Sanctions Must Continue: A Comparative Analysis of Sanctions Against Legal Entities

The Monitoring Group of BlackSeaNews
and the Black Sea Institute of Strategic Studies  

The BlackSeaNews and the Black Sea Institute for Strategic Studies Monitoring Group continue to analyze the scope of sanctions against legal entities. This ongoing effort is based on a comprehensive database of sanctioned entities related to Russian aggression against Ukraine, which our team has maintained since the conflict's inception. For previous sanctions review of September 1, 2023, click here.

As of November 1, 2024, our database encompassed legal entities sanctioned by Ukraine, the US, the EU, the UK, and Canada.

We update the database regularly, a process that since Russia's full-scale invasion, has become nearly continuous due to the significant expansion of sanctions.

Updating the database involves a lot more than just transferring data from the sanction lists; it requires a thorough identification of each entity – a painstaking process due to the often incomplete or erroneous information in the official lists. Whenever possible and necessary, we also research and add crucial information about sanctioned entities, including their official and actual addresses, registration and tax data, partners, connections, and so on.

The database, however, isn't merely an updated list of the sanctioned companies. It also contains the entire sanction decision history for each entity, as well as all changes to their names and legal status, reorganizations, liquidations, bankruptcies, successors and/or managing companies, all tracked in a timely manner.

As of November 1, 2024, the database contained 10,174 legal entities, with the vast majority – 8,077 (79%) – being Russian.

Additionally, 450 entities are registered in the occupied territories of Ukraine (448) and Georgia (2). The database also includes 5 entities registered by Russia in the Ukrainian city of Kherson during its 2022 occupation.

The majority of companies (7,267) have been sanctioned by Ukraine. U.S. sanctions affect 4,637 firms, including those on the U.S. Department of the Treasury's Office of Foreign Assets Control Office (OFAC) list and those subject to export restrictions. The number of entities sanctioned by other countries is considerably smaller.

Ukraine's Sanctions

The database contains all legal entities named in all relevant President of Ukraine's Decrees since September 2015. 

In recent years, Ukraine has been actively updating its sanctions lists. As of November 1, 2024, the database contained 7,267 legal entities subject to Ukrainian sanctions

5,136 of the entities (50% of the total database), have been sanctioned by Ukraine only.

Between our last review and 01.11.2024, Ukraine has made 1,613 more sanction decisions, 879 of which constituted adding new entities to the list, while the rest – extending the already existing sanctions.

The process remains ongoing, with four more sanction packages imposed on 157 legal entities as of the publication date.

Unfortunately, Ukraine's sanctions policy still falls short of being precise and systematic, often resulting in sanctions not being extended after expiration.

As of November 1, 212 functioning Russian companies were no longer under Ukrainian sanctions, with 123 of those left sanction-free throughout 2024.

While as of the publication date, sanctions against 24 operational Russian companies have been renewed, many important enterprises, including those in the military-industrial complex, still await decisions.

Examples of companies whose Ukrainian sanctions expired on June 24, 2024, include:

JSC Izhevsk Mechanical Plant, a well-known arms manufacturer that is part of the Kalashnikov concern

OJSC State Airline 224th Flight Detachment, that transports military equipment and weapons, including from North Korea

JSC St. Petersburg Aircraft Repair Company, that repairs and maintains military helicopters

OJSC 308th Aviation Repair Plant, that repairs and maintains military aircraft

JSC Aerosila Research and Production Enterprise, that develops and produces propellers, gas turbine engines, and other aircraft components

OJSC Kazan Plant Elektropribor, that manufactures military aviation devices

OJSC Rosneft Oil Company.

Obviously, Ukrainian sanctions during the active phase of the war do not make economic sense, because cooperation with any Russian companies is impossible and unacceptable anyway, constituting criminal offense.

