... After the wave of apologies for the long years of slavery and exploitation of African populations in the last decade across Europe and the United States, as well as public discussions of the phenomenon from every possible angle - historical, political, economic and social - have not closed the question of ethical reparations for the victims of slavery. However, with the willingness to recognize the mistakes of the past and to fully examine shameful experiences in human history, is society ready to speak openly about contemporary slavery, to recognize the problem and to address it...?
Today, the world is shaken by horrific events centered on human beings - men and women, the elderly and children. People are willing to pay a high price for their salvation - and sometimes pay with their lives. Despite all the risks, migrant flows do not subside, often using channels of "illegal" movement and work in the shadow sector in the new place - which also entails the following risks - involvement in "trafficking" or modern slavery, to put it simply.
Expert Vera Gracheva, President of the Interregional Public Movement against Trafficking in Human Beings and Modern Forms of Forced Labor "Alternativa", a Russian non-governmental organization that since 2011 has been assisting in the release of victims of these crimes throughout Russia and beyond, agreed to answer the agency's questions. As one of the leading Russian and international experts in this field, author of the Commentary to the OSCE Action Plan to Combat Trafficking in Human Beings and co-author of a number of OSCE, Council of Europe and CBSS studies, Vera Georgievna is also an editor and translator of publications on modern slavery. In addition, V.G. Gracheva is a member of the Board of the Partnership in Action International Network of NGOs against Trafficking in Human Beings and Other Forms of Violence. V.G. Gracheva represents this platform of cooperation in the Alliance Expert Coordination Team (Alliance Expert Coordination Team) under the auspices of the OSCE, which brings together representatives of leading international organizations that are leading in the development of modern methods of combating trafficking in human beings, assisting victims and preventing this crime. In her personal capacity, V.G. Gracheva is an expert of the Global Initiative against Transnational Organized Crime.
- Vera Georgievna, tell me, how relevant is this topic today? Is slavery possible now, in the twenty-first century?
- Let's start with the terminology.
Slavery, in its traditional sense, is "the position or condition of a person over whom some or all of the powers inherent in the right of ownership are exercised" (Slavery Convention, 1926)[1]. Today, almost a hundred years later, we speak of modern slavery in relation to human trafficking and forced labor, debt bondage and servitude. This is how this criminological process has been interpreted by the European Court of Human Rights under Article 4 of the European Convention on Human Rights (Prohibition of slavery, forced labor and servitude)[2]. In the judgment in the case of Rantsev v. Cyprus and Russia (2010)[3] the ECtHR noted that "trafficking in human beings is a worldwide phenomenon which has become much more widespread in recent years". And in determining the extent to which the treatment of a trafficked person falls within the scope of this Article of the Convention, the ECtHR held that "trafficking in human beings, by its very nature and purpose of exploitation, is based on the exercise of attributes of the right to property. In trafficking, a person is treated as a commodity to be bought and sold and may be subjected to forced labor, often for little or no remuneration, usually in the sex industry, but also in any other field". Trafficking in human beings, as the ECtHR writes, "involves close surveillance of the activities of the victims, whose movements are often restricted. It involves the use of violence and threats against victims who live and work in poor conditions" and can be seen as "a modern variation of the old global slave trade".
In support of its position, the ECtHR also cites the opinion of the International Criminal Tribunal for the former Yugoslavia: "the traditional concept of slavery has, in the course of its development, come to include various modern forms of slavery based on the exercise of all or some of the attributes of ownership. And further: "... in determining whether a situation constitutes a modern form of slavery, the following factors are relevant: whether the person's movement or physical environment was controlled, whether there was an element of psychological control, whether measures were taken to prevent or deter escape, whether the person's sex life was controlled and whether the person was engaged in forced labor"[4].
It should be added that since 2000, with the adoption of the UN Convention against Transnational Organized Crime and its supplementary Protocol to Prevent, Suppress and Punish Trafficking in Persons, Especially Women and Children[5], trafficking in human[6] beings has been criminalized, and the Council of Europe Convention on Action against Trafficking in Human Beings (2005)[7] states in its preamble that "trafficking in human beings is a violation of human rights and an affront to the dignity and integrity of the human person; ... may lead to the enslavement of its victims; ... may lead to the exploitation of their victims; ... may lead to the trafficking of women and children; ... may lead to the enslavement of women and children; ... may lead to the trafficking of women and children"[8].
