Guns for Gold: The Wagner Network Exposed/Appendix 1: Sanctions comparisons for the UK, United States and European Union

4381219Guns for Gold: The Wagner Network Exposed2023the Foreign Affairs Committee

Appendix 1: Sanctions comparisons for the UK, United States and European Union rule

These Tables have been prepared by analysing the sanctions lists and decisions of the United States, European Union and United Kingdom, as of 7 July 2023.[1] The below individuals and entities have been identified due to the explicit links drawn to Prigozhin, Wagner or Prigozhin-linked entities in the designation of one or more jurisdictions. The analysis is not intended to be exhaustive. Every effort has been made to ensure the accuracy of this information as of 7 July 2023, via cross-checks and the additional use of sanctions comparison resources.[2]

Sanctions comparisons for 44 individuals sanctioned for their association with Prigozhin and/or the Wagner Group in the US, the EU and/or the UK

Name of sanctioned individual, starting with surname (with supporting information from the time of designation)[3] Sanction by the US? Sanction by EU? Sanction by UK?
AFANASYEVA, Yulia. Afanasyeva, an employee of the “Africa Back Office,” ran AFRIC and the International Anticrisis Center “(US designation). Yes No No
BEZRUKIKH, Dmitriy Nikolaevich.

A Russian official at the rank of colonel, equivalent or higher, involved in allowing Prigozhin to recruit soldiers from prisons in Rostov, leading to suspected involvement in destabilising activities in Ukraine. (UK designation)

Yes No Yes
BICHKOV, Peter Alexandrovich (a.k.a. BYCHKOV, Petr Alexandrovich; a.k.a. BYCHKOV, Pyotr Aleksandrovich).

He manages Prigozhin’s “Africa Back Office,” a team of political consultants tasked with devising strategies for manipulating African politics in support of Prigozhin’s interests (U.S. designation).

Yes No No
BOGATOV, Andrei Mikhailovich.

Sanctioned for his involvement as a commander in Wagner activities in Syria || Example || Example

No Yes No
Name of Sanctioned individual, starting with surname

(with supporting information from time of designation)[354]
Sanction by US? Sanctioned by EU? Sanctioned by UK?
DJUMA, Abbas (a.k.a. DZHUMA, Abbas, a.k.a. DZHUMA, Abbas Mokhammadovich).

Involved in PMC Wagner’s acquisition of Iranian UAVs to support combat operations in Ukraine (U.S. designation)
Yes No No
DYCHKO, Stanislav Evgenievitch.

Wagner mercenary who took part in the torture of a Syrian deserter in 2017 (EU designation under the human rights regime)
No Yes No
ELIZAROV, Anton Olegovich.

Wagner commander in Ukraine (EU designation)
No Yes No
GASPARYAN, Hayk Arsenovich

Wagner commander in Ukraine (EU designation)
No Yes No
GERGES, Fawaz Mikhail.

CEO of Al-Sayyad Company for Guarding and Protection Services in Syria, a company supervised by Wagner (EU designation)
No Yes Yes
GOSTEV, Arkadiy Aleksandrovich.

A Russian official at the rank of colonel, equivalent or higher, involved in supporting the recruitment of soldiers to the Wagner Network, thus supporting destabilising activities in Ukraine (UK designation)
Yes No Yes
IBRAHIM, Yasar Hussein.

Co-owner of Al-Sayyad Company for Guarding and Protection Services Ltd, a Syrian private security company supervised by the Wagner Group in Syria, active in the protection of Russian interests (phosphates, gas and securing oil sites). The company recruits Syrian mercenaries to Libya and Ukraine (EU designation)
Yes Yes Yes
IVANOV, Aleksandr Aleksandrovich (a.k.a. IVANOV, Alexander).

Wagner representative in CAR; director of OUIS (U.S. and EU designations)
Yes Yes No
IVANOV, Andrey Nikolayevich.