Instead, they primarily serve to inform our "sanctions coalition" partners of the entities that still need to be sanctioned. Meanwhile, if Ukraine expects the partners to take a responsible approach to limiting Russia's economic and military capabilities, it must be careful not to erode the process by overlooking its own sanctions.
 

U.S. Sanctions

Our database includes all legal entities on the SDN, SSI, and CAPTA lists of the OFAC under sanctions programs related to the Russian aggression against Ukraine. It also includes entities from other OFAC programs connected to Russian aggression:

• UKRAINE-EO13660 (Executive Order 13660)
• UKRAINE-EO13661 (Executive Order 13661)
• UKRAINE-EO13662 (Executive Order 13662)
• UKRAINE-EO13685 (Executive Order 13685)
• RUSSIA-EO14024 (Executive Order 14024)
• RUSSIA-EO14065 (Executive Order 14065)
• BPI-RUSSIA-EO14024 (Blocked Pending Investigation, Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR Part 587)
• BELARUS (Belarus Sanctions Regulations, 31 C.F.R. part 548; Executive Order 13405)
• BELARUS-EO14038 (Executive Order 14038)

But the range of sanctioned entities in the database is not limited to purely "Russian-Ukrainian" programs. Over time, an increasing number of companies listed in other U.S. sanctions programs are coming to light as entities connected to Russia's aggression against Ukraine.

Therefore, the database also includes legal entities from the following OFAC programs:

• CAATSA-RUSSIA (Countering America's Adversaries Through Sanctions Act of 2017)
• CAR (Central African Republic Sanctions, 31 C.F.R. part 553)
• CYBER2 (Executive Order 13694; Executive Order 13757)
• DPRK (Executive Order 13551)
• DPRK2 (Executive Order 13687)
• DPRK3 (Executive Order 13722)
• ELECTION-EO13848 (Executive Order 13848)
• GLOMAG (Executive Order 13818 – Global Magnitsky)
• IFSR (Iranian Financial Sanctions Regulations, 31 CFR part 561)
• IRAN-CON-ARMS-EO (Executive Order 13949)
• IRGC (Iranian Financial Sanctions Regulations, 31 CFR Part 561)
• NICARAGUA (Executive Order 13851)
• NPWMD (Weapons of Mass Destruction Proliferators Sanctions Regulations, 31 C.F.R. part 544)
• PEESA-EO14039 (Executive Order 14039)
• SDGT (Global Terrorism Sanctions Regulations, 31 C.F.R. part 594)
• SYRIA (Executive Order 13338; EO 13399; EO 13460; EO 13572; EO 13573; EO 13582)
• SYRIA-CAESAR (Sections 7404-7438 of the National Defense Authorization Act for Fiscal Year 2020, Title LXXIV—Caesar Syria Civilian Protection Act of 2019​​)
• TCO (Transnational Criminal Organizations Sanctions Regulations, Executive Order 13581)
• VENEZUELA-EO13850 (Executive Order 13850)

The database separately identifies legal entities subject to U.S. export restrictions, including those on the Entity List (EL) and Military End User List (MEU List) of the Bureau of Industry and Security (BIS) of the U.S. Department of Commerce.

Despite the broad scope of the U.S. sanctions and their importance in maintaining pressure on Russia, many legal entities still need to be added to the lists. 

One of the main objectives of sanctions is to impede Russia's military-industrial complex, making it difficult to produce modern weapons in the numbers required for warfare.

An important role in this is played by the general export restrictions on the supply of military and dual-use goods to Russia. But it is equally important that all Russian military-industrial enterprises are included in the sanctions lists of all countries of the "sanctions coalition."

Synchronizing partners' sanctions against Russian companies and other entities is crucial for deterring Russia's military potential. We hope the United States will join in sanctioning legal entities already targeted by Ukraine, the EU, the UK, and Canada.

With that in mind, we hope that the US will also join the sanctions against legal entities already imposed by Ukraine, the EU, the UK, and Canada.

