US President Barack Obama will first discuss this issue with Chinese leader Xi Jinping on 7 June and 10 days later, with Russian President Vladimir Putin.

Shortly before then, in May this year, NATO experts from the Cooperative Cyber Defence Centre of Excellence (NATO CCD COE) published the Tallinn Manual, the first ever guidance on how to apply existing laws to cyber warfare.

The main problem in the fight against international cyberterrorism consists in that it is impossible to establish the source of an attack promptly and accurately, which creates a great scope for mutual accusations and damage to countries' reputation.

This has more than once been stated by official representatives of the Chinese and Russian defence ministries, as well as by experts from the Kaspersky Lab internet security company.

The Tallinn Manual

The full title of the document is "The Tallinn Manual on the International Law Applicable to Cyber Warfare". It features Tallinn because the CCD COE office, which opened in 2008, is based in the Estonian capital.

The purpose of the document is to prove that the existing norms of international law (primarily international humanitarian law) are applicable to cyberspace. And therefore, contrary to Russia's position, which proposes developing laws specifically to deal with cybercrime, there is no need for new laws.

Attacks carried out without a full-fledged war are described by the authors of the manual as "unlawful actions". A state that has been damaged in an attack can respond to it either by bringing the aggressor to account or by resorting to "proportionate counter-measures".

The authors stress that depending on its scale and consequences (loss of life, damage to or destruction of facilities), a cyber attack in peaceful time can be considered equal to "use of force" or "an armed attack", which allows the state that has been attacked to resort to self-defence, including the use of conventional weapons.

The biggest section of the Manual is devoted to cyber attacks accompanying traditional armed conflicts. They, the authors believe, should be covered by all the norms of international humanitarian law, up to recognizing the participants and organizers of online attacks as combatants, who can be taken prisoner or eliminated. 

Manual for war

The Russian authorities, especially the military, have greeted the Tallinn Manual with considerable caution. Although the document is no more than an expert publication, an advisory rather than an official manual, Moscow has interpreted it as a step towards legitimising the very notion of cyber warfare.

This position was clearly stated in April by a Russian Defence Ministry official, Konstantin Peschanenko: "The issue of cyber security is a most topical one at present. It is particularly important to prevent the militarisation of the virtual space. Whereas the Tallinn Manual is a step in exactly that direction. Its approach to the issue at hand is far from perfect. And the assessments made in it appear one-sided."

In the West however, the publication of the Tallinn Manual has received a warm welcome.

Prof Michael Schmitt from the International Law Department at the United States Naval War College and several other experts have pointed out that its key ideas are in line with Washington's position whereby there is no need to draft new laws for regulating cyberspace.

Platform for dialogue

At the same time, despite the fact that on legal issues, the positions of China, Russia and the USA are very much apart, they have for the first time come closer in practical terms.

Neither Russia nor China denies the need to develop norms of international law regulating cyberspace.

Chinese Foreign Ministry spokeswoman Hua Chunying said in March that the Chinese authorities were ready to cooperate with the USA in maintaining internet security and transparency.

An expert with the Russian Institute of Strategic Studies, Aleksandr Bedritskiy, pointed out that Moscow had initiated a broad international discussion of issues related to countries' confrontation in cyberspace. For instance, Russia already cooperates with IMPACT, International Multilateral Partnership Against Cyber Threats, a division of the United Nations' International Telecommunication Union, as well as with the OSCE's Action Against Terrorism Unit.

However, Russia has for a long time been confronted with the USA's reluctance to engage in dialogue.

No-one is above reproach

The USA has more than once branded China and Russia as the main source of cyber threats. In a report to the US Congress in November 2011, the Office of the National Counterintelligence Executive said that hackers from those two countries were actively trying to break into secure servers storing economic and defence information.

In February a US internet security company, Mandiant, accused a division of China's People's Liberation Army of staging over 140 hacker attacks, mainly aimed against US companies engaged in military research.

China has repeatedly denied its involvement in any form of cyberspace action and instead accused the US of cyber activity in the Chinese segment of the internet.

After the publication in February of a report called "Exposing One of China's Cyber Espionage Units", in which China was described as the main cyber threat, a spokesperson for the Chinese Foreign Ministry said: "Speculation and unfounded accusations like these seem to us unprofessional and irresponsible, and do not help to address the problem. China is a target for cyber attacks too."

While representatives of the Chinese Defence Ministry said that the Americans launch up to 100,000 attacks on Chinese computers every month.

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