- It is almost a quarter of a century since the adoption of the Palermo Protocol and 18 years since the Council of Europe Convention. So is it relevant today? Is it possible?
According to a study on the state of organized crime published in the Global Organized Crime Index 2021 report[9], trafficking in persons has become the most prevalent criminal trade market in the world, surpassing drug trafficking, illicit arms trafficking and the organization of irregular migration by a number of indicators[10]. . According to the Global Organized Crime Index 2023 report[11], trafficking in persons is on par with financial crime in terms of prevalence, dynamics and ineffectiveness of countermeasures, followed by cannabis and arms trafficking. The organization of irregular migration and trafficking in synthetic drugs showed an upward trend.
According to 2021 data from the International Labour Organization[12], the number of victims of forced labour and involuntary servitude, which combines labour and sexualized exploitation, is estimated at 49.6 million worldwide. The increase in a few years is 10 million. How could this have happened? Has the number of victims actually risen or have we become more careful in counting? Either way, the factors behind the growth have been the coronavirus pandemic, which has significantly increased the proportion of vulnerable groups, the migration crisis of recent years, and the active penetration of human trafficking into the Internet space, both in terms of the use of digital technology to recruit potential victims and online exploitation, that is, the use of the Internet to serve clients in real time without the victims having to move across borders or within the country. Some experts believe that this transforms classic human trafficking, which involves transporting victims to the place of exploitation, into purely sexualized exploitation, crimes against the person, or related forms of criminal activity (e.g., the use of minors in the production of pornography), but in any case we are faced with the treatment of human beings as objects of consumption. If we exclude the movement of the victim to the place of exploitation as an element of the internationally accepted definition of trafficking in human beings, the use of deception, fraud, abuse of a vulnerable position in recruitment and the purpose, namely exploitation and criminal profit, remain unchanged.
Trafficking in persons, in whatever form, remains an extremely lucrative crime, characterized by extreme latency, with experts estimating that less than 0.05 per cent of victims are identified worldwide and annual revenues estimated at $150 billion.
- What does modern slavery look like? How do people get into these situations?
Modern slavery is constantly evolving. New methods of recruitment (and above all the use of ICT - modern information and communication technologies) are emerging, exploitation is penetrating new economic spheres, and the proportion of minors among identified victims is constantly increasing, reaching an average of 30 per cent today. While at the beginning of the "noughties" it was common to associate human trafficking only with coercion in commercial prostitution, today we can speak of the prevalence of labor exploitation or trafficking for forced labor. And this sphere is almost limitless - 63% of exploitation takes place in the private sector, 23% in commercial prostitution, and 14% is allowed in public sector enterprises[13]. The sectors of the economy most exposed to forced labor are, according to the ILO, the service sector, production of consumer goods, construction, agriculture and domestic work. There has been an increase in labor exploitation in mining, fishing, forced begging and exploitation in the criminal sector (drug cultivation and distribution, theft, social benefit fraud, exploitation of trafficked persons by illegal terrorist groups). Trafficking in human beings for the illegal extraction of organs and tissues for the purpose of transplantation is the least frequently detected, although this does not mean that there are few such cases. Sexualized exploitation is not limited to commercial prostitution, but also includes the exploitation of women's reproductive functions, the production of pornography involving minors, and forcing women to bear children for sale. Moreover, trafficking in children for exploitation in any form is increasingly coming to the attention of international organizations as a problem that requires immediate measures in the area of prevention and counteraction[14].
There is a list of indicators that can be used to suspect a high likelihood of trafficking and forced labor. These include illegal confiscation of identity and migration cards, isolation and restriction of freedom of movement, abuse of vulnerability, deception in recruitment, e.g. regarding the scope and conditions of work (including pay), use of physical and sexualized violence, withholding of wages, ever-increasing debt obligations, excessive overtime and many others. The ILO explains, "The presence of at least one indicator in a given situation may in some cases indicate a situation of forced labor. In other cases, however, you may need to look for several indicators that, taken together, indicate that forced labor is taking place." However, not all front-line workers put these indicators into practice or pay attention to them. There are cases of mistrust of victims' statements or lack of understanding of how effective psychological pressure can be, how real the threats from criminals are, and the validity of victims' fears for their safety and the safety of their loved ones. The ratio of reported to latent crimes, which can range from 1:3 to 1:10[15], is a problem, including due to lack of confidence in the victims' testimony and refusal to accept a report of an offense committed against them.