Examples include:

JSC Aerospace Equipment Corporation, one of the largest Russian companies in the field of military aviation equipment, air defense and missile systems, etc. As part of Rostec, it has been actively growing during the war, taking in 2023 over two large enterprises: JSC Sapsan Research and Production Center (sanctioned) and JSC Auto Components and Equipment.

JSC Research and Production Enterprise Krasnoznamenets, a manufacturer of weapons and ammunition, part of the Rostec State Corporation

JSC Garnison Holding (until 2014 -- OJSC Oboronservis), manages the activities of a number of military enterprises, such as: JSC Oboronenergo, JSC Voentorg, JSC Voentelecom, and JSC Main Directorate for the Arrangement of Troops.

JSC Scientific and Technical Center for Industrial Technologies and Aeronautical Systems (STC Promtehaero), engaged in the development and production of aviation equipment.

JSC Universalmash Plant, manufacturer of wheeled and tracked military vehicles.

JSC S.A. Afanasyev NPO Technomash, a subsidiary of Roscosmos engaged in the military R&D.

JSC Ulyanovsk Instrumentation Design Bureau, an aviation instrumentation company servicing military aviation, and others.

 

EU Sanctions

EU sanctions are regulated by several Council Decisions and Regulations, that are amended each time new sanctions packages are adopted.

Our database includes all legal entities subject to EU sanctions related to Russian aggression, as defined by the following EU Regulations:

• №269/2014 of 17 March 2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine;
• № 692/2014 of 23 June 2014 concerning restrictive measures in response to the illegal annexation of Crimea and Sevastopol;
• № 833/2014 of 31 July 2014 concerning restrictive measures in view of Russia's actions destabilising the situation in Ukraine.

There are also Belarusian companies and Russian legal entities that are subject to EU sanctions due to cyberattacks and human rights violations. See regulations:

• № 765/2006 of 18 May 2006[1] concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine;
• № 2019/796 of 17 May 2019 concerning restrictive measures against cyber-attacks threatening the Union or its Member States;
• № 2020/1998 of 7 December 2020 concerning restrictive measures against serious human rights violations and abuses.

The EU position on supporting Ukraine and strengthening its influence over Russia has evolved since the start of the war.

While in late 2022, concerns about exhaustion of the sanctions' potential were voiced, in 2023-24, the realization of the Russian threat to Europe has grown, not in the least due to the US elections. However, that still hasn't had a sufficient impact on the scope and procedures for the sanctions enactment.

Between our previous review and November 1, 2024, 297 legal entities were added to EU sanctions lists. 

European sanctions against legal entities continue to account for about 11% of the total number of sanctioned entities.

Organizational issues, particularly the influence in decision-making of states under effective Russian control -- primarily, Hungary – continue to hinder the EU sanctions expansion.

However, handling of the issues not requiring political consensus have somewhat improved, as seen in the resolution of the entity identification problem we had previously raised. Thanks to the Regulation 2024/1745, Annex IV of Council Regulation (EU) No. 833/2014 concerning entities that are end military users, are part of the Russian military-industrial complex or have commercial or other links with and/or otherwise support the Russian defense and security sector, has been completely revised.

Currently, the EU is finalizing a new, 15th sanctions package. This is a positive development, as many legal entities still lack EU restrictions.

Examples include:

Lukoil's gas station and refinery networks that still operate in Europe.
 

Russian companies directly manufacturing weapons using European technological equipment, such as:

JSC Research Institute of Physical Measurements, that uses machines from Germany, France, Austria, the Czech Republic, and the Netherlands to produce components for cruise missiles X-101, X-59, Su aircraft, Ka helicopters, and intercontinental ballistic missiles.

JSC Research and Production Corporation Space Monitoring Systems, Information Control and Electromechanical Complexes named after A.G. Yosifyan that manufactures military satellites using equipment from Germany, Italy, and the Czech Republic

JSC NPO Energomash named after Academician V.P. Glushko, that manufactures liquid missile engines using machinery from Germany and Italy.

