well as an open letter to the Polish Supreme Court, signed by leading European legal & bar associations. It is worth mentioning that since July 2017, the authoritarian regimes in Kazakhstan and Moldova (under Plahotniuc) have joined forces with Poland’s hybrid regime to launch a coordinated attack against the Foundation.
This high-level human rights advocacy work has turned us into an enemy of the rule-of-law violating authorities in Poland, who use every instrument at their disposal to silence us.
1.5.01. Politically motivated persecution of the Foundation in Poland (chronological order)
The Foundation’s position against violations of the rule of law by the ruling coalition in Poland was first expressed in 2017 by Bartosz Kramek, chair of the Foundation Supervisory Board. Immediately after that, the Foundation’s leadership and the organisation became the target of propaganda, disinformation campaign, and legal and extra-legal actions by the Law and Justice (PiS) government. For example:
- In 2018, the president of the Foundation, Lyudmyla Kozlovska, was entered into the Schengen Information System (SIS) by the head of Poland’s Internal Security Agency (ABW). Following the politically motivated abuse of SIS II by Poland in Kozlovska’s case, the PACE issued a resolution, introducing several recommendations to provide safeguards against such unlawful practices. Polish courts, including the Supreme Administrative Court, issued four verdicts, ruling that Kozlovska’s expulsion in August 2018 from the EU and Poland was arbitrary and unjustified because the secret and public materials collected by the ABW “do not allow the conclusion that Kozlovska poses a threat to state security.” [1], [2]
- Bartosz Kramek regularly participated in various forms of protest against the Polish authorities and had filed around 20 lawsuits on behalf of the Foundation against PiS politicians and propaganda outlets [1], [2]. As a result, in July 2021, the Polish authorities arrested Bartosz Kramek for 3 weeks on politically motivated charges. In October 2021, the District Court in Lublin lifted nearly all of the preventive measures imposed by the state prosecution (at the personal request of Justice Minister Zbigniew Ziobro) in the pending case of Bartosz Kramek as “unreasonable and disproportionate”. The case is widely seen as politically motivated in the independent press and by dozens of public figures, including two Nobel Peace Prize laureates and 28 human rights watchdogs and NGOs.
- In September 2021, Martin Mycielski, the Vice-President and Director of Public Affairs of the Foundation, was called for questioning by the police in Brussels, Belgium (where he resides), following a politically motivated European Investigation Order (EIO) issued against him by the Economic Crime Department of the Regional Prosecutor’s Office in Warsaw. The EIO was issued as part of an investigation initiated following a private complaint by PiS Chairman Jarosław Kaczyński. In a 2-page complaint, Kaczyński claimed that his morality was questioned, “public trust in him was undermined,” and “electoral results of him and his party were threatened,” all by a tweet published in January 2021 by the satirical SokzBuraka (4 months before Mycielski became its editor-in-chief). The tweet asked why Chairman Kaczyński had been vaccinated against COVID before his turn. Despite it being a private complaint under Art. 212 kk (defamation), which the court would under normal circumstances handle without any involvement of the prosecution service, Warsaw regional prosecutor Konrad Gołębiowski initiated an ex officio investigation and decided to use European criminal cooperation mechanisms to question the two potential culprits mentioned by Kaczyński by name in his complaint, one of whom was Mycielski.
The harassment against the Foundation has been well documented by independent media [1], [2], NGOs submission to the UN, the position of the UN Special Rapporteurs, and described in the Foundation’s 2019 report “Law and Justice’s campaign against the Open Dialogue Foundation.” Since the publication of the report, numerous court decisions have confirmed that the authorities’ accusations and actions against ODF were unfounded. More details of the Foundation’s work in Poland can be found on its website.
1.5.02. Disinformation campaign against the Foundation in Poland
In August 2022, the court in Poland ruled in favour of the Foundation in its decision in a defamation case against the secret services deputy chief Maciej Wąsik. The court found no evidence of the Foundation’s alleged links to Russia or alleged involvement in money laundering practices. The court ordered the secret services deputy chief to publish an apology and pay damages in favour of the Foundation, Bartosz Kramek, and Lyudmyla Kozlovska for his defamatory, false public claims that the Foundation had ties with Russia and engaged in money laundering practices.
