Ukraine Symposium – Seizure of Russian State Assets: State Immunity and Countermeasures

by | Mar 8, 2023


On 24 February 2023, the United Kingdom (UK) government objected to the Seizure of Russian State Assets and Support for Ukraine Bill in the House of Commons, proposed legislation that would require the government to put measures in place to seize frozen Russian State assets in the UK to aid in the reconstruction of Ukraine. The bill specifically singled out the frozen reserves of the Russian Central Bank in the UK, estimated to be worth £26 billion. Although it remains uncertain whether the bill will progress further, it is likely that more such initiatives will follow soon, as this is only the latest in a string of proposed measures aimed at holding Russia accountable for its war of aggression against Ukraine.

Earlier this year, the Swedish Presidency of the Council of the European Union (EU) announced its plan to set up a Working Group to explore the potential use of frozen Russian assets to finance the reconstruction of Ukraine. Similar initiatives have been directed at the frozen assets of Russian individuals. In December 2022, the Canadian government started the process of seizing and pursuing the forfeiture of assets of a sanctioned Russian oligarch. In the same month, the United States (U.S.) Senate passed an amendment to a sanctions package mandating the seizure of assets belonging to Russian oligarchs and transferring them to a trust fund for the reconstruction of Ukraine.

While the intent behind these initiatives is commendable, practical and legal challenges have arisen. Under international law, measures of expropriation against the assets of Russian individuals may raise questions concerning their legality under human rights or applicable investment treaty standards. However, measures such as the UK Seizure of Russian State Assets and Support for Ukraine Bill, which target the foreign reserves of the Russian Central Bank and other Russian state assets, present distinct international legal challenges, which are the focus of this post. In particular, these measures may be difficult to reconcile with the law of State immunity (or sovereign immunity, as it is more frequently know in the U.S. legal system), which exempts State property used for sovereign purposes from measures of execution.

Legal experts such as Zelikow and Webb have suggested that countermeasures could provide the legal basis for justifying these measures, while others such as Stephan and Anderson and Keitner have raised objections, citing difficulties in meeting some of the conditions of countermeasures. In this post, I argue that while there may be some challenges to seizing Russian State assets at this stage of the war, it may not be for the reasons that are commonly assumed. First, I discuss the concerns about State immunity raised by freezing and seizing these assets. Next, I explain why applying countermeasures to preclude the illegality of measures that affect State immunity may be less problematic than some assume. Finally, I examine some of the outstanding challenges that may arise from the seizure of Russian State assets.

The Law of State Immunity and Frozen Russian State Assets

After Russia’s invasion of Ukraine in February 2022, the EU and the Group of Seven (G7) States took an “unprecedented” step by freezing an estimated U.S. $300 billion worth of assets held by the Russian Central Bank as foreign exchange reserves. The international legal basis for implementing these measures remains unclear, with sanctioning States providing little information on the matter. For instance, the EU Council’s website simply states that “all EU sanctions are fully compliant with obligations under international law.” However, compliance with international law is not self-evident as State assets, even when located in the jurisdiction of the sanctioning States, remain protected by the rules of state immunity. When it comes to central bank assets, in particular, Wuerth notes that customary international law requires States to provide immunity from execution for the currency reserves of foreign central banks and near-absolute immunity from execution for all central bank assets. This is consistent with Articles 19 and 21(1)(c) of the 2004 United Nations Convention on the Jurisdictional Immunities of States and Their Property (not in force).

There are two main schools of thought on how to overcome the obstacle posed by the protection that State immunity offers to foreign State assets. One perspective, supported by scholars like Ruys and Wuerth, holds that State immunity only applies to “measures of constraints in connection with proceedings before a court” in line with the language of the UN Convention. As a result, this interpretation excludes the application of State immunity to asset freezing, which is an executive or legislative measure. However, this interpretation may place too much emphasis on the UN Convention’s language, which in its Preamble acknowledges that customary international law may go beyond its provisions. Additionally, it is not a particularly attractive policy proposition to suggest that measures taken by fiat of the executive are subject to fewer constraints than those that occur pursuant to the guarantees of a judicial process. Thus, according to a different perspective state immunity from execution applies to all measures of constraint, regardless of their judicial, legislative, or administrative nature, and therefore extends to asset freezing.