JSC Semikhatov Automation Research and Production Association, that manufactures intercontinental ballistic missiles using an SP-280Y lathe from KOVOSVIT MAS from the Czech Republic.

JSC Mytishchinsky Machine-Building Plant, that manufactures tracked chassis for military vehicles using German VDF Boehringer machines (FFG Group).

OJSC UDK-Ufa Motor-Building Production Association, that manufactures components for military aircraft using German machines from Trumpf, Walter Maschinenbau, Hermle, KNUTH Werkzeugmaschinen, and others.

Eventually, the EU will need to cease all business operations with the aggressor country enterprises, including servicing previously sold equipment and software updates, because no one knows where the next missile made on the European equipment will fly.

 

Canada's Sanctions

The database contains legal entities subject to sanctions according to Special Economic Measures Regulations adopted in 2014-2020 under the Special Economic Measures Act.

• Special Economic Measures (Russia) Regulations , 2014-03-17
• Special Economic Measures (Belarus) Regulations, 2020-09-28
• Special Economic Measures (Ukraine) Regulations, 2014-03-17. These are sanctions concerning the occupied territories and persons involved in the occupation.

As of November 1, Canada's sanctions accounted for 7.4% of the total sanctions against legal entities. Since September 1, 2023, only 191 companies have been added to the list.

However, the fact that Canada's sanctions list contains only the companies' names, creates an evasion loophole easily accomplished by simply changing it.

For instance,

on February 21, 2024, Canada imposed sanctions on JSC Russian Helicopter Systems. By March 06, 2024, the company had changed its name to JSC RVS. While the legal entity remains the same, with identical details and address, those relying on official Canadian documents might conclude that the sanctioned company no longer exists, as the list provides no identification information beyond the name.

Similarly, on February 23, 2023, sanctions were imposed on the United Machine-Building Group (listed as Obedinennaya Mashinostroitelnaya Gruppa). Since October 17, 2023, however, it has been operating as Uralaz Production Association LLC.

Another example is JSC Concern Radio Engineering and Information Systems, which appeared on Canada's sanctions list on March 10, 2022. The company has since changed its name twice. From February 6, 2023, to June 18, 2024, it was known as JSC Research and Production Association of Long Range Radar. Currently, the legal entity is called JSC Research and Production Association of Long-Range Radar named after Academician A.L. Mints.

 

UK Sanctions

The UK Sanctions List comprises the EU lists that had existed before December 31, 2020, and entities subject to UK sanctions post-Brexit. The pre-existing European sanctions were transformed under the 2018 Sanctions and Anti-Money Laundering Act, becoming part of the UK sanctions registrars alongside the new British sanctions.

The database includes all legal entities listed on the UK sanctions list under the Russia (Sanctions) (EU Exit) Regulations 2019.

It also contains several legal entities from other lists, including:

• Republic of Belarus (Sanctions) (EU Exit) Regulations 2019
• Iran (Sanctions) (Nuclear) (EU Exit) Regulations 2019
• Syria (Sanctions) (EU Exit) Regulations 2019
• Cyber (Sanctions) (EU Exit) Regulations 2020
• Chemical Weapons (Sanctions) (EU Exit) Regulations 2019

Despite the UK's significant role in supporting Ukraine against Russian aggression, British sanctions against legal entities remain relatively limited.
 

Sanctions are in place. What's next?

Alas, imposing sanctions on an company is not a one-time deal. Beyond the challenge of monitoring compliance, while some sanctions have been enacted over a decade ago, the affected businesses certainly do not remain static.

For instance, some sanctioned companied have been liquidated for various reasons, whether due to sanctions or ineffective management. That, however, doesn't preclude the emergence of related firms or even entirely new enterprises based on the production facilities of the formerly sanctioned ones. 

As of November 1, 2024, the database contained 449 non-functioning enterprises.