A Wagner executive who, during spring 2023, worked closely with Prigozhin’s entity Africa Politology and senior Malian government officials on weapons deals, mining concerns, and other Wagner Group activities in Mali (U.S. designation).
Yes No No
Name of sanctioned individuals, starting with surname
(with supporting information from the time of designation)[334]
Sanctioned by the US? Sanctioned by the EU? Sanctioned by the UK?
KHARITONOV, Denis Yurievich

Deputy regional head of the Astrakhan branch of the Union of Donbass Volunteers, member of Duma of Astrakhan Oblast and Wagner Group mercenary, sanctioned for activities in Ukraine (EU designation)

No Yes No
KHODOTOV, Yevgeniy Garryevich (a.k.a. KHODOTOV, Yevgeny).

Served as the director of Lobaye Invest. Involved in Prigozhin’s CAR operations since 2017 (U.S. designation)

Yes No No
KUZIN, Aleksandr Yuryevich (a.k.a. KUZIN, Alexander).

Prigozhin’s employee operating in CAR, who has been been involved in Prigozhin’s CAR operations since 2017 (U.S. designation).

Yes No No
KUZNETSOV, Alesandr.

Involved in Wagner activities in Libya (EU designation)

No Yes No
LAVRENKOV, Igor Valerievich.

Director and owner of Shine Dragon Group Limited (U.S. designation)

Yes No No
MALKEVICH, Alexander Aleksandrovich.

His company, the Foundation for National Values Protection (FZNC), facilitated Prigozhin’s global influence operations since at least 2019. (U.S. designation)

Yes Yes Yes
MALOLETKO, Aleksander Grigorievitch

A close collaborator of Yevgeny Prigozhin. He has been working as an instructor for the Wagner Group in the Central African Republic (CAR). He is associated with Wagner, listed for serious human rights abuses in several countries, including in CAR, and is responsible for supporting the acts of the Wagner Group. (EU designation)

No Yes Yes
MALYAREVICH, Aleksei Alekseevich

Linked to Charter Green Light: see entities table below (U.S. designation).

Yes No No
MANDEL, Andrei Sergeevich.

M Invest’s Director General (U.S. designation)

Yes Yes No
Name of sanctioned individuals, starting with surname
(with supporting information from the time of designation)[334]
Sanctioned by the US? Sanctioned by the EU? Sanctioned by the UK?
MASLOV, Ivan Aleksandrovich (a.k.a. “MASLOV, Ivan Oleksandrovich”).

Head of ‘Wagner’ paramilitary units and principal administrator in Mali (U.S. designation)

Yes Yes No
PERFILEV, Vitalii.

Wagner operative in CAR (EU designation).

No Yes No
PETROVSKIY, Yan Igorovich

Head of the ‘Rusich’ military taskforce that is linked to Wagner (EU designation)

Yes Yes No
PIKALOV, Konstantin

Wagner Commander in the CAR (EU designation)

No Yes No
POTEPKIN, Mikhail Sergeyevich

Ex-employee of the Internet Research Agency, M Invest’s and Meroe Gold’s Regional Director based in Sudan (U.S. designation).

Yes Yes No
PRIBYSHIN, Taras.

Pribyshin has conducted influence operations in Africa for the Internet Research Agency in support of Prigozhin’s objectives in the region since at least 2019 (U.S. designation).

Yes No No
PRIGOZHIN, Evgeny (a.k.a. PRIGOZHIN, Yevgeniy Viktorovich).

Founder and financier of the Wagner Group/Network

Yes Yes Yes
PRIGOZHIN, Pavel Evgenyevich

Prigozhin’s family facilitates the activities of his enterprise, which benefits from his favored status within Russia’s elite. Pavel Prigozhin is his son. (U.S. designation).

Yes Yes Yes
PRIGOZHINA, Lyubov Valentinovna.

Prigozhin’s family facilitates the activities of his enterprise, which benefits from his favored status within Russia’s elite. Lyubov Prigozhina (Lyubov) is Prigozhin’s wife. (U.S. designation).

Yes Yes Yes
PRIGOZHINA, Polina Evgenyevna.

Prigozhin’s family facilitates the activities of his enterprise. Polina Prigozhina (Polina) is his daughter (U.S. designation).