Almost anyone can find themselves in a human trafficking situation. The criminals are perfectly skilled in deceiving a person interested in employment. This is most often the case with adult victims. Millions of people are desperately looking for jobs, livelihoods, and the poverty rate is not decreasing year after year. For them, employment becomes a survival strategy and their natural belief in better things turns out to be a trap. Job offers, whether on the Internet or on paper, as well as face-to-face contact, look so attractive that a person agrees without giving any thought to what lies behind the facade - expecting a roof over their head, food, a good climate, a labor contract, the opportunity to support their family...In other cases, victims of kidnapping find themselves in a trafficking situation, no matter how well off the person was. This is often the case with children and the elderly. For example, there have been cases of such people disappearing from nursing homes and then being found as victims of forced begging.
Children in orphanages and boarding schools are in a particularly vulnerable situation, and recently new terms have emerged - trafficking of children into orphanages (in order to increase the number of pupils and, accordingly, funding), from orphanages and within orphanages (for example, temporary transfer of children for "rent" with subsequent return). There are many cases (more than 50 percent)[16] in which children are trafficked by their own parents, close relatives or people they know well. The reasons are not so numerous. At one pole - poverty and the search for a source of income to feed other children, the naive hope that in the case of "adoption" the child will be provided with good conditions. At the same time, the adults on whom the fate of such children depends may not have the slightest idea that they are committing a serious criminal offense. At the other pole is the criminal business that profits from trafficking in children for illegal adoption (i.e. actually resale), forced labor, begging, stealing, participation in drug trafficking, commercial prostitution and production of child pornography, sexualized online exploitation, etc.
- Tell us who is at risk - men or women; young or old; educated or not so educated; urban or rural?
We are all, with very few exceptions, at risk. Men and women as potential victims of trafficking for labour or sexualized exploitation, newborn (and even unborn) children as potential victims of illegal adoption or begging, adolescents in child pornography production, commercial prostitution, criminal activities, street vending or domestic work, young people in any of these areas, and lonely old people, people with various disabilities, mainly for forced begging or fraudulent activities Previously, it seemed that low or no education was a risk factor. This is true, but in recent times, the victims of transnational trafficking have often been IT professionals who are moved abroad and forced to create fake accounts to siphon money from potential clients. Such accounts disappear as soon as the prepayment for the service is made and are reopened under a different name.
- How do the country's legal systems classify such crimes? How are the perpetrators punished?
171 countries around the world have ratified the Palermo Protocol, thereby criminalizing trafficking in persons. States parties to the Protocol undertook to amend their national legislation accordingly and to provide for criminal liability commensurate with the gravity of the crime. While at the stage of criminalizing trafficking in persons, the vast majority of countries had similar positions, different approaches emerged at the next stage, when their national legal systems needed to be improved. Some states have gone down the path of developing and adopting separate, specialized anti-trafficking laws and, moreover, have introduced provisions guaranteeing state protection of the rights and legitimate interests of trafficking victims. Others have limited themselves to the introduction of one or two articles in the Criminal Code[17] and the adoption of a law on the protection of victims and other participants in criminal proceedings, thus, in our view, unreasonably leveling the needs of victims of crimes of different gravity. There is hardly any doubt that those who have suffered, for example, from robbery, require one kind of assistance, while those who have been subjected to coercion, humiliation, physical and psychological torture for a long time, sometimes for years, and those who have suffered severe trauma, require completely different support and assistance, long-term rehabilitation, compensation for damage (including moral damage), socialization and rebuilding their lives.
Of particular interest are the attempts of regional international organizations, such as the European Union and the Commonwealth of Independent States, to encourage their members to unify their national legislation and bring it in line with international and regional standards. In this respect, the European Union's Directives on combating trafficking in human beings are binding and, being regularly updated, are the most relevant to the requirements of the times and the new risks and challenges posed by organized crime. It would be an exaggeration to say that the EU member states immediately "take up arms" and immediately implement all the relevant provisions of the Directives; the pace of implementation is different for each country, but they are nevertheless moving in the same direction, taking into account current trends and approaches, accumulated experience and the need to prioritize the protection of victims' rights.
