January 17, 2025
The Honorable Nida Grunskienė
Prosecutor General of the Republic of Lithuania
The Honorable Vladislav Kondratovič
Minister of Internal Affairs of the Republic of Lithuania
Cc:
Gintautas Paluckas, Prime Minister of the Republic of Lithuania
Saulius Skvernelis, Speaker of the Seimas of the Republic of Lithuania
Members of the Seimas of the Republic of Lithuania
Kaja Kallas, Vice-President of the European Commission
Marta Kos, European Commissioner for Enlargement
Ministers of Foreign Affairs of the European Union
Ministers of Internal Affairs of the European Union
International Civil Aviation Organization (ICAO)
Interpol General Secretariat
Subject: Request for Investigation Regarding the Issuance of "New Belarusian Passports" and Related Activities
Dear Prosecutor General Grunskienė and Minister Kondratovič,
We would like to bring to your attention that the issuance of the so-called "New Belarusian Passports," printed by the Belarus Passport Center, VšĮ (registration code: 306628310, Lithuania), is scheduled for January 26, 2025. It has been reported that this initiative is commissioned by the Office of Sviatlana Tsikhanouskaya, VšĮ (registration code: 305683122, Lithuania), and the United Transitional Cabinet (NIP: 7011139691, Poland).
Given the significant public concern surrounding this matter and the potential security risks it poses to citizens, we respectfully request that a thorough investigation be conducted. The purpose of this request is to ensure that all activities are fully compliant with the legislation of the Republic of Lithuania and the European Union (EU).
Earlier, Sviatlana Tsikhanouskaya, a Belarusian citizen residing in Lithuania, and her representatives announced plans for the design and production of Belarusian passports for citizens seeking to obtain a "New Belarus Passport." According to information provided by the organization, applicants must submit their old Belarusian passports, provide documentation confirming their legal stay in the EU, pay a €90 fee, and submit biometric data. Sviatlana Tsikhanouskaya "expressed gratitude to the Lithuanian government for its support and consultations," while her advisor Franak Viačorka stated that "the New Belarus Passport project has been coordinated with the European Commission and complies with ICAO standards."[1][2]
The issuance of such documents involves the collection and processing of sensitive personal data, thereby falling under the jurisdiction of the General Data Protection Regulation (GDPR). Additionally, the process is governed by EU Directive 2019/1157/EC, which establishes security standards for identity documents, including the use of biometric data and identity verification methods to prevent fraud. Moreover, it implicates EU Directive 2004/82/EC (preventing illegal immigration), EU Directive 2005/60/EC (combating money laundering and terrorism financing), and EU Directive 2011/95/EU (refugee protection).
We urge the General Prosecutor's Office to examine whether such actions comply with Article 300 of the Criminal Code of the Republic of Lithuania, which addresses the creation, forgery, and use of counterfeit documents.
Furthermore, it is important to highlight that employees of Sviatlana Tsikhanouskaya's office have previously been accused of transferring personal data from the "Black Book of Belarus" channel to the security services of the Lukashenko regime, resulting in numerous arrests. Similarly, the "Plan Peramoga" initiative, endorsed by Ms. Tsikhanouskaya, has reportedly led to the detention and imprisonment of Belarusian citizens, with some receiving sentences of up to 24 years.
In light of these concerns, we respectfully request answers to the following questions:
- What are the legal grounds for issuing documents referred to as "New Belarus Passports" by the Lithuania-based organization? Would it be lawful for any entity inside or outside the EU to collect personal data for the production of a hypothetical "New Lithuanian Passport"?
- Is the claimed "Belarus Passport" manufactured in Lithuania recognized as an official identity document in compliance with EU Directive 2019/1157/EC?
- Can an individual presenting this document be held criminally liable for providing a forged document?
- For what purposes is the personal data of Belarusian citizens being collected, including documentation confirming their legal stay in the EU and biometric data? Does the collection, storage, and protection of such data comply with GDPR requirements and the relevant safeguards for citizens, including refugees?
- Who guarantees that the collected data will not be transferred to the security services of the Lukashenko or Putin regimes?
Given the significance of this issue for the well-being of Belarusian citizens and the necessity of protecting them from arrest, detention, and imprisonment, we respectfully request:
- A public explanation of the activities of the Lithuania-based organization;
- Transparency in the investigation's findings;
- Information to be shared with Belarusian citizens and the international community regarding the outcome of the investigation.
We trust that the Lithuanian authorities will prioritize this matter to ensure the protection of Belarusian citizens residing in the EU and uphold the principles of justice and transparency.
Sincerely,
Belarus Democratic Forum