Yes No Yes
Name of sanctioned individuals, starting with surname
(with supporting information from the time of designation)[334]
Sanctioned by the US? Sanctioned by the EU? Sanctioned by the UK?
PRIGOZHINA, Violetta Kirovna

The mother of Yevgeniy PRIGOZHIN. There are reasonable grounds to suspect that Violetta Kirovna PRIGOZHINA is associated with Yevgeniy Viktorovich PRIGOZHIN, and has obtained a financial benefit or other material benefit from him. (UK designation)

No Yes Yes
PROKOPENKO, Ivan Pavlovitch

A Russian official at the rank of colonel, equivalent or higher, involved in supporting the recruitment of soldiers to the Wagner Network and thus supporting destabilising activities in Ukraine (UK designation).

Yes No Yes
SHAMMOUT, Abu Hani

A former Syrian military officer charged by Wagner Group to recruit veterans as mercenaries (EU designation).

No Yes Yes
SHCHERBAKOY, Sergey Vladimirovich

Freelance employee of GRU and Wagner mercenary in Ukraine (EU designation)

No Yes No
SHUGALEY, Maxim

Conducts pro-Wagner propaganda (EU designation)

No Yes No
SRABIONOY, Tigran Khristoforovich

Involved in Wagner's acquisition of Iranian UAVs to support combat operations in Ukraine (U.S. designation)

Yes No No
SYTII, Dmitry (a.k.a. SYTII, Dmitry Sergeevich (a.k.a. SYTYI, Dmitry)

Prigozhin’s employee and the founder of Lobaye Invest. Sytii has also worked for the Internet Research Agency. Involved in Prigozhin’s CAR operations since 2017 (U.S. designation)

Yes Yes No
TENSIN, Alexey.

Director of joint-stock company ‘PMC Wagner Centre’ (EU designation)

No Yes No
TRONIN, Alexander.

Founder and curator of a young wing of Wagner, operating on the premises of ‘PMC Wagner Centre’. (EU designation).

No Yes No
Name of sanctioned individuals, starting with surname
(with supporting information from the time of designation)[334]
Sanctioned by the US? Sanctioned by the EU? Sanctioned by the UK?
TROSHEV, Andrey Nikolaevich

Commander in the Wagner Group and involvement in destabilising activities in Syria (UK designation)

No Yes Yes
UTKIN, Dmitriy Valeryevich.

Commander of the Wagner Network involved in actions threatening the territorial integrity of Ukraine (UK designation).

Yes Yes Yes
ZAKHAROV, Valerii (a.k.a. ZAKHAROV, Valery Nikolayevich)

Former FSB, security counsellor to CAR President (at time of designation) and key figure in Wagner command structure, sanctioned under the EU’s human rights regime (EU designation).

Yes Yes No
Sanctions comparisons for 37 entities sanctioned for their association with Prigozhin and/or the Wagner Group in the US, EU and/or UK
Name of entity, with supporting information from the time of designation[4] Designated by US? Designated by EU? Designated by UK?
224TH FLIGHT UNIT STATE AIRLINES

(a.k.a. JOINT STOCK COMPANY THE 224TH FLIGHT UNIT STATE AIRLINES; a.k.a. JSC THE 224TH FLIGHT UNIT STATE AIRLINES; a.k.a. LYOTNY OTRYAD 224; a.k.a. OJSC GOSUDARSTVENNAYA AVIAKOMPANIYA 224 LETNY OTRYAD; a.k.a. TTF AIR HEAVY LIFTING; a.k.a. “224 FU JSC”; a.k.a. “224TH FLIGHT UNIT”; a.k.a. “OAO 224 LO”).

Listed as linked to Wagner in the designation (U.S. designation)

Yes No No
AFRICA POLITOLOGY.