Regardless of one’s view on State immunity, the freezing of foreign State assets may be reconciled with international law under the countermeasures framework. According to the International Law Commission’s (ILC) Articles for Responsibility of States for Internationally Wrongful Acts (ARSIWA), the wrongfulness of measures that prima facie constitute breaches of international legal obligations may be precluded when these are taken in response to prior breaches of international law in order to induce the wrongdoing State to comply with its international obligations. Substantive and procedural conditions (such as proportionality and the duty to notify the target State) are in place to prevent abuse, but in the case of freezing foreign State assets, these do not ordinarily pose insurmountable obstacles. While some have questioned the applicability of countermeasures to the rules of State immunity, I have argued in a separate article that the wrongfulness of measures taken in breach of jurisdictional immunity may in fact be precluded according to the general rules of State responsibility governing countermeasures. In a similar vein, the rules of immunity safeguarding State assets from execution may be temporarily suspended if it is necessary and proportionate to induce the wrongdoing State to comply with its international obligations. The only exception to this is property used by diplomatic or consular missions, which is considered “inviolable” and excluded by the countermeasures mechanism under Article 50(2)(b) ARSIWA.

However, as Stephan notes, freezing and seizing are two distinct legal concepts, and the legal justification for freezing State assets may not necessarily apply to seizing them. In the next section, I will delve deeper into the issue and explore whether the seizure of foreign State assets can be reconciled with the countermeasures framework.

Countermeasures and the Seizure of Russian State Assets

The proposed Seizure of Russian State Assets and Support for Ukraine Bill seeks to place frozen Russian State assets in the UK under the control of a trustee, who would use the funds to make payments in support of Ukraine’s compensation and reconstruction efforts. While introducing the bill in the House of Commons, Sir Chris Bryant did not provide a detailed explanation of its legal basis but stated that Russia’s failure to comply with its international obligations justifies an exemption from State immunity. A more comprehensive justification for similar proposals has been put forth in literature. In the United States, Zelikow has argued that a mechanism of this nature would serve as a countermeasure aimed at enforcing Russia’s compliance with its international obligations, including compensation. However, this opinion has been met with some criticism.

As Stephan highlighted, while asset freezing can be suspended and property returned to its owner, a seizure is permanent—once the property is transferred to another owner, there is no turning back. This contradicts the nature of countermeasures as coercive measures designed to induce compliance with international law rather than to punish wrongdoing states. To maintain their coercive purpose, Article 49 ARSIWA prescribes that countermeasures must be temporary in character and reversible. For this reason, Anderson and Keitner, among others, have pointed to the non-reversibility of asset seizure as the main obstacle to the application of the countermeasures framework to similar measures.

However, the extent to which non-reversibility poses such a major hurdle to countermeasures in the form of asset seizures can be debated. While reversibility is an important concept, as Crawford has suggested, it should be interpreted broadly. According to Article 49(3) ARSIWA, countermeasures only need to be reversible “as far as possible.” The ILC’s Commentary to Article 49(3) acknowledges that the coercive nature of countermeasures is not necessarily compromised even if it is not possible to fully reverse their effects. This is particularly true when a State is enforcing a judgment of an international court or tribunal.

The unsuccessful attempt by the UK to seize Albanian assets in its territory to enforce International Court of Justice’s (ICJ) judgment in the Corfu Channel case serves as a well-known example. As Schachter noted, there was no question raised about the propriety of the procedure. The logic is clear; there is no reason to remove the effects of a measure that achieves the result that the wrongdoing State should have implemented itself to comply with its international obligations. This is not so much a punitive measure as it is a measure aimed at ensuring full implementation of international responsibility.

In the absence of an international judgment or award establishing Russia’s compensation obligations, the challenges associated with applying the countermeasures framework to the seizure of Russian State assets may stem more from practical than legal considerations, as the next section will show.

Outstanding Challenges

The challenges arising from the seizure of Russian State assets are primarily related to its timing and complexity rather than its potential non-reversibility. Determining the entity of reparation that a State owes for its breaches of international law, especially serious breaches of peremptory norms, is a difficult task. The exceptional magnitude of damages resulting from an ongoing armed conflict makes their calculation even more challenging.