Crucially, Polish special services based their accusations against the Foundation on Moldovan and Kazakh disinformation [1], [2]. Representatives of the Moldovan and Polish foreign ministries discussed the Foundation and Kozlovska’s case during official meetings at international platforms like the OSCE. With Plahotniuc out of power, the coordinated attack continues by the Kazakh and Polish regimes.
Without checking its sources in good faith, Bland, on behalf of IEI, makes the following false claims, which have been debunked many times: “Polish Government sources believe Kozlovska may have been recruited by the Federal Security Services of Russia (FSB) through her Crimea-based brother, Peter Kozlovsky, whose former-company MAYAK Sevastopol supplies the Russian Navy. A Russian auditing website of business entities shows that Lyudmila’s sister, Elena Miroshnikova, and her mother, Sidonia Kozlovska, own 50% each of the shares in MAYAK Sevastopol as of September 2022.”
These false claims were propagated most notably by the state-owned Polish Radio in 2018. However, the original article was removed by a court order in favour of the Foundation in a libel case against state media Telewizja Polska S.A., a well-known propaganda outlet (together with TVP) of the ruling PiS party. The claim of links with the FSB never had any grounds (they were also propagated by the “Stop Corruption” (antikor.com.ua) website – more on it below). At the same time, the alleged ownership of “Mayak” was based on untrustworthy Russian sources and never proven. These false claims that propaganda outlets repeated have been debunked by the Foundation and by independent media outlets on multiple occasions [1], [2], [3], [4]. As stated above, in its August 2022 decision on the defamation case against the Polish secret services deputy chief, the court in Poland found no evidence of the Foundation’s alleged links to Russia or alleged involvement in money laundering practices.
On behalf of IEI, Bland repeatedly makes an inaccurate statement omitting material developments: “In July 2018, the Polish Government flagged Lyudmyla Kozlovska in the Schengen Information System (SIS) as a danger to national security. The ban was overturned by a provincial court in 2019.”
As stated above, not one, but four Polish courts, including the Supreme Administrative Court, issued verdicts, ruling that Kozlovska’s expulsion in August 2018 from the EU and Poland was arbitrary and unjustified because the secret and public materials collected by the ABW “do not allow the conclusion that Kozlovska poses a threat to state security.” [1], [2]
In addition to the court decisions, five Western European states (Germany, Belgium, France, Switzerland, and the UK) recognised in the case of Kozlovska the abuse of SIS as politically motivated and granted her entry and let her speak about her case in the Bundestag, European Parliament, Council of Europe, UN and House of Commons, respectively. It was also deemed unlawful by legal scholars [1], [2] and politically motivated by experts in prominent media outlets like the Washington Post and the Financial Times. Finally, it was Belgium that granted Kozlovska a stay permit forcing Poland to remove the SIS entry. Dozens of public figures and NGOs from around Europe demanded her return to the EU, as well as journalists, politicians (from both ruling and opposition parties), and NGOs from Ukraine, including the 2022 Nobel Peace Prize laureate and the Foundation’s frequent collaborator Oleksandra Matviychuk.
1.6. Foundation: Founder, Goals, Human Rights Advocacy. Debunking of specific false claims and accusations of IEI
Bland, on behalf of IEI, made intentionally convoluted inaccurate statements against the Foundation: “According to its website, the “Open Dialogue Foundation (ODF) was established in Poland in 2009 on the initiative of Ukrainian student and civic activist, Lyudmyla Kozlovska.” However, other sources – including ODF financial statements – show the Foundation was founded in Lublin by Paweł Świderski and Ivan Szerstiuk, who ran consultancy companies in Kyiv, Kharkiv, and Kozlovska’s hometown of Sevastopol. Accused of supporting fugitive billionaire Mukhtar Ablyazov’s party in elections in which he was supposed to be an independent observer, Szerstiuk was deported from Kazakhstan and reportedly sentenced to fifteen years in Ukraine for fraud and ordering a murder. Other sources claim that Szerstiuk previously led the Dialogue for Development Foundation in Lublin, where Lyudmyla Kozlovska was a co-worker.”
