law enforcement officers to steal the corporate registration documents of three Hermitage holding companies. They perpetrated a fraud, claiming (and receiving) a rebate of $230 million in taxes paid by those companies to the Russian state in 2006. In November 2008, one of Hermitage's auditors, Sergei Magnitsky, was arrested. He was "charged with two counts of aggravated tax evasion committed in conspiracy with Mr. Browder in respect of Dalnyaya Step and Saturn" (ECHR § 35). Magnitsky died on November 16, 2009, in prison, after eleven months in pretrial detention, nearly the limit allowed under the law. On August 27, 2019, the European Court for Human Rights, in judging a case brought against Russia by the Magnitsky family, ruled that Magnitsky was detained in conditions which amounted to "inhuman and degrading treatment in breach of Article 3 of the Convention" (§ 193). This, combined with negligence, lack of adequate medical care, and ill-treatment also amounted to a breach of the convention (§ 240). Magnitsky's family was awarded €34,000. As a result of the controversy related to his arrest and evidence of mistreatment and claimed abuse, his death aroused international coverage and outrage. Magnitsky's death was the catalyst for passage by the U.S. Congress, of the Magnitsky Act, signed into law by President Barack Obama on December 14, 2012. The act directly targeted individuals involved in the Magnitsky affair by prohibiting their entrance to the United States and their use of its banking system. In February 2013, Russian officials announced that Browder and Magnitsky would both be tried for evading $16.8 million in taxes. In March 2013, Russian authorities announced that they would be investigating Hermitage's acquisition of Gazprom shares worth $70 million. The investigation was to focus on whether Browder violated any Russian laws when Hermitage used Russian companies registered in the region of Kalmykia to buy shares. An investigation by the Council of Europe's Committee on Legal Affairs and Human Rights cleared Browder of the accusations of improprieties that surfaced at this time. Browder was also charged with trying to gain access to Gazprom's financial reports. Browder admitted having sought influence in Gazprom, but denied any wrongdoing. He said that purchasing Gazprom shares was an investment in the Russian economy, and the desire to influence the Gazprom management was driven by the need to expose a "huge fraud going on at the company". However, at the time it was illegal