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Moldova – Russian Federation

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Transdniestria claimed by Moldova, remained occupied by Russia.

The law of occupation applies to the belligerent occupation of Moldovan territory by Russia. The law of military occupation is set out in Hague Convention IV of 1907 and the annexed Regulations; Geneva Convention IV of 1949; and Additional Protocol I of 1977. Moldova and Russia are parties to the Geneva Conventions, but only Moldova is party to the Additional Protocol I. Customary international humanitarian law (IHL) also applies to an occupation complementing treaty law and binding all the parties.

Transdniestria (also called Transnistria) is a narrow strip of land within the internationally recognized borders of Moldova in Eastern Europe. This narrow strip of land is nestled between the Dniester river and Ukraine and is part of sovereign Moldovan territory. Moldova is made up of two regions. The eastern part of the State, Bessarabia, mainly comprises ethnic Romanians, while in Transdniestria in the west most of the population is Slavic.1Constitutional History of Moldova’, Constitution.Net. In 1989, during the lead-up to the fall of the Soviet Union, tensions ran high in Transdniestria when Moldova adopted a controversial language law making Moldovan its official language instead of Russian.2Transnistria profile’, BBC News, 25 October 2024; A. Ali, ‘Transnistria: Russia’s Sleeper Front’, European Relations, 6 August 2025. Transdniestria broke away from Moldova on 2 September 1990,3A. Ali, ‘Transnistria: Russia’s Sleeper Front’, European Relations, 6 August 2025 but does not enjoy recognition by the international community.4Transnistria profile’, BBC News, 25 October 2024; ‘Transnistria’, DW. Before announcing its independence, fighting broke out in November 1990 between the Moldovan Armed Forces and Transdniestrian separatists.5The war in Transnistria’, BBC. Fighting escalated when Transdniestria’s paramilitary forces seized Moldovan public institutions in 1991.6Transnistria profile’, BBC News, 25 October 2024; ‘Moldova Marks 30 Years Since War with Russia-Backed Transnistria Rebels’, Balkan Insight, 2 March 2022. During this period the Russian Armed Forces became involved in the conflict.

Following Moldova’s declaration of independence on 27 August 1991,7Transnistria – Life in a Russian Bear Hug’, Association for Diplomatic Studies and Training the Soviet Union’s Fourteenth Army remained in the Transdniestrian part of Moldovan territory,8ECtHR, ‘Case of Ilaşcu and Others v Moldova and Russia’, Judgment, 8 July 2004, paras 32 – 35 joining the separatists in  their conflict against the Moldovan Armed Forces.9K. Verseck, ‘Breakaway Transnistria is Russia’s stronghold in Moldova’, DW, 28 September 2025; ‘Breakaway Moldovan Region Of Transdniester Celebrates 30 Years Of ‘Independence’’, Radio Free Europe Radio Liberty, 2 September 2020. The conflict peaked in June 1992 with the battle of Dniester in which between 700 and 1,000 people were killed,10A. Felcher, ‘The 1990–92 Armed Conflict at the Dniester River: Continuous Memory Confrontation’, Cultures of History Forums, 19 September 2022; ‘Transnistria profile’, BBC News, 25 October 2024; ‘Moldova Marks 30 Years Since War with Russia-Backed Transnistria Rebels’, Balkan Insight, 2 March 2022 and 3,500 were wounded.11V. Roşa, ‘The Transnistrian Conflict: 30 Years Searching for a Settlement’, Utrikespolitiska Institutet, October 2021. The Yeltsin-Snegur ceasefire agreement12K. Harrington, ‘Moldova Marks 30 Years Since Ceasefire Ended War on Costly Terms’, Balkan Insight, 21 July 2022 was signed in July 1992 after the battle of Dniester to officially end the conflict.13Moldova and Transnistria: Thawing the Frozen Conflict?’, Spheres of Influence, 21 November 2023. This agreement created the Joint Control Commission and a Russian-led peacekeeping mission.14K. Harrington, ‘Moldova Marks 30 Years Since Ceasefire Ended War on Costly Terms’, Balkan Insight, 21 July 2022.