Owned or controlled by, or for having acted or purported to act for or on behalf of, directly or indirectly, Yevgeniy Prigozhin. Africa Politology develops strategies and mechanisms to induce Western countries to withdraw their presence in Africa and is involved in a series of Russian influence tasks in the Central African Republic, to include undermining Western influence, discrediting the UN, and carrying out lawsuits against Western press outlets. (U.S. designation)

Yes No No
AL-SAYYAD COMPANY FOR GUARDING AND PROTECTION SERVICES LTD

Also known as ‘ISIS Hunters’, this is a Syrian private security company overseen by Wagner (EU designation)

No Yes No
Name of entity, with supporting information from the time of desgination[335] Designated by US? Designated by EU? Designated by UK?
ASSOCIATION FOR FREE RESEARCH AND INTERNATIONAL COOPERATION (a.k.a. “AFRIC”)

The Association For Free Research And International Cooperation (AFRIC), [...] facilitate[s] Prigozhin’s malign operations in Africa and Europe while primarily operating from Russia. AFRIC has served as a front company for Prigozhin’s influence operations in Africa, including by sponsoring phony election monitoring missions in Zimbabwe, Madagascar, the Democratic Republic of the Congo, South Africa, and Mozambique. Despite posing as an African-led initiative, AFRIC serves to disseminate Russia’s preferred messaging, often related to disinformation. AFRIC works in coordination with other elements of the Prigozhin network, including FZNC and the International Anticrisis Center, a fraudulent think tank controlled by Prigozhin’s operatives. (U.S. designation)
Yes No No
CHANGSHA TIANYI SPACE SCIENCE AND TECHNOLOGY RESEARCH INSTITUTE CO. LTD (SPACETY CHINA).

A People’s Republic of China (PRC)-based entity that has provided Terra Tech synthetic aperture radar satellite imagery orders over locations in Ukraine. These images were gathered in order to enable Wagner combat operations in Ukraine (U.S. designation)
Yes No No
CHARTER GREEN LIGHT MOSCOW

Operating or has operated in the aerospace sector of the Russian Federation economy. Charter Green Light is an aircraft charter service that offers VIP, group, cargo, and helicopter charters based in Moscow, Russia. It has been reported that it is the preferred company of the Wagner Group, which uses its charter planes to transport Wagner personnel and equipment. (U.S. designation)
Yes No No
CHINA HEAD AEROSPACE TECHNOLOGY COMPANY (a.k.a. CHINA HEAD TECHNOLOGY CO; a.k.a. HEAD AEROSPACE GROUP)

A PRC-based satellite image reseller that supplied satellite imagery of locations in Ukraine to entities affiliated with PMC Wagner and Yevgeniy Prigozhin. (U.S. designation)
Yes No No
Name of entit, with supporting information deom the time of desgination[335] Designated by US Designated by EU? Designated by UK?
DIAM VILLE (a.k.a. DIAMVILLE; a.k.a. DIAMVILLE COMPANY; a.k.a. DIAMVILLE SAU; a.k.a. DIAMVILLE SAUAG)

A gold and diamond purchasing company based in the CAR and controlled by Prigozhin. Diamville is one of several Prigozhin-connected entities that is intimately involved in the CAR mining sector. In 2022, Diamville participated in a gold selling scheme that entailed converting CAR-origin gold into U.S. dollars. Following the imposition of U.S. sanctions on several Russian financial institutions, participants in the scheme planned to move the proceeds by transferring cash by hand. Additionally, Diamville shipped diamonds mined in the CAR to buyers in the UAE and in Europe. (U.S. designation)

Yes Yes No
EVRO POLIS LTD. (a.k.a. EVRO POLIS)

A Russian company that has contracted with the Government of Syria to protect Syrian oil fields in exchange for a 25 percent share in oil and gas production from the fields. Evro Polis Ltd. is being designated for being owned or controlled by Yevgeniy Prigozhin, (U.S. designation)

Yes Yes Yes
FEDERAL STATE GOVERNMENTAL INSTITUTION 223 FLIGHT UNIT STATE AIRLINES OF THE MINISTRY OF DEFENSE OF THE RUSSIAN FEDERATION (a.k.a. 223RD STATE AIRLINE FLIGHT UNIT; a.k.a. FGBU GAK 223 LETNYI OTRYAD MO RF; a.k.a. FGBU GOSUDARSTVENNAYA AVIAKOMPANIYA 223 LETNYY OTRYAD MO RF (Cyrillic: ФГБУ ГОСУДАРСТВЕННАЯ АВИАКОМПАННЯ 223 ЛЕТНЫЙ ОТРЯД МО РФ); a.k.a. “223RD FLIGHT DETACHMENT”; a.k.a. “223RD FLIGHT UNIT”).