The recent ICJ reparations judgment in DRC v Uganda is a testament to these complexities. To mention but one of the many issues involved, while reaffirming the Chorzow Factory standard according to which full reparation should wipe out all consequences of the internationally wrongful act, the ICJ held that it “may, on an exceptional basis, award compensation in the form of a global sum, within the range of possibilities indicated by the evidence and taking into account equitable considerations” (para. 106). In DRC v Uganda, this resulted in the Court awarding just around 3% of the amount claimed by the DRC. It is true that the delay between the conclusion of the conflict and the awarding of reparation, resulting in evidentiary uncertainties and challenges in quantifying damages, contributed to some of the difficulties faced by the ICJ. This would weigh in favour of initiating the reparation process as soon as possible. However, an ongoing armed conflict may present additional challenges in determining and implementing reparations.

In the case of Ukraine, current estimates of the costs for reparations range anywhere from U.S. $138 billion, to $349 billion, to over a trillion dollars. This uncertainty is problematic as it must be possible to quantify the amount owed by Russia as a result of its internationally wrongful conduct before its secondary obligations can be implemented by means of countermeasures. This does not necessarily disqualify the legality of unilateral measures against Russian State assets, but it does make the calculations behind such measures—which are necessarily self-judging and are taken at a State’s own risk—complex and precarious. Multilateral coordination may be required to ensure a consistent approach among sanctioning States.

If sufficient support can be mustered for a coordinated approach, it may also be wondered whether, given the sheer scale of the damages in question, more creative solutions may have a better chance to provide full reparation for Ukraine. The United Nations Compensation Commission (UNCC) established following the 1990 Iraqi invasion of Kuwait is a much-cited precedent in this respect. With its ability to draw income from the revenues of the Iraqi oil industry, the UNCC directed the payment of U.S. $52 billion in compensation to 1.5 million claimants in over 30 years. If a similar solution can be achieved with respect to Ukraine, countermeasures consisting in the seizure of Russian State assets may have a more clearly defined role to play in enforcing Russia’s compliance with its international obligations.


Supporting the Ukrainian cause requires all efforts that can help restore peace and provide full reparation for the damages inflicted by Russia’s aggressive and unlawful war. Further economic restrictions on Russia may be necessary to achieve these goals. The seizure of Russian State assets is a measure that, given the exceptional nature of the situation created by Russia’s aggression against Ukraine, defies easy legal categorization. On the one hand, it is difficult to ignore that seizing frozen Russian State assets may be the best opportunity for Ukraine to obtain some form of reparation for the damages inflicted upon it by Russia. On the other hand, the uncertainty resulting from the continuation of the conflict makes the application of international legal rules particularly complex. The primary concern when considering the application of the countermeasures framework to the seizure of frozen Russian State assets is not so much whether this measure is reversible, but rather whether there is sufficient consensus on the content of the obligations being enforced and the objectives being pursued through them.

What is undeniable is that frozen Russian State assets can play a crucial role in inducing Russia’s compliance with its international obligations. Alternatives to seizing Russia’s State assets, which have been suggested, also recognize that these assets may provide a strong incentive to bring Russia to the negotiating table. When pursuing all these options, it is important to view international law not as an obstacle, but as a tool to achieve meaningful solutions that can help restore the very international order that Russia has disrupted.


Daniel Franchini is Lecturer in International Law and Deputy Director of the Sheffield Centre for International and European Law at the University of Sheffield.


Photo credit: Unsplash


Symposium Intro: Ukraine-Russia Armed Conflict

by Sean WattsWinston WilliamsRonald Alcala

February 28, 2022

Russia’s “Special Military Operation” and the (Claimed) Right of Self-Defense

by Michael N. Schmitt

February 28, 2022

Legal Status of Ukraine’s Resistance Forces

by Ronald Alcala and Steve Szymanski

February 28, 2022

Cluster Munitions and the Ukraine War

by William H. Boothby

February 28, 2022

Neutrality in the War against Ukraine

by Wolff Heintschel von Heinegg

March 1, 2022

The Russia-Ukraine War and the European Convention on Human Rights

by Marko Milanovic

March 1, 2022

Deefake Technology in the Age of Information Warfare

by Hitoshi Nasu

March 1, 2022

Ukraine and the Defender’s Obligations

by Eric Jensen

March 2, 2022

Are Molotov Cocktails Lawful Weapons?