On several occasions, Russia committed, at international level, to withdraw its forces from Transdniestria. The 1994 bilateral agreement15Written Declaration No. 243 on the 14th Russian Army’s withdrawal from Transnistria’, Council of Europe, 12 July 1995 was reaffirmed at the 1999 OSCE Istanbul Summit;16Lisbon Document 1996’, Organization for Security and Co-operation in Europe, 1996 in 2003, the Russian Draft Memorandum on the Basic Principles of the State Structure of a United State in Moldova (also referred to as the Kozak Memorandum) was issued;17Russian Draft Memorandum on the basic principles of the state structure of a united state in Moldova, 17 November 2003’, Eurac Research while 2005 saw the 5+2 diplomatic negotiation platform.18Annex 3 to the Commission Implementing Decision on the ENI East Regional Action Programme for 2019, Part 2, including some actions to be carried out in 2020, to be financed from the general budget of the European Union’, European Union; ‘Memorandum: Meeting of Chancellor Angela Merkel and President Dmitri Medvedev on 4 – 5 June 2010 in Meseberg’, Die Bundesregierung; L. S. Râncioagă, ‘Recent Evolutions in the Political Environment in Transnistria’, Revista de Ştiinţe Politice, 2012. Russia is yet to honor any of these commitments.19S. Korshak, ‘Explained: Russian Troops, Pro-Russian Forces in Moldovan ‘Separatist’ Transnistria Region’, Kyiv Post, 25 September 2025. In 2020, President Vladimir Putin expressly rejected the Kozak Memorandum, blaming Western intervention for the situation.20W. H. Hill, ‘Putin on Moldova: What Can We Still Learn from a 2003 Failure?’, Wilson Center, 15 January 2021. The 5+2 format negotiations became defunct in 2022 when Russia invaded Ukraine, as both Russia and Ukraine were participants in the process.21Krasnoselski se plânge iarăși pe Moldova: Criza energetică a răcit relațiile’, Timpul, 18 November 2022.

Russian soldiers remained on this strip of Moldovan territory throughout the reporting period.22A. Ali, ‘Transnistria: Russia’s Sleeper Front’, European Relations, 6 August 2025; M. Lelich and L. Oleniak, ‘Ukraine’s Ambassador to Moldova reveals number of Russian soldiers in Transnistria’, RBC-Ukraine, 28 October 2025; K. Verseck, ‘Breakaway Transnistria is Russia’s stronghold in Moldova’, DW, 28 September 2025.

Heightened security tension between Moldova and Russia

During the first year of the international armed conflict between Russia and Ukraine, there were allegations that high-ranking Russian officials explored the potential of Transdniestria as a possible second entry point into Ukraine as part of Russia’s military tactics.23C. Belton, ‘Russia’s security service works to subvert Moldova’s pro-Western government’, The Washington Post, 28 October 2022; K. Zakharchenko, ‘Russia Could Invade Moldova in Days If Ukraine Weakens – Ex-Moldovan Spy Chief’, Kyiv Post, 22 April 2025; ‘Russia Seeks to Deploy 10K More Troops to Moldovan Breakaway Region, PM Says’, The Moscow Times, 4 June 2025. Moldova has continued to allege that Russia has conducted disinformation campaigns, false-flag operations, and other destabilizing efforts in Moldova.24Russia ramping up operations in Moldova’s breakaway Transnistria region’, The New Voice of Ukraine, 10 December 2025; K. Zakharchenko, ‘Russia Could Invade Moldova in Days If Ukraine Weakens – Ex-Moldovan Spy Chief’, Kyiv Post, 22 April 2025. During September 2025, Moldovan police detained persons accused of election interference on Russian instruction.25M. Sharipzhan, et al, ‘EU Monitoring Threats To Moldova’s Elections Amid Alleged Russian Plot To Train Provocateurs In Serbia’, Radio Free Europe Radio Liberty, 25 September 2025; ‘Moldova detains 74 people over alleged Russia-backed plot before elections’, Al Jazeera, 22 September 2025. In October 2025, Moldova launched its military strategy for 2025–35,26Military Strategy 2025–2035 approved by Government’, Government of the Republic of Moldova, 8 October 2025 which flags Russia as a primary concern to its national security.27Russia named top security threat in Moldova’s military strategy’, Russian News Agency, 8 October 2025. This was not well received by the Kremlin.28M. Gridina, ‘Kremlin Warns Moldova Could “Share Ukraine’s Fate” After New Military Strategy Designates Russia as Main Threat’, Moldova Live, 13 October 2025.

