When Russia becomes a member of the World Trade Organization in the coming months, Europe and the United States are expected to take different approaches to putting pressure on the country to improve its human rights record. The United States is likely to use trade, specifically the granting of permanent normal trade relations status, as an incentive. Europe, on the other hand, will count on the European Court of Human Rights to penalize human rights failings. The question is, which approach will ultimately be most successful?