by Sean Watts

March 2, 2022

Application of IHL by and to Proxies: The “Republics” of Donetsk and Luhansk

by Marco Sassòli

March 3, 2022

Closing the Turkish Straits in Times of War

by Raul (Pete) Pedrozo

March 3, 2020

The Abuse of “Peacekeeping”

by Alexander Gilder

March 3, 2022

Prisoners of War in Occupied Territory

by Geoff Corn

March 3, 2022

Combatant Privileges and Protections

by Laurie R. Blank

March 4, 2022

Siege Law

by Sean Watts

March 4, 2022

Russia’s Illegal Invasion of Ukraine & the Role of International Law

by Michael Kelly

March 4, 2022

Russian Troops Out of Uniform and Prisoner of War Status

by Chris Koschnitzky and Michael N. Schmitt

March 4, 2022

On War

by Andrew Clapham

March 5, 2022

Providing Arms and Materiel to Ukraine: Neutrality, Co-belligerency, and the Use of Force

by Michael N. Schmitt

March 7, 2022

Keeping the Ukraine-Russia Jus ad Bellum and Jus in Bello Issues Separate

by Rob Mclaughlin

March 7, 2022

The Other Side of Civilian Protection: The 1949 Fourth Geneva Convention

by Jelena Pejic

March 7, 2022

Special Forces, Unprivileged Belligerency, and the War in the Shadows

by Ken Watkin

March 8, 2022

Accountability and Ukraine: Hurdles to Prosecuting War Crimes and Aggression

by Lauren Sanders

March 9, 2022

Remarks on the Law Relating to the Use of Force in the Ukraine Conflict

by Terry D. Gill

March 9, 2022

Consistency and Change in Russian Approaches to International Law

by Jeffrey Kahn

March 9, 2022

The Fog of War, Civilian Resistance, and the Soft Underbelly of Unprivileged Belligerency

by Gary Corn

March 10, 2022

Common Article 1 and the Conflict in Ukraine

by Marten Zwanenburg

March 10, 2022

Levée en Masse in Ukraine: Applications, Implications, and Open Questions

by David Wallace and Shane Reeves

March 11, 2022

The Attack at the Zaporizhzhia Nuclear Plant and Additional Protocol I

by Tom Dannenbaum

March 13, 2022

The Russia-Ukraine War and the Space Domain

by Timothy GoinesJeffrey BillerJeremy Grunert

March 14, 2022

Fact-finding in Ukraine: Can Anything Be Learned from Yemen?

by Charles Garraway

March 14, 2022

Status of Foreign Fighters in the Ukrainian Legion

by Petra Ditrichová and Veronika Bílková

March 15, 2022

Law Applicable to Persons Fleeing Armed Conflicts

by Julia Grignon

March 15, 2022

Ukraine’s Legal Counterattack

by Michael Kelly

March 17, 2022

The ICJ’s Provisional Measures Order: Unprecedented

by Ori Pomson

March 17, 2022

Displacement from Conflict: Old Realities, New Protections?

by Ruvi Ziegler

March 17, 2022

A No-Fly Zone Over Ukraine and International Law

by Michael N. Schmitt

March 18, 2022

Time for a New War Crimes Commission?

by Diane Marie Amann

March 18, 2022

Portending Genocide in Ukraine?

by Adam Oler

March 21, 2022

Are Mercenaries in Ukraine?

by Robert Lawless

March 21, 2022

Abducting Dissent: Kidnapping Public Officials in Occupied Ukraine

by Katharine Fortin

March 22, 2022

Are Thermobaric Weapons Unlawful?

by Matt Montazzoli

March 23, 2022

A Ukraine No-Fly Zone: Further Thoughts on the Law and Policy

by Terry D. Gill

March 23, 2022

The War at Sea: Is There a Naval Blockade in the Sea of Azov?