During December 2025, suspicions that Russia planned to heighten its military presence in Transdniestria arose again, the alleged purpose of which was to escalate tension in Ukraine’s southern regions.29Russia boosts activity in Transnistria to divert Ukraine’s resources and strengthen military presence’, The Odessa Journal, 10 December 2025; ‘Russia ramping up operations in Moldova’s breakaway Transnistria region’, The New Voice of Ukraine, 10 December 2025. But as at 14 December 2025, no active troop movements were observed on the Ukraine-Moldova border along the Transdniestria region.30No Russian buildup seen in Transnistria, border agency says’, The New Voice of Ukraine, 14 December 2025.

Russia cut off all gas exports to Moldova

On 1 January 2025, Transdniestria stopped receiving gas from Russia as Ukraine blocked the transit of Russian gas through its territory.31S. Ciochina, ‘Moldovans in Transnistria adjust to life without Russian gas’, DW, 1 October 2025; T. Zadorozhnyy, ‘Transnistria again declares economic emergency over Russian gas cut’, The Kyiv Independent, 11 June 2025; ‘Russian gas shutdown forces closure of almost all industry in Transnistria’, The Guardian, 2 January 2025. It is suggested that Russia had the possibility to reroute gas supplies to Transdniestria and ensure that it would not be affected by Ukraine’s blockage of Russian gas flow but declined to do so.32V. Solovyov, ‘The Gas Man Cometh: Moscow risks losing Transnistria by creating energy problems for Moldova’, The Insider, 27 January 2025. Transdniestria’s economy has been severely impacted as this part of Moldovan territory is completely reliant on free Russian gas.33E. Grynszpan, ‘Russia cuts Transnistria’s gas supply to destabilize Moldova’, Le Monde, 12 January 2025; T. Zadorozhnyy, ‘Transnistria again declares economic emergency over Russian gas cut’, The Kyiv Independent, 11 June 2025; ‘Russian gas flow to Europe via Ukraine stopped: Who does it hurt?’, Al Jazeera, 1 January 2025; M. Ohanjanyan, ‘Unfreezing Transnistria?’, Clingendael, 12 March 2025. These gas cuts have resulted in thousands of job losses and generated a prolonged economic emergency in Transdniestria.34Statement: “If Russia halts gas deliveries to the Transnistrian region, we can discuss reintegrating the area into the country”’, Moldova 1, 16 December 2025. The energy crisis may stimulate an improvement in Moldova’s relations with its separatist region.35Statement: “If Russia halts gas deliveries to the Transnistrian region, we can discuss reintegrating the area into the country”’, Moldova 1, 16 December 2025.

Moldova expels Russian diplomats

Moldova expelled three Russian diplomats in March 2025. Moldova accused Russia of trying to facilitate the escape of a pro-Russian lawmaker, Alexander Nesterovschii, in Moldova to Transdniestria in order to escape a prison sentence. Russia denied the allegations.36Moldova expels three Russian diplomats, Moscow promises to retaliate’, Al Jazeera, 31 March 2025; ‘Moldova says Russia helped pro-Moscow MP flee long jail sentence’,CNN, 31 March 2025.

Moldova’s road to European Union Membership

On 3 March 2022, Moldova applied for European Union (EU) membership.37Moldova’, European Commission. In June 2022, it was granted EU candidate country status.‘European Council conclusions on Ukraine, the membership applications of Ukraine, the Republic of Moldova and Georgia, Western Balkans and external relations, 23 June 2022’, European Council, 23 June 2022. On 14 December 2023, the EU initiated accession planning with Moldova to join the EU.38Moldova’, European Commission. On its road to accession, Moldova’s first intergovernmental conference took place on 25 June 2024.39Directorate-General for Neighbourhood and Enlargement Negotiations, ‘EU opens accession negotiations with Moldova’, European Commission, 25 June 2024. On 10 September 2025, the European Parliament adopted a resolution in support of Moldova’s inclusion in the EU,40The European Parliament adopted the resolution supporting Moldova’s accession to the EU’, Government of the Republic of Moldova, 10 September 2025 with its screening assessment completed on 22 September 2025.41Directorate-General for Enlargement and Eastern Neighbourhood, ‘Moldova successfully completes its screening process’, European Commission, 22 September 2025.