The CIS member states adopted Model Legislation on Combating Trafficking in Human Beings in 2008[18] and the Concept of Cooperation in this area in 2014[19]. In practical terms, after several cycles of Cooperation Programs on Combating Trafficking in Human Beings, in 2019 this topic was integrated into the Interstate Program of Joint Crime Control Measures for 2019-2023[20]. Despite the recommendatory nature of model legislation, most CIS member states have adopted special laws dedicated to combating modern slavery, have created or are in the process of creating national monitoring systems, a national referral mechanism for victims of trafficking in persons to provide them with guaranteed assistance and protection, and are developing systems of coordination between state authorities and civil society institutions.
It seems that today we are facing a problem not so much with the adoption of new legal norms as with their enforcement, with the ability of investigative bodies and the judicial system to qualify a committed crime as human trafficking, to obtain a sufficient evidence base, to promote a human rights approach, and to prevent re-traumatization of victims in the course of legal proceedings. And this is only a small part of what requires an immediate solution and a coordinated approach of many stakeholders in the fight against modern slavery.
In Western Europe and the United States, national legislation in the form of special laws has been in use for more than twenty years and, despite this, is also subject to continuous improvement. Of particular interest in this regard is not even so much the severity and inevitability of the penalties provided for by the laws, but rather the elaborate system of protection measures for victims. Examples of such legislation are presented in the International Organization for Migration publication "Review of Legislation and Law Enforcement Practices in the United Kingdom, France, Germany, Italy, Sweden, the United States and Germany on Combating Trafficking in Persons and Forced Labour" (2022)[21].
- How does the civil sector work? Is there cooperation between specialized NGOs? Do you manage to recover victims of trafficking?
Civil institutions remain (or should remain) one of the main actors in combating human trafficking[22]. The vast majority of NGOs providing assistance to victims of human trafficking receive calls to hotlines, messages from volunteers, and from relatives of people in captivity who need support. Rarely do victims manage to contact relevant NGOs on their own and ask for help - their contacts are monitored by criminals and people are intimidated, assuring them that any attempt to free themselves will result in either reprisals or criminal prosecution for violating migration laws. Nevertheless, NGOs enjoy more trust from victims than any official structures. Of course, working with survivors of trafficking requires considerable funds to maintain shelters, food, clothing, first aid, even to pay for hotlines or rental of premises, not to mention transportation costs for volunteers to travel to the places of alleged exploitation and return with the victim.
Receiving support mainly from concerned citizens, NGOs do a lot of preventive work, raising awareness of the population, especially young people and other targeted vulnerable groups, about the risks associated with trafficking. Obviously, their work urgently requires government support in the form of long-term grants, namely long-term grants, since work with victims cannot be interrupted due to lack of funding, and people cannot simply be put out on the street until they have completed a full course of rehabilitation and have a real opportunity for employment and independent further life. Not surprisingly, without such support, the number of NGOs engaged in this field is catastrophically decreasing, especially given the problematic nature of obtaining foreign grants, even from international organizations, and the possible consequences.
A significant factor in the effectiveness of NGOs remains their interaction, whether through specially created platforms, chat rooms or associations. One example of such interaction at the international level was the creation of the Partnership in Action International Network of NGOs to Combat Trafficking in Human Beings and Other Forms of Violence. In a few years, the Network, initially founded by organizations from Uzbekistan, Kazakhstan and Russia, has grown to 50 organizations representing all Central Asian countries, Russia, Armenia, Azerbaijan, Moldova/Transnistria, Turkey, the UAE and the United States. The network has become a public prototype of the Transnational Referral Mechanism, a platform for 7/24 interaction in solving specific cases and assisting in the return of victims to their home countries, in raising the qualifications of the staff of NGOs themselves, and in creating a system of real interaction.
- What to do to avoid being enslaved?
Anyone can become a victim of modern slavery, but there are categories of people for whom this threat is particularly relevant due to their vulnerability. These are refugees and displaced persons. They have been forced to leave their homes, whether as a result of war, natural or man-made disasters. These people are deprived of their means of subsistence, are under stress and are desperately looking for an opportunity to start a new, decent life, to provide for their loved ones, to overcome addiction. Their vulnerability is shamelessly exploited by criminals, involving in their networks defenseless people who are ready to believe their promises of work, wages and housing. Criminals do not miss any opportunity to profit from human grief. In this case, these attempts are especially cynical and cruel, as we are talking about women, children and the elderly.