by Martin Fink

March 24, 2022

Deportation of Ukrainian Civilians to Russia: The Legal Framework

by Michael N. Schmitt

March 24, 2022

Weaponizing Food

by Michael N. Schmitt

March 28, 2022

Command Responsibility and the Ukraine Conflict

by Noëlle Quénivet

March 30, 2022

The Siren Song of Universal Jurisdiction: A Cautionary Note

bySteve Szymanski and Peter C. Combe

April 1, 2022

A War Crimes Primer on the Ukraine-Russia Conflict

by Sean Watts and Hitoshi Nasu

April 4, 2022

Russian Booby-traps and the Ukraine Conflict

by Michael N. Schmitt

April 5, 2022

The Ukraine Conflict, Smart Phones, and the LOAC of Takings

by Gary Corn

April 7, 2022

War Crimes against Children

by Véronique Aubert

April 8, 2022

Weaponizing Civilians: Human Shields in Ukraine

by Michael N. Schmitt

April 11, 2022

Unprecedented Environmental Risks

by Karen Hulme

April 12, 2022

Maritime Exclusion Zones in Armed Conflicts

by Raul (Pete) Pedrozo

April 12, 2022

Ukraine’s Levée en Masse and the Obligation to Ensure Respect for LOAC

by Jann K. Kleffner

April 14, 2022

Cultural Property Protection in the Ukraine Conflict

by Dick Jackson

April 14, 2022

Results of a First Enquiry into Violations of International Humanitarian Law in Ukraine

by Marco Sassòli

April 14, 2022

Comprehensive Justice and Accountability in Ukraine

by Chris Jenks

April 15, 2022

Maritime Neutrality in the Russia-Ukraine Conflict

by David Letts

April 18, 2022

Cyber Neutrality, Cyber Recruitment, and Cyber Assistance to Ukraine

by Nicholas Tsagourias

April 19, 2022

Defiance of Russia’s Demand to Surrender and Combatant Status

by Chris Koschnitzky and Steve Szymanski

April 22, 2022

The Montreux Convention and Turkey’s Impact on Black Sea Operations

by Adam Aliano and Russell Spivak

April 25, 2022

Lawful Use of Nuclear Weapons

by Jay Jackson and Kenneth “Daniel” Jones

April 26, 2022

Litigating Russia’s Invasion of Ukraine

by Lawrence Hill-Cawthorne

April 27, 2022

Military Networks and Cyber Operations in the War in Ukraine

by Heather Harrison Dinniss

April 29, 2022

Building Momentum: Next Steps towards Justice for Ukraine

by Philippa Webb

May 2, 2022

Counternormativity and the International Order

by Dan E. Stigall

May 3, 2022

Destructive Counter-Mobility Operations and the Law of War

by Sean Watts and Winston Williams

May 5, 2022

Are We at War?

by Michael N. Schmitt

May 9, 2022

The Ukraine Conflict and the Future of Digital Cultural Property

by Ronald Alcala

May 13, 2022

Neutral State Access to Ukraine’s Food Exports

by James Kraska

May 18, 2022

Negotiating an End to the Fighting

by Michael N. Schmitt

May 24, 2022

Is the Law of Neutrality Dead?

by Raul (Pete) Pedrozo

May 31, 2022

Effects-based Enforcement of Targeting Law

by Geoff Corn and Sean Watts

June 2, 2022

U.S. Offensive Cyber Operations in Support of Ukraine

by Michael N. Schmitt

June 6, 2022

War Sanctions Steadily Degrade the Russian Maritime Sector

by James Kraska

June 7, 2022

The Atrocity Crimes Advisory Group & Ukrainian Prosecutions of Russian POWs – Part 1

by Chris Jenks

June 22, 2022

The Atrocity Crimes Advisory Group & Ukrainian Prosecutions of Russian POWs – Part 2

by Chris Jenks

June 24, 2022

The Atrocity Crimes Advisory Group & Ukrainian Prosecutions of Russian POWs – Part 3

