To His Excellency Gitanas Nausėda
President of the Republic of Lithuania
Dear Mr. President,
We hereby inform you that the Belarus Democratic Forum has submitted an application to the Prosecutor General’s Office of the Republic of Lithuania reporting indications of potential criminal activity falling within the jurisdiction of the Republic of Lithuania and the European Union.
The application concerns the circumstances surrounding the receipt of approximately EUR 15,000 in cash by Ms. Sviatlana G. Tsikhanouskaya, a citizen of the Republic of Belarus, from a senior officer of the Belarusian security services. According to available information, these funds were not declared in accordance with the procedures established by law, and the fact of their receipt was concealed for a long time, being acknowledged only after a video and audio recording of the money transfer became publicly available.
Particular concern arises from the fact that the funds were transferred by a high-ranking representative of the security apparatus of an authoritarian regime whose activities have been unequivocally condemned by the European Union, the United Nations, the OSCE, and other international organizations due to gross human rights violations and political repression.
In our submission, we request that the competent authorities examine the circumstances regarding the origin of these funds, as well as the purposes of their transfer, as provided for by the legislation of the Republic of Lithuania and the European Union concerning the laundering of proceeds derived from criminal activity, corruption, and other associated offenses.
We are convinced that the pursuit of democratic values is impossible without uniform standards of legality applied to everyone without exception. The principle of the rule of law dictates that any circumstances containing indications of potential offenses must receive an objective legal assessment, irrespective of political views, social status, or the affiliation of the individuals concerned with any political or civil society structures.
We believe that the absence of an appropriate legal assessment of such circumstances could create a dangerous precedent, whereby the territory of the European Union might be used by representatives of repressive regimes, corrupt officials, and organized criminal groups to import and legalize funds of suspicious or unlawful origin, as well as to circumvent sanctions and anti-corruption frameworks.
In this regard, we deem it necessary to inform you of the submission made and express our hope that the circumstances set forth therein will be reviewed objectively, impartially, and in strict accordance with the law.
This matter concerns not only a specific case, but also adherence to the principle of equality before the law, regardless of office, political status, or public prominence. The consistent application of the law is a necessary condition for public trust in state and European institutions, and an essential safeguard for the authority of the Republic of Lithuania as a state based on the rule of law.
Respectfully,
Belarus Democratic Forum
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Summary of the application to law enforcement authorities
Nida Grunskienė
Prosecutor General of the Republic of Lithuania
Copy to:
Financial Crime Investigation Service (FNTT)
State Border Guard Service (VSAT)
Customs Department under the Ministry of Finance of the Republic of Lithuania
Subject: Report concerning the possible transfer of funds of criminal origin, their importation into the European Union, and possible laundering in the Republic of Lithuania
Dear Ms. Prosecutor General,
The Belarus Democratic Forum hereby reports circumstances that may indicate the existence of criminal activity falling within the jurisdiction of the Republic of Lithuania and the European Union. Guided by the principles of the rule of law, transparency in public and political activities, and equality of all persons before the law regardless of office, social status, or political views, we respectfully request that the facts set forth below be examined in accordance with the legislation of the Republic of Lithuania and the European Union.
It has recently become known that on 10 August 2020, in the territory of the Republic of Belarus, Ms. Sviatlana G. Tsikhanouskaya, a citizen of the Republic of Belarus, received approximately EUR 15,000 in cash from Hennadiy Pavliuchenko, Head of the Operational and Analytical Center (OAC) under the President of the Republic of Belarus.
The OAC is a security service that plays a key role within the system of political repression in Belarus. Its functions include monitoring internet communications and social media, identifying and persecuting political opponents, conducting surveillance of diplomatic personnel, and verifying the personal loyalty of officers of the Ministry of Internal Affairs, the KGB, and other security agencies to Alexander Lukashenko.
In August 2025, following the publication of the relevant materials in the public domain, Ms. Tsikhanouskaya was compelled to acknowledge that she had received the funds.
It has also been established that the specified funds were moved across an external section of the European Union border by crossing the "Kotlovka" border checkpoint (the adjacent Lithuanian border checkpoint is "Lavoriškės" / "Medininkai") at approximately 3:30 AM on August 11, 2020. There are grounds to believe that the individual importing the substantial amount of cash into the European Union failed to declare it in accordance with the requirements of applicable law. There are also grounds to believe that the funds were subsequently used within the territory of the European Union.
Accordingly, the manner in which the funds were transferred, the nature of the relationship between the parties involved, and the circumstances surrounding their cross-border movement provide sufficient grounds to verify compliance with the requirements of European Union and Lithuanian legislation concerning the declaration of cash upon crossing the external borders of the Union.