Wagner-linked entity (U.S. designation)

Yes No No
Name of entity, with supporting information from the time of designation[335] Designated by US? Designated by EU? Designated by UK?
INDUSTRIAL RESOURCES GENERAL TRADING (a.k.a. INDUSTRIAL RESOURCES GENERAL TRADING LLC)

A Dubai-based industrial goods distributor that has provided financial support to Prigozhin through its business dealings with Diamville. Industrial Resources also participated in the aforementioned gold selling scheme. Following U.S. sanctions on various Russian financial institutions, Industrial Resources wittingly participated in the transfer by hand of cash to Russia. Industrial Resources works with Diamville to generate revenue and move funds for Prigozhin. (U.S. designation)

Yes No No
INTERNATIONAL ANTICRISIS CENTER.

A fraudulent think tank controlled by Prigozhin’s operatives (U.S. designation)

Yes No No
JOINT STOCK COMPANY RESEARCH AND PRODUCTION CONCERN BARL (AO BARL).

A Russian space company supporting Russia’s military activities in Ukraine. AO BARL has shared foreign high-resolution satellite imagery with Russia’s military. It is listed in a section on entities and individuals that have supported Wagner’s military operations. (U.S. designation)

Yes No No
KRATOL AVIATION (a.k.a. KRATOL AVIATION COMPANY; a.k.a. KRATOL AVIATION ‘FZC’).

A UAE-based aviation firm. Wagner uses Kratol-provided aircraft to move personnel and equipment between the CAR, Libya, and Mali. (U.S. designation)

Yes No No
LIMITED LIABILITY COMPANY DM

Limited Liability Company DM (OOO DM) is a Russia-based firm that also participated in the aforementioned gold selling scheme (see Diam Ville above). (U.S. designation)

Yes No No
LOBAYE INVEST (a.k.a. LOBAYE INVEST SARL; a.k.a. LOBAYE INVEST SARLU)

Mining company linked to Prigozhin’s operations in CAR (U.S. designation)

Yes Yes No
Caption text
Name of entit, with supporting information deom the time of desgination[335] Designated by US Designated by EU? Designated by UK?
M FINANS (a.k.a. M-FINANCE LLC; a.k.a. M-FINANS OOO).

A mining company under sanction linked to Wagner’s operations in CAR. (U.S. designation)

Yes No No
M INVEST.

Involved in furthering Prigozhin’s operations in Sudan and owned or controlled by Prigozhin. Serves as a cover for PMC Wagner forces operating in Sudan (U.S. designation)

Yes Yes No
MERCURY LLC.

An oil and gas company in Syria, involved in supporting or benefiting from the Syrian regime and associated with Prigozhin (UK designation)

No Yes Yes
MEROE GOLD CO. LTD.

A subsidiary of M Invest in Sudan (U.S. designation).

Yes Yes No
MIDAS RESSOURCES

(a.k.a. MIDAS RESSOURCES LIMITED LIABILITY; a.k.a. MIDAS RESSOURCES MINING COMPANY; a.k.a. MIDAS RESSOURCES SARLU; a.k.a. MIDAS RESSOURCES SURL; a.k.a. MIDAS SURL; a.k.a. “MIDAS RESOURCES”)

Owned or controlled by, or for having acted or purported to act for or on behalf of, directly or indirectly, Prigozhin (U.S. designation).

Yes No No
OFFICER’S UNION FOR INTERNATIONAL SECURITY (a.k.a. SODRUZHESTVO OFITSEROV ZA MEZHDUNARODNUYU BEZOPASNOST; a.k.a. “OUIS”)

Involved in Wagner’s CAR operations. It is a front company that claims to represent Russian “instructors” in CAR. Starting in 2021, Wagner used OUIS to obscure an increase of Wagner Group personnel operating in CAR. (U.S. designation)

Yes No No
PATRIOT MEDIA GROUP No Yes No
Name of entity, with supporting information from the time of designation[335] Designated by US? Designated by EU? Designated by UK?
PMC WAGNER (a.k.a. CHASTNAYA VOENNAYA KOMPANIYA ‘VAGNER’; a.k.a. CHVK VAGNER; a.k.a. PRIVATE MILITARY COMPANY ‘WAGNER’; a.k.a. WAGNER GROUP (Cyrillic: ГРУППА ВАГНЕРА)).