Moldova’s elections

President Maia Sandu won a second term as the president of Moldova during the 2024 presidential elections.42P. Kirby, ‘Pro-EU leader wins Moldova election despite alleged Russian meddling’, BBC, 4 November 2024. This is despite accusations of Russia interfering in the presidential and parliamentary elections.43Moldova formally protests alleged Russian election meddling’, Al Jazeera, 12 November 2024; T. Lister and K. Gak, ‘Moldova’s election delivers lessons to Europe on countering Russian interference’, CNN, 30 September 2025.  President Maia Sandu took a pro-European stance whilst the opposition leader, Alexandr Stoianoglo, belonged to the pro-Russian party.44P. Kirby, ‘Pro-EU leader wins Moldova election despite alleged Russian meddling’, BBC, 4 November 2024. Moldova handed a diplomatic note  of protest over alleged election interference to the Russian ambassador to Chisinau.45Moldova formally protests alleged Russian election meddling’, Al Jazeera, 12 November 2024.

Parliamentary elections

In September 2025, Moldova held their parliamentary elections. These elections were described as potentially determining the fate of Moldova’s accession bid into the EU.46D. Peleschuk, ‘Moldova faces key parliamentary election, with EU bid at stake’, Reuters, 25 September 2025. Leading up to the elections there were allegations of electoral fraud, with police discovering 200 ballots already stamped in a printing house in the capital. All had the stamp ‘voted’ on the ‘Alternativa’ block.47C. Donțu and R. Hoară, ‘Poliția din Chișinău a descoperit 200 de buletine de vot care erau deja ștampilate în favoarea blocului Alternativa’, Știrile Pro TV, 24 September 2025. Alternativa in this instance refers to Blocul Politic Alternativa, a political alliance which describes itself as having been formed by forces united in their belief that Moldova needs a new direction.48About Us’, Blocul Politic Alternativa. According to Ion Ceban, the leader of the political party, the ballots were just models for the electoral campaign.49C. Donțu and R. Hoară, ‘Poliția din Chișinău a descoperit 200 de buletine de vot care erau deja ștampilate în favoarea blocului Alternativa’, Știrile Pro TV, 24 September 2025. In another incident, Prime Minister Dorin Recean reported that a massive cyberattack had targeted the structure related to Moldova’s electoral process with around 4,000 websites being brought down. However, the attacks were detected and neutralized before they could affect the electoral process.50M. Conovali, ‘Promo-LEX: Alegători transportați în coloană cu mașini transnistrene: în unele telefoane „instrucțiuni” de vot’, News Maker, 28 September 2025. Bomb alerts were reported at several polling stations in the diaspora, which the Moldovan authorities denounced as part of Russia’s assault on the electoral process in Moldova.51I. Soltan, ‘Alertă cu bombă la mai multe secții de votare din străinătate. MAE: Avem scenariul sub control’, Agora, 28 September 2025.

Russian-controlled outlets have been accused of being the foundation of a global media and proxy propaganda infrastructure intended to disrupt the electoral process.52A. Hansen, ‘How Russia tried to manipulate Moldova’s election – and what it reveals’, The Interpreter, 27 November 2025. The United Kingdom announced that it would sanction the Evrazia organization for Russian interference in Moldovan elections.53UK sanctions pro-Russian group over alleged Moldova vote interference’, Al Jazeera, 2 April 2025; T. Lister and K. Gak, ‘Moldova’s election delivers lessons to Europe on countering Russian interference’, CNN, 30 September 2025.

The pro-European party, Action and Solidarity, won the elections, capturing 50.2 per cent of the vote, winning 55 out of 101 seats, and securing a single party majority aligned with the Moldovan President and Prime Minister.54T. Akhvlediani, ‘In Moldova’s election, the line held and a mandate was won – but the hard work is only just beginning’, Center for European Policy Studies, 1 October 2025. The victory has been described as a litmus test in Moldova where Russian interference and disinformation campaigns had sought to prevent the country from joining the European mainstream.55T. Lister and K. Gak, ‘Moldova’s election delivers lessons to Europe on countering Russian interference’, CNN, 30 September 2025.

Transdniestria elections

Transdniestria held its parliamentary elections on 30 November 2025. These elections served to fill all thirty-three seats in the Supreme Council.56A. Выприцких, ‘В Приднестровье началось досрочное голосование на выборах в местный парламент’, News Maker, 24 November 2024. These elections identify potential presidential candidates in Transdniestria.57A. Dirun, ‘Parliamentary Elections in Transnistria: Internal and External Dynamics, Including Rising Tensions with Moldova and the Influence of Russia’, Tartu Ülikool, 27 November 2025. Voter turnout was disappointing as only 26 per cent of voters – 102,600 of 394,000 – participated. A preliminary list of the thirty-three elected deputies was published; all elected officials belong to the ‘Renewal’ party. Detailed voting results by district were not made available.58Foreign Intelligence Service: Transnistria “elections” mark record low turnout, complete control by Sheriff-linked party’, The Odessa Journal, 2 December 2025.