Particular attention should be paid to the fact that Ms. Tsikhanouskaya concealed the receipt of the funds, their origin, and the circumstances of their transfer despite the substantial amount involved. She acknowledged receiving the money only after video and audio recordings documenting the transfer became publicly available. This circumstance indicates an intention to conceal the receipt of the funds, their origin, and the conditions under which they were transferred until such concealment became impossible due to the existence of objective evidence.
Based on the totality of the circumstances, there are grounds to believe that the funds may have constituted an unlawful remuneration for the performance of certain acts or for influencing decision-making through the use of public standing or influence, which may constitute an aggravating factor. The funds may have been received in exchange for services rendered to the person who transferred the money or to a third party on whose behalf the transfer was made.
In light of the foregoing, we respectfully request an examination as to whether the circumstances disclose indications of criminal offences under the Criminal Code of the Republic of Lithuania, including: – money laundering and the legalization of proceeds derived from criminal activity; – acquisition, possession, or use of property of criminal origin; – possible corruption-related offences and associated criminal conduct; – any other criminal offences that may be identified during the course of the investigation.
The transfer of a substantial amount of cash by a senior officer of the security apparatus of an authoritarian regime requires a thorough examination of the purpose and motives of the payment. Particular concern arises from the fact that the source of the funds was a high-ranking representative of security structures whose activities have repeatedly been condemned by the European Union, the United Nations, the OSCE, and other international organizations in connection with systematic human rights violations, political repression, and abuse of power.
It is therefore necessary to establish what services, if any, were provided in exchange for the funds and to determine for which specific actions the payment was made.
In particular, it is necessary to examine whether initiatives associated with the Tsikhanouskaya Office, including “Peramoga,” “Black Book of Belarus,” and “Belaruski Hajun,” which reportedly contributed to the identification and arrest of hundreds of citizens in Belarus, constituted concealed services rendered in exchange for financial remuneration from representatives of the Belarusian regime. It should also be established whether the current “New Belarus Passport” project constitutes a paid service involving the collection of personal data of democratically minded Belarusians for potential transfer to the Belarusian security services.
As a political organization committed to the principles of the rule of law, legality, and accountability of public figures, the Belarus Democratic Forum proceeds from the understanding that the pursuit of democratic values is impossible without adherence to uniform legal standards. Democratic forces cannot demand transparency and accountability from state institutions while simultaneously disregarding circumstances that may indicate corruption, money laundering, or other serious offences.
The principle of equality before the law requires that legal assessments be conducted irrespective of political views, public status, or affiliation with democratic organizations, civil society groups, or state institutions.
Any other approach would create the unacceptable impression that different standards of law enforcement apply to different categories of individuals, contrary to the principle of equality before the law enshrined both in the Constitution of the Republic of Lithuania and in European Union law. Moreover, such an approach could give rise to doubts regarding the commitment of European institutions to the principles of the rule of law and impartial justice.
Such a practice would effectively amount to the adoption within the European Union of methods characteristic of authoritarian regimes, where decisions are based on personal loyalty, political expediency, favoritism, and differing treatment of “friends” and “opponents,” rather than on uniform legal standards and equality before the law.
The absence of an appropriate legal assessment would create a dangerous precedent that could be invoked by representatives of repressive regimes, corrupt officials, organized criminal groups, and other actors to justify the importation into the European Union of funds of suspicious or criminal origin. Such an approach would facilitate the movement of substantial amounts of cash across the external borders of the European Union without adequate legal consequences, thereby undermining the effectiveness of the European anti-money laundering framework.
Furthermore, it would create a genuine risk of establishing mechanisms for circumventing sanctions regimes through the use of intermediaries and nominee recipients for the subsequent legalization of funds within the territory of the European Union.
In light of the foregoing, we respectfully request that you:
- Register this submission as a report of a possible criminal offence;
- Conduct an examination of the circumstances described herein;
- Provide a legal assessment of the origin of the funds and the circumstances of their importation into the territory of the European Union;
- Notify the complainant of the decision adopted in accordance with the procedures established by law.
Should the circumstances described above be deemed insufficient to initiate criminal proceedings, we respectfully request a reasoned explanation of the grounds for such a decision. Such clarification is essential for understanding the legal standards applied in cases of this nature and for preventing the emergence of practices that could be exploited to circumvent mechanisms aimed at combating corruption, money laundering, and sanctions evasion within the European Union.
Attachments:
- Video recording of the transfer of funds and audio recording of the accompanying conversation.
- Link to publication 1: https://charter97.org/ru/news/2025/8/7/651164/