- 12 (c) failing to investigate, prosecute, or extradite perpetrators of the financing of
terrorism found within its territory, in violation of Articles 9, 10, 11, and 18;
(d) failing to provide Ukraine with the greatest measure of assistance in connection
with criminal investigations of the financing of terrorism, in violation of
Articles 12 and 18; and
(e) failing to take all practicable measures to prevent and counter acts of financing of
terrorism committed by Russian public and private actors, in violation of
Article 18.
135. Ukraine respectfully requests the Court to adjudge and declare that the
Russian Federation bears international responsibility, by virtue of its sponsorship of
terrorism and failure to prevent the financing of terrorism under the Convention, for
the acts of terrorism committed by its proxies in Ukraine, including:
(a) the shoot-down of Malaysia Airlines Flight MH17;
(b) the shelling of civilians, including in Volnovakha, Mariupol, and Kramatorsk; and
(c) the bombing of civilians, including in Kharkiv.
136. Ukraine respectfully requests the Court to order the Russian Federation to
comply with its obligations under the Terrorism Financing Convention, including that
the Russian Federation:
(a) immediately and unconditionally cease and desist from all support, including the
provision of money, weapons, and training, to illegal armed groups that engage in
acts of terrorism in Ukraine, including the DPR, the LPR, the Kharkiv Partisans,
and associated groups and individuals;
(b) immediately make all efforts to ensure that all weaponry provided to such armed
groups is withdrawn from Ukraine;
(c) immediately exercise appropriate control over its border to prevent further acts of
financing of terrorism, including the supply of weapons, from the territory of the
Russian Federation to the territory of Ukraine;
(d) immediately stop the movement of money, weapons, and all other assets from the
territory of the Russian Federation and occupied Crimea to illegal armed groups
that engage in acts of terrorism in Ukraine, including the DPR, the LPR, the
Kharkiv Partisans, and associated groups and individuals, including by freezing all
bank accounts used to support such groups;
(e) immediately prevent all Russian officials from financing terrorism in Ukraine,
including Sergei Shoigu, Minister of Defence of the Russian Federation;
Vladimir Zhirinovsky, Vice-Chairman of the State Duma; Sergei Mironov,
member of the State Duma; and Gennadiy Zyuganov, member of the State Duma,
and initiate prosecution against these and other actors responsible for financing
terrorism;