Memorial Human Rights Centre (HRC) commented that the complaints against its statutes include several unjustified and excessive demands. “The Ministry of Justice wants virtually the whole of the Civil Code to be included in our statutes, which is a problem not only for NGOs but for all legal entities”, said Aleksander Cherkasov, who chairs Memorial HRC’s board. 
On 9 November 2015 it transpired that two officials based at the Ministry of Justice Moscow headquarters, G.A. Aloyan and P.V. Cheremnov, accused Memorial HRC in their official inspection report of “undermining the constitutional order of the Russian Federation, calling for the overthrow of the government and a change of the country’s political regime”.

These dreadful accusations gave rise to public indignation both in Russia and abroad. Russian academics, the PEN Centre, the Free Historical Society, and Russian and foreign human rights defenders issued special statements on the subject. Arseny Roginsky, chair of the board of the International Memorial Society and a well-known historian, wrote an open letter to the Justice Minister, General Konovalov, in which he stressed that '[...] Ministry of Justice officials believe that making statements critical of the government constitutes "undermining the basis of constitutional order" and "calling for the overthrow of the government." This "legal" logic doesn’t only recall Soviet times, when dissent was equated to undermining the Socialist order - it takes us straight back to that era [...].' 

The Secretary General of the Council of Europe, Thorbjørn Jagland, expressed his disquiet about the accusations against Moscow’s Memorial Human Rights Centre, stating: 'These accusations are particularly worrying in that they classify the ordinary work of NGOs as a serious criminal offence.' He called on the Russian government to stop its harassment of human rights activists, including Memorial. Jagland also restated the necessity of revising Russian legislation on NGOs, including with regard to so-called ‘foreign agent’ NGOs.