Yes, refugees and migrants, but they are not the only ones. Vulnerable categories include people living below the poverty line, the unemployed, the homeless, people prone to various addictions, lonely old people, orphans and children from dysfunctional families, victims of domestic violence, migrant workers and their children. This list has no end in today's turbulent world... How to prevent crime?
The first is to know that the risk of becoming a victim of human trafficking is real. Most often, the danger comes from recruiters. These are people who may offer employment - both domestically and abroad. If they are young women and girls, they will talk to them about working as a dancer, animator or photo model, a maid or nanny, a waitress or a secretary in a "good firm". Salaries for such "jobs" are promised exorbitant. The reality is far from what is offered. Most often victims find themselves in a situation of sexualized exploitation.
Romeo recruiters approach the girls, woo them, make gifts, promise to marry them, and, having gained trust and often aroused affectionate feelings in return, involve the victim in forced prostitution. In the case of the elderly and disabled, they may be offered temporary light work, but in reality it turns out to be forced begging. For young people, recruiters may offer construction or farm work, and the result will be labor exploitation or a mousetrap!"!
No, you should not suspect any job advertisement of possible criminality, but you should be particularly careful about attractive-looking offers of employment and housing. For example, the promise of high earnings in the absence of the necessary qualifications is more than suspicious. On the Internet, you can always find data on the average salary for similar labor and compare it with what you are offered.
Criminals use proven methods of psychological pressure on the potential victim: "The group is almost fully formed, there are only a few places left"; "Documents can be drawn up later"; "You should leave immediately, otherwise the vacancy will be gone". If labor conditions are not specified (no contract or employment agreement), the risk is doubled. If there is a contract, however, it should be carefully studied, consulted with a lawyer, and not signed if something is unclear. The contract should be written in a language you speak well. Without an employment contract, it will be almost impossible to prove in court that it was violated by the employer. And the information about the company/firm where you are supposed to get a job should be carefully checked.
When it comes to working abroad, claiming that there is no need for an employment visa and that no foreign language skills are required puts you in a disempowered position in advance. A tourist visa does not entitle you to employment - this is a gross violation of the law. Without language skills, it will be difficult to assert your rights in a foreign country. Pay attention to the offer to pay transportation costs at the employer's expense - especially if it is a one-way ticket. This potentially creates a situation of debt bondage, which will grow fines for spurious reasons, and will be accompanied by demands to "work off the debt".
There are ground rules that are extremely dangerous to break. For example, never give your documents to anyone! Illegal seizure of passports under any pretext upon arrival (for registration, for example) is a traditional technique that puts the victim in a dependent position. If you are in trouble, you should know where you can turn for help. Memorize the telephone numbers and address of your consulate in another country, the telephone number of the Human Trafficking Hotline, make copies of your documents and leave them with your loved ones (this will help to restore your travel documents and confirm your identity). Tell your friends and family where you are going to work and give them the coordinates of the firm you signed a contract with. Agree on a code word for your family (with a possible phone call in the presence of those who are holding you back) that will let them know you need help.
Be careful in your online contacts. Know that criminals make extensive use of the Internet to recruit, control and blackmail potential victims. Never post intimate photos or videos or personal information online - criminals can use them. Take care of yourself, preventing crime is easier than dealing with its consequences.
One last thing. Any evil exists as long as it is considered acceptable by the majority. It is difficult for us to expect to overcome it quickly, after all these millennia of slavery as a norm of life, but let's strive for it. Together.
[1] https://www.un.org/ru/documents/decl_conv/conventions/convention_slavery.shtml
[2] https://www.echr.coe.int/documents/d/echr/Convention_RUS
[3] https://europeancourt.ru/uploads/ECHR_Rantsev_v_Cyprus_and_Russia_07_01_2010.pdf
[4] Ibid.