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International armed conflict between Moldova and Russia – War WATCH

Approximately 1,500 Russian soldiers remain in the Transdniestria region of Moldova.1ECtHR, ‘Case of Lypovchenko and Halabudenco v the Republic of Moldova And Russia’, Judgment, 20 February 2024, para 57; ‘European Parliament resolution of 5 May 2022 on the state of play of EU-Moldova cooperation (2022/2651(RSP))’, European Union, 2022, para F; ‘From Warnings to Warfare: Russia’s Hybrid Offensive Against Moldova’s Westward Turn”’, Robert Lansing Institute, 13 October 2025. This is despite Moldova not consenting to this and the State’s repeated requests for Russia to withdraw its soldiers from Moldova’s sovereign territory.2UNGA, ‘Resolution adopted by the General Assembly on 22 June 2019’, UN Doc A/RES/72/282, 26 June 2018, preambular paras 1 and 7; ‘Russia Seeks to Deploy 10K More Troops to Moldovan Breakaway Region, PM Says’, The Moscow Times, 4 June 2025. In October 2022, Moldova was once again asked Russia to withdraw its soldiers from Transdniestria.3J. Pleschberger, ‘Moldova urges Russia to withdraw troops from Transnistria’, CTGN, 28 October 2022.

In January 2025, Moldova’s prime minister said that a lasting solution to the energy crisis in Transdniestria hinged on Russia withdrawing its troops from Transdniestria.4Moldova PM Says Russia Troops Must Leave Transnistria to Solve Crisis’, Kyiv Post, 22 January 2025. In July 2025, European leaders called for the ‘full’ and ‘immediate’ withdrawal of all Russian military personnel and ammunition from the Transdniestrian region of Moldova, reaffirming their commitment to supporting Moldova’s territorial integrity within its internationally recognised borders and its continued path towards EU membership.5EU Calls for withdrawal of Russian forces from Transnistria’, Kuwait News Agency, 4 July 2025. In December 2025, the Organization for Security and Cooperation in Europea (OSCE) Chairperson in Office, Finland’s Minister of Foreign Affairs Elina Valtonene, urged Russia to immediately and unconditionally withdraw its troops and weapons from Transdniestria.6OSCE Chair Calls on Russia to Withdraw Troops from Transnistria’, Mezha, 4 December 2025.           

Under IHL, a situation of occupation exists if the territory is ‘under the authority of the hostile army’, even in the absence of resistance.7Article 42 of Convention (IV) respecting the Laws and Customs of War on Land and its annex: Regulations concerning the Laws and Customs of War on Land, 18 October 1907’, International Committee of the Red Cross: International Humanitarian Law Databases. The hostile foreign forces must exercise effective control over a territory without the consent of the sovereign State.8T. Ferraro and L. Cameron, ‘Article 2: Application of the Convention’, Commentary on the First Geneva Convention, International Committee of the Red Cross, 2016, para 302. The nature of ‘effective control’ in the context of occupation is further elaborated in legal doctrine and interpretations, which establish three cumulative conditions for occupation:9How is the Term “Armed Conflict” Defined in International Humanitarian Law’, International Committee of the Red Cross, 2024, 11-12; T. Ferraro ‘Determining the Beginning and End of an Occupation Under International Humanitarian Law’, International Review of the Red Cross, 2012

  • The foreign state’s armed forces are physically present in the territory or parts of the territory of the territorial state without its consent.
  • The presence of the foreign forces prevents the effective local government in place at the time of invasion from substantially or completely exercising its powers.
  • The foreign forces are able to establish their own authority.

