In some states, "repression" can be an official term used in legislation or the names of government institutions. The Soviet Union had a legal policy of repression of political opposition defined in its penal code and Cuba under Fulgencio Batista had a secret police agency officially named the Bureau for the Repression of Communist Activities. According to Soviet and Communist studies scholar Stephen Wheatcroft, in the case of the Soviet Union terms such as "the terror", "the purges" and "repression" are used to refer to the same events. He believes the most neutral terms are "repression" and "mass killings", although in Russian the broad concept of repression is commonly held to include mass killings and is sometimes assumed to be synonymous with it, which is not the case in other languages.