Sometimes, liquidation of a legal entity occurs during its reorganization – whether driven by the market needs or in an attempt to evade sanctions – often resulting in the entity's removal from the sanctions lists.

Examples include:

The Federal State Unitary Enterprise The Order of Lenin and the Order of the Red Banner of Labor Research Institute of Synthetic Rubber named after Academician S.V. Lebedev that was sanctioned by the US on May 19, and by Ukraine -- May 27, 2023. Two weeks later, on June 14, the enterprise was liquidated. Its successor, the Federal State Budget Institution The Order of Lenin and the Order of the Red Banner of Labor Research Institute of Synthetic Rubber named after Academician S.V. Lebedev (ODNR: 1237800068439) remains sanction-free.

Avia Group LLC, operating since 2006, that in 2010 became the founder of Avia Group Nord LLC. Both companies have been under numerous sanctions since 2014. On September 11, 2020, Avia Group Nord LLC ceased operations, merging with Avia Group LLC. On April 1, 2021, Avia Group LLC was liquidated, with its successor, Avia Group Non-Public JSC, currently under Ukrainian sanctions only. On September 11, 2023, the latter established JSC Avia Group Nord Non-Public (ODRN: 1235000111940), that still remains under the sanctions radar.

The above is but a small part of the chain of transformations of Putin's friend Gennady Timchenko former (?) properties that have been uncovered.

Sometimes, sanctions decrees mistakenly mention legal entities that no longer exist but have legal successors. 

For instance:

The Federal State Unitary Enterprise State Research Institute of Aviation Systems was sanctioned by the US on June 28, and by Ukraine on October 19, 2022. Unfortunately, a non-existent company was listed on both the US and Ukrainian sanctions lists because since March 1, 2022, it had become not a "Federal State Unitary Enterprise" but a "Federal Autonomous Institution". Thus, this is a new, different legal entity with new details. Legally, it is free from US and Ukrainian sanctions.

On April 7 and June 3, 2022, JSC Research and Production Enterprise Vostok, that had been liquidated on February 18, 2020, fell under export restrictions from the US and the EU, respectively. While its successor, JSC Novosibirsk Semiconductor Device Plant Vostok, is currently subject to Ukrainian, US and Canadian sanctions, it's still not under the export restrictions imposed on its predecessor.

Zvezda-Strela LLC of the Tactical Missile Arms Corporation had been liquidated on March 30, 2021 – long before the US imposed export restrictions on it on April 07, 2022. Its current successor is Zvezda-Strela JSC.

Unmanned Systems Roboavia LLC was included in the US sanctions lists on June 12, 2024, despite the fact that the company had ceased to exist on June 30, 2023 with no official successor. Here, though, the most likely reason was a mistake in the enterprise identification, because the lists should've included Roboavia LLC, that is actually engaged in manufacturing of the drone systemsю

These examples underscore the need for ongoing work with the sanctions lists, as well as for the careful monitoring of all further developments with the sanctioned enterprises, even though the latter is becoming more and more challenging as Russia increasingly conceals information.

At the same time, we can't limit our joint effort to only the existing measures.

To ensure the effectiveness of restrictions on Russia, sanctions against legal entities must be both synchronized among all the "sanctions coalition" partners and considerably expanded. 

Russia, in its current form, won't stop being a threat to Europe and the world – that would be impossible even due to the economic factors alone. No "truce" or "ceasefire" that some now hope for, will deter Russia from accumulating military resources in preparation for further aggression.

So, if the goal is to, at the very least, prevent military production by the Russian Federation, the process of identifying relevant legal entities and applying sanctions must continue at full speed. Exposing and restricting every enterprise directly or indirectly related to the Russian military-industrial complex or war financing is crucial in preventing the aggressor from producing modern weapons of the qualities and in the quantities required for warfare.

* * *

 

The publication has been created with the support of the Europe and the World Program of the International Renaissance Foundation. The position of the International Renaissance Foundation does not necessarily reflect the opinion of the authors.