[5] https://www.un.org/ru/documents/decl_conv/conventions/protocol1.shtml
[6] Article 3 of the Protocol states: (a) "Trafficking in persons" shall mean the recruitment, transportation, transfer, harbouring or receipt of persons, by means of the threat or use of force or other forms of coercion, of abduction, of fraud, of deception, of the abuse of power or of a position of vulnerability or of the giving or receiving of payments or benefits to achieve the consent of a person having control over another person, for the purpose of exploitation. Exploitation shall include, at a minimum, the exploitation of the prostitution of others or other forms of sexual exploitation, forced labor or services, slavery or practices similar to slavery, servitude, or the removal of organs;
(b) The consent of a victim of trafficking in persons to the planned exploitation referred to in subparagraph (a) of this article shall be disregarded if any of the means set forth in subparagraph (a) have been used;
(c) The recruitment, transportation, transfer, harbouring or receipt of a child for the purpose of exploitation shall be considered "trafficking in persons" even if it does not involve any of the means set forth in subparagraph (a) of this article;
(d) "Child" shall mean any person under the age of 18 years.
[7] https://rm.coe.int/16805a937a
[8] Ibid.
[9] https://globalinitiative.net/wp-content/uploads/2021/09/GITOC-Global-Organized-Crime-Index-2021.pdf
[10] The experts compared the following indicators: prevalence, evolution and effectiveness of measures taken by States to counter one or another of the ten types of organized crime (trafficking in persons, organization of irregular migration, arms trafficking, crimes against wild flora and fauna, crimes against non-renewable resources, heroin trafficking, cocaine trafficking, cannabis trafficking, trafficking in synthetic drugs).
[11] https://ocindex.net/report/2023/0-3-contents.html
[12] https://www.ilo.org/wcmsp5/groups/public/---ed_norm/---ipec/documents/publication/wcms_854733.pdf
[13] Ibid.
[14] Report of the International Organization for Migration (2023) “From Evidence to Action. Twenty Years of IOM Child Trafficking Data to Inform Police and Programming, https://publications.iom.int/system/files/pdf/PUB2023-021-EL-From-Evidence-to-Action_0_0.pdf
[15] https://www.yandex.ru/search/?text=%D1%81%D0%BE%D0%BE%D1%82%D0%BD%D0%BE%D1%88%D0%B5%D0%BD%D0%B8%D0%B5+%D0%B7%D0%B0%D1%80%D0%B5%D0%B3%D0%B8%D1%81%D1%82%D1%80%D0%B8%D1%80%D0%BE%D0%B2%D0%B0%D0%BD%D0%BD%D1%8B%D1%85+%D0%B8+%D0%BB%D0%B0%D1%82%D0%B5%D0%BD%D1%82%D0%BD%D1%8B%D1%85+%D0%BF%D1%80%D0%B5%D1%81%D1%82%D1%83%D0%BF%D0%BB%D0%B5%D0%BD%D0%B8%D0%B9+%D1%81%D0%BE%D1%81%D1%82%D0%B0%D0%B2%D0%BB%D1%8F%D0%B5%D1%82&lr=213&search_source=chromentp_desktop&src=suggest_T
[16] Ibid.
[17] For example, article 127.1, "Human trafficking", was introduced into the Criminal Code of the Russian Federation in 2003, https://www.consultant.ru/document/cons_doc_LAW_10699/4a5e2bbfdd061dde65a55bb65d36d4b4a7fe8ee7/ , and article 127.2 "Use of slave labor", https://www.consultant.ru/document/cons_doc_LAW_10699/d9997ad420efb5277afbabe009c87f15895214cf/
[18] Model Law on Combating Trafficking in Human Beings, https://docs.cntd.ru/document/902124613; Model Law on Assistance to Victims of Trafficking in Persons, https://docs.cntd.ru/document/902124615, as well as Recommendations on Unification and Harmonization of the Legislation of CIS Member States in Combating Trafficking in Human Beings, https://docs.cntd.ru/document/902124617
[19] Decision on the Concept of Cooperation of the States Members of the Commonwealth of Independent States in Combating Trafficking in Human Beings, https://www.cis.minsk.by/reestrv2/doc/4993#text
[20] https://cis.minsk.by/reestrv2/doc/5863#text
[21] https://russia.iom.int/sites/g/files/tmzbdl1036/files/documents/Overview%20human%20trafficking%20fin.pdf
[22] See for more details the OSCE thematic report "The Key Role of Civil Society in Combating Trafficking in Human Beings", https://www.osce.org/files/OP8_RU_Critical%20Role%20of%20NGOs_screen_low-res_150dpi_190208.pdf
Медицинская помощь иностранным гражданам в РФ: правовое регулирование и практика правоприменения