In Moldova, Russian Armed Forces, without Moldovan consent, remain present on sovereign Moldovan territory.10UNGA, ‘Resolution adopted by the General Assembly on 22 June 2019’, UN Doc A/RES/72/282, 26 June 2018, preambular para 6 and operative para 1; A. Ali, ‘Transnistria: Russia’s Sleeper Front’, European Relations, 6 August 2025. Russia’s Fourteenth Army never withdrew from Transdniestria,11Transnistria profile’, BBC News, 25 October 2024 although Moldova has repeatedly called on Russia to withdraw its armed forces and weaponry from Moldovan territory.12UNGA, ‘Resolution adopted by the General Assembly on 22 June 2019’, UN Doc A/RES/72/282, 26 June 2018, preambular para 7; ‘Russia Seeks to Deploy 10K More Troops to Moldovan Breakaway Region, PM Says’, The Moscow Times, 4 June 2025. In sum, Russia’s continued military presence in Transdniestria without Moldova’s consent fulfils the first requirement of occupation as demanded by IHL.

There have been reports of Russia attempting to consolidate their military presence in the region with The Moscow Times reporting in June 2025 that Russia was planning to deploy 10,000 more troops to the Moldovan breakaway region.13Russia Seeks to Deploy 10K More Troops to Moldovan Breakaway Region, PM Says’, The Moscow Times, 4 June 2025. This was in reference to statements by Moldova’s Prime Minister to the Financial Times, citing intelligence assessments.14H. Foy and P. Ivanova, ‘Russia wants to deploy 10,000 troops in Moldovan breakaway regio, PM warns’, Financial Times, 4 June 2025; ‘Lecartev: Russia plans for major troop buildup in Transnistria’, Ukrainian World Congress, 6 June 2025.

The second requirement for effective control necessitates that ‘the effective local government in place at the time of the invasion has been or can be rendered substantially or completely incapable of exerting its powers by virtue of the foreign forces’ unconsented-to presence’.15How is the Term “Armed Conflict” Defined in International Humanitarian Law’, International Committee of the Red Cross, 2024, 11. Moldova is incapable of exercising control over Transdniestria. The self-proclaimed ‘Moldovan Republic of Transnistria’ administers and acts as the de facto authority of Transdniestria. Indeed, the Moldovan Republic of Transnistria has its own de facto constitutional regime, de facto courts, and de facto authorities akin to police and armed forces.16ECtHR, ‘Case of Lypovchenko and Halabudenco v the Republic of Moldova And Russia’, Judgment, 20 February 2024, paras 2, 12, 14, and 57. Transdniestria has its own government, parliament, constitution, flag, and national anthem.17Transnistria profile’, BBC News, 25 October 2024. Moldova has not been able to exercise any authority over Transdniestria.18ECtHR, ‘Case of Lypovchenko and Halabudenco v the Republic of Moldova And Russia’, Judgment, 20 February 2024, para 55. Hence the second condition for occupation under IHL is fulfilled.   

The third requirement to qualify a situation as an occupation under IHL entails that ‘the foreign forces are in a position to exercise authority over the territory concerned (or parts thereof) in lieu of the local government.19How is the Term “Armed Conflict” Defined in International Humanitarian Law’, International Committee for the Red Cross, 2024, 11.  It is required that the foreign forces are in a position to exercise authority but it is not demanded that the foreign forces do exercise such authority. Russia has the ability to exercise authority in Transdniestria owing to its continued military presence. The European Court of Human Rights has recognized that the Russian Federation exercises de facto jurisdiction over Transdniestria as its regime would not be able to survive without the continued military, economic and political support of Russia.20Republic of Moldova Constitutional Court, ‘Judgment on the Interpretation of Article 11 of the Constitution (Permanent Neutrality)’, 2 May 2017, para 132; ECtHR, ‘Case of Ilaşcu and Others v Moldova and Russia’, Judgment, 8 July 2004, paras 222 and 392; ECtHR, ‘Case of Ivanţoc and Others v Moldova and Russia’, Judgment, 15 November 2011, para  101; ECtHR, ‘Case of Catan and Others v Moldova and Russia’, Judgment, Grand Chamber, 19 October 2012, paras 122 – 123.

The Council of Europe has qualified the Transdniestrian situation as a Russian occupation of Moldova.21Consequences of the Russian Federations Aggression against Ukraine, Opinion 300 (2022)’, Council of Europe Parliamentary Assembly, 15 March 2022, para 5. The Constitutional Court of the Republic of Moldova drew a similar conclusion.22Republic of Moldova Constitutional Court, ‘Judgment on the Interpretation of Article 11 of the Constitution (Permanent Neutrality)’, 2 May 2017, para 134.

State

  • Moldova
  • Russia