A private military company that has recruited and sent soldiers to fight alongside separatists in eastern Ukraine. Responsible for or complicit in, or having engaged in, directly or indirectly, actions or policies that threaten the peace, security, stability, sovereignty, or territorial integrity of Ukraine (U.S. designation).

Yes Yes Yes
PRIME SECURITY AND DEVELOPMENT (a.k.a. PRIME SECURITY AND DEVELOPMENT JSC)

Owned or controlled by, or for having acted or purported to act for or on behalf of, directly or indirectly, Wagner. Has acted as a Wagner front company and its Director General has represented Wagner in discussions with African governments. (U.S. designation)

Yes No No
RADIO LENGO SENGO

A Central African radio station conducting disinformation campaigns and promoting Wagner’s presence in CAR (EU designation)

No Yes No
RIA FAN MEDIA GROUP

Prigozhin-linked media group (EU designation)

No Yes No
RUSICH MILITARY GROUP.

Linked to Wagner (EU designation).

Yes Yes No
SEWA SECURITY SERVICES (Latin: SEWA SÉCURITÉ SERVICES).

A CAR-based security company controlled by the Wagner Network that provides protection for senior CAR government officials. Sewa has also claimed to provide “instructors” for “training exercises” in CAR. (U.S. designation)

Yes Yes No
Name of entity, with supporting information from the time of designation [335] Designated by US? Designated by EU? Designated by UK?
SHEN YANG JING CHENG MACHINERY IMP&EXP. CO.

Designated for having materially assisted Prigozhin. Owned by Shine Dragon Group Limited. Involved in facilitating over 100 transactions exceeding $7.5 million that were sent in the interest of Prigozhin" (U.S. designation)

Yes No No
SHINE DRAGON GROUP LIMITED.

Designated for having materially assisted Prigozhin. Involved in facilitating over 100 transactions exceeding $7.5 million that were sent in the interest of Prigozhin (U.S. designation)

Yes No No
SPACETY LUXEMBOURG S.A. (SPACETY LUXEMBOURG).

Spacety China's Luxembourg-based subsidiary, mentioned among companies that had support Wagner's military operations (U.S. designation)

Yes No No
THE FOUNDATION FOR NATIONAL VALUES PROTECTION (Cyrillic: ФОHДА ЗАЩИТЬІ HАЦИОНАЛЬНЬІХ ЦЕHHОСТЕЙ) (a.k.a. "FZNC").

Alexander Malkevich (Malkevich) and his company, the Foundation for National Values Protection (FZNC), have facilitated Prigozhin's global influence operations since at least 2019. (U.S. designation)

Yes Yes No
VELADA LLC.

An oil and gas company in Syria, involved in supporting or benefiting from the Syrian regime and associated with Prigozhin (UK designation).

No Yes Yes
ZHE JIANG JIAYI SMALL COMMODITIES TRADE COMPANY LIMITED.

Designated for having materially assisted Prigozhin. Owned by Shine Dragon Group Limited. Involved in facilitating over 100 transactions exceeding $7.5 million that were sent in the interest of Prigozhin (U.S. designation)

Yes No No
Caption text
Name of entity, with supporting information from the time of designation [335] Designated by US? Designated by EU? Designated by UK?
“PMC Wagner Centre”.

A Russian commercial venture, aiming to support private sector investment and innovation to support and bolster Russia’s defence capabilities, with close links to the unincorporated ‘PMC Wagner Group’. (EU designation)

No Yes No
  1. UK Government, The UK Sanctions List (ODT format accessed 7 July 2023); Office of Foreign Assets Control,Specially Designated Nationals and Blocked Persons List, 29 June 2023 (PDF accessed 7 July 2023); separate EU decisions.
  2. For example, Ukrainian Government, Personal sanctions tracker: War and sanctions (accessed 17 July 2023)
  3. U.S. designation information is drawn from the Treasury press releases.
  4. U.S. designation information is drawn from the supporting Treasury press releases.