by Chris Jenks

June 28, 2022

Putting “Overall Control” to the Test of the Third Geneva Convention

by Alessandra Spadaro

July 6, 2022

The Risk of Commercial Actors in Outer Space Drawing States into Armed Conflict

by Tara Brown

July 8, 2022

The Release of Prisoners of War

by Jeroen van den Boogaard

July 8, 2022

The Attack on the Vasily Bekh and Targeting Logistics Ships

by James Kraska

July 11, 2022

Lessons from Syria’s Ceasefires

by Marika Sosnowski

July 12, 2022

Documentation and Investigation Responses to Serious International Crimes

by Brianne McGonigle Leyh

July 13, 2022

Rebel Prosecutions of Foreign Fighters in Ukraine

by René Provost

July 15, 2022

Forced Civilian Labor in Occupied Territory

by Michael N. Schmitt

August 2, 2022

Forced Conscription in the Self-Declared Republics

by Marten Zwanenburg

August 8, 2022

Amnesty International’s Allegations of Ukrainian IHL Violations

by Michael N. Schmitt

August 8, 2022

Oil Tankers as “Environmental Time Bombs,” or Not

by Mark Jessup

August 12, 2022

The Escalating Military Use of the Zaporizhzhia Nuclear Plant

by Tom Dannenbaum

August 22, 2022

Protected Zones in International Humanitarian Law

by Michael N. Schmitt

August 24, 2022

Photos of the Dead

by William Casey Biggerstaff

August 19, 2022

Deception and the Law of Armed Conflict

by William Casey Biggerstaff

September 8, 2022

Data-Rich Battlefields and the Future of LOAC

by Shane ReevesRobert Lawless

September 12, 2022

Russian Crimes Against Children

by Oleksii KaminetskyiInna Zavorotko

September 14, 2022

Targeting Leadership

by Mehmet Çoban

September 16, 2022

Illegality of Russia’s Annexations in Ukraine

by Lauri Mälksoo

October 3, 2022

Russia’s Forcible Transfer of Children

by Alison Bisset

October 5, 2022

The Kerch Strait Bridge Attack, Retaliation, and International Law

by Marko MilanovicMichael N. Schmitt

October 12, 2022

Russian Preliminary Objections at the ICJ: The Case Must Go On?

by Ori Pomson

October 13, 2022

The Complicity of Iran in Russia’s Aggression and War Crimes in Ukraine

by Marko Milanovic

October 19, 2022

Attacking Power Infrastructure under International Humanitarian Law

by Michael N. Schmitt

October 20, 2022

Dirty Bombs and International Humanitarian Law

by Michael N. Schmitt

October 26, 2022

Doxing Enemy Soldiers and the Law of War

by Eric Talbot JensenSean Watts

October 31, 2022

Are Civilians Reporting With Cell Phones Directly Participating in Hostilities?

by Michael N. SchmittWilliam Casey Biggerstaff

November 2, 2022

Using Cellphones to Gather and Transmit Military Information, A Postscript

by Michael N. Schmitt

November 4, 2022

State Responsibility for Non-State Actors’ Conduct

by Jennifer Maddocks

November 4, 2022

Reparations for War: What Options for Ukraine?

by Luke Moffett

November 15, 2022

Further Thoughts on Russia’s Campaign against Ukraine’s Power Infrastructure

by Michael N. Schmitt

November 25, 2022

Russia’s Allegations of U.S. Biological Warfare in Ukraine – Part I

by Robert Lawless

December 2, 2022

Russia’s Allegations of U.S. Biological Warfare in Ukraine – Part II

by Robert Lawless

December 9, 2022

The THeMIS Bounty Part I: Seizure of Enemy Property

by Christopher Malis and Hitoshi Nasu

December 12, 2022

Classification of the Conflict(s)

by Michael N. Schmitt

December 14, 2022

The THeMIS Bounty Part II: Stealing Enemy Technology

by Christopher Malis, Hitoshi Nasu

December 16, 2022

The “I Want to Live” Project and Technologically-Enabled Surrender

by David Wallace, Shane Reeves

January 13, 2023

UN Peacekeepers and the Zaporizhzhia Nuclear Plant

by Alexander Gilder

January 20, 2023

What’s in a Name? Getting it Right for the Naval “Drone” Attack on Sevastopol

by Caroline Tuckett

January 23, 2023

Ukraine’s “Suicide Drone Boats” and International Law

by Charles M. Layne

January 25, 2023

The Impact of Sanctions on Humanitarian Aid

by Alexandra Francis

January 27, 2023

A Wagner Group Fighter in Norway

by Camilla Cooper

February 1, 2023

The Legal and Practical Challenges of Surrendering to Drones

by William Casey Biggerstaff,Caitlin Chiaramonte

February 8, 2023

Field-Modified Weapons under the Law of War

by Ronald Alcala

February 13, 2023

The Wagner Group: Status and Accountability

by Winston Williams, Jennifer Maddocks

February 23, 2023

The Law of Crowdsourced War: Democratized Supply Chains – Part I

by Gary Corn

March 1, 2023

Reprisals in International Law

by Michael N. Schmitt

March 6, 2023

The Law of Belligerent Occupation

by David A. Wallace 

March 8, 2023