First, Bland’s mysterious sources must be disclosed: these false statements are based on a series of black PR articles in the Polish pro-government media Polskie Radio. and Polish weekly Sieci, as well as on blog posts of James Wilson. Wilson is a staff writer for brussels-express.eu, who has never been known as an expert on Poland or Kazakhstan, yet in 2018–2019 he became conspicuously active, advancing in his posts joint Polish and Kazakh propaganda against the Foundation and the Kazakh opposition in exile.

Following the beginning of the political confrontation between the Foundation and PiS, the Foundation had to file more than 20 libel/defamation lawsuits against PiS politicians and propaganda outlets, including Polskie Radio S.A. and Polish Sieci weekly magazine, for their false claims against the Foundation and its leadership [1], [2]. On 13 March 2020, to protect the Foundation’s personal rights, Lyudmyla Kozlovska and Bartosz Kramek, the District Court in Warsaw ordered the state-owned broadcaster Polskie Radio S.A. to put a disclaimer on its defamatory articles that they are subject to the court proceedings. Bland could not see such disclaimers, should he be diligent and in good faith.
The Foundation was set up on the initiative of Lyudmyla Kozlovska with technical assistance in registering the organisation from two then-friends and fellow activists, Pavel Swiderski and Ivan Sherstyuk. It was established in December 2009 and registered in the National Court Register in Poland in 2010. The establishment of the Foundation in Poland was a logical continuation of Kozlovska’s human rights and civic activities as a student. Kozlovska was involved in the activities of the Ukrainian Foundation for Regional Initiatives and “Чорна «Пора!»” in Sevastopol, Ukraine. In 2004, Kozlovska was a young active participant in the Orange Revolution in Kyiv, Ukraine. Kozlovska was a leader of the campaign to withdraw Russia’s Black Sea Fleet from Sevastopol in 2005-2006. After receiving an invitation for the Polish Foreign Ministry scholarship programme, in 2008 Kozlovska commenced her studies at the European College of Polish and Ukrainian Universities, Maria Curie-Sklodowska University (Lublin, Poland), PhD programme Political History of Eastern Europe and Central Asia.
Since 2011, Ivan Sherstyuk has not been associated with the Foundation or its activities in any way; neither the Management Board nor the Foundation team has maintained any contact with him. This is public information, and claims of the two being somehow behind the Foundation were debunked back in 2016. The Foundation is not responsible for the private actions and fate of its founders/employees after they have terminated their association with the Foundation. According to the available information, Sherstyuk has never met and never cooperated with Ablyazov.
From 2009 to 2017, Poland’s transition to democracy, its protection of human rights and the rule of law, and the Solidarity Movement were an inspiration and shining example for the Foundation. From 2010 until July 2017, politicians from all political parties in Poland were actively involved in defending hundreds of politically persecuted persons and political prisoners in Kazakhstan, Russia, Moldova, and Ukraine.
As discussed above, since July 2017, in Poland the Foundation has been involved in defending the rule of law and documenting for international organisations [1], [2], European parliamentarians, and the European Commission individual cases of political persecution of judges, prosecutors, activists, NGOs, entrepreneurs, LGBT+ and women’s organisations. Since then, PiS politicians have broken off cooperation with the Foundation and launched systematic attacks on it and its leadership, based on false accusations and disinformation created by the regimes of Plahotniuc in Moldova and Nazarbayev in Kazakhstan.
2. Questionable contributors within IEI team and attacks on pro-human rights EU politicians
The Institute for European Integrity’s website lists, among its contributing analysts, Stephen M. Bland. Bland is a frequent contributor to Gary Cartwright, a former UKIP employee, far-right racist, and Holocaust denier running a network of black PR websites, often posing as EU news outlets under names such as “EU Today” or “EU Reporter” or brussels-express.eu. Cartwright was also possibly linked to the now-defunct “EU Anti-Corruption” group, which had spent substantial amounts of money to defame the Foundation via sponsored social media campaigns in 2018.
Cartwright and Bland have been working together in the former’s outlets, with Bland writing defamatory articles about the Foundation for Cartwright. The two organised press briefings disguised as conferences just to attack the Foundation [1], [2]. Bland was also the editor of Cartwright’s book entitled “Wanted Man”, which is devoted to smearing Ablyazov and the Foundation. In fact, the “book” is a compilation of defamatory articles, some of which were made by Bland. Cartwright organised an event in the European Parliament focused on smearing the Foundation. A host of the event, a Member of the European Parliament from Croatia, Mr. Tomislav Sokol, had to denounce the event. Cartwright, a collaborator of Bland, claimed the existence of an OSCE HDIM meeting and Written Declaration devoted to the Foundation, with no proof of either. Cartwright and IEI’s Bland organised an event in the Brussels Press Club to smear specifically Mukhtar Ablyazov and the Foundation.
In his book Kleptopia, Financial Times journalist Tom Burgis described the scale of politically motivated attacks that the regime in Kazakhstan is capable of. Kazakhstani regime systematically attacks the Foundation for exposure of political persecution, political killings, and mass torture, as well as protecting the rights of the leading political opponent of the regime and the most influential political opposition figure in Kazakhstan – Mukhtar Ablyazov. The way Bland writes his hack pieces based purely on the regime’s disinformation fits the modus operandi of “hired guns” of the regime in Kazakhstan, disguised as journalists.
James Wilson, whose articles are used as “sources” by the IEI, is another embarrassing example of a journalist that produces a variation, a rewriting of the joint Polish, Moldovan, and Kazakh propaganda articles against the Foundation and the Kazakh opposition in exile [1], [2], [3]. Therefore, it seems highly likely that the IEI article was also produced by Bland, which would be consistent with his history of smearing the Foundation and opponents of the authoritarian regime in Kazakhstan.
In the article “Interview with Stephen Bland on the Open Dialogue Foundation” on brussels-express.eu, Wilson has not even tried to hide the clientelist nature of his publication: repeating the smear narrative of the Kazakh regime against the Foundation, publishing a large photo and praising epithets about Tokayev’s “confident election victory” in 2019, and quoting Bland’s ability to “predict Tokayev’s successful election two weeks before the election”.

Worth to mention that Wilson, as a staff writer for brussels-express.eu, mainly focused on Kazakh propaganda against the ODF and the Kazakh opposition in exile, including Bland’s articles.
Similarly to Cartwright and Wilson previously, in the defamatory publication for IEI, Bland has attacked European politicians, who, relying on the reports, information, personal meetings and testimonies organised/provided by the Foundation, have advocated for hundreds of political prisoners and politically persecuted persons and saved lives of hundreds in Kazakhstan, Russia, Moldova (during the Plahotniuc regime) and Ukraine during the Yanukovych regime.
Bland, in his article for IEI, made his baseless insulting attack against MEP Róża Thun, former MEP Julie Ward, former Polish MP Marcin Święcicki, and former Italian MP Roberto Rampi, who over the years have been consistently raising issues of human rights abuses around the world, including, without limitation, Kazakhstan, Russia, Moldova, and Poland.
As stated above, IEI has not attempted to conduct any pre-publication verification with the Foundation in connection with its work in Kazakhstan. It is also likely that IEI internally failed to verify the sources of Bland’s articles which attacked EU politicians mentioned above. The links in the article used allegedly as sources for the information against EU politicians are not active anymore, as in the case of former Polish MP Marcin Święcicki and Antonio Stango, President of the Italian Federation for Human Rights.

In the cases of Roberto Rampi and Julie Ward, Bland’s allegations just repeat Kazakhstani propaganda that James Wilson advanced to attack EU politicians who had helped civil society to expose massive fraud and violations by Tokayev’s and Nazarbayev’s regime during elections:

In some cases, Bland just refers to himself as a source:

Bland failed to provide any link to the alleged «report issued by the EPP Group in the European Parliament stated that MEP Róża Thun is “suspected to be under the influence of Mukhtar Ablyazov and his associates through her affiliation with the Open Dialogue Foundation”» simply because it does not exist.
The IEI claims that its “team includes sector-leading investigators, researchers and analysts, data scientists, NGO veterans, security specialists, administrators, and subject matter experts.” However, even a rudimentary analysis shows that Bland, as the author for IEI, is spreading deliberately false information in his article for IEI.
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For more information contact:
Lyudmyla Kozlovska, [email protected]
Martin Mycielski, [email protected]
Annex 1: Debunking od Lyudmyla Kozlovska’s “Russian passport”
