Guns for Gold: The Wagner Network Exposed/Responses to the Wagner Network

by the Foreign Affairs Committee

2 Responses to the Wagner Network

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The UK’s general response

33. In February, the Minister told us that “we must treat [the Wagner Network] very seriously as a destabilising threat”.^[1] The UK Government’s response focuses on Ukraine, which is the Wagner Network’s “main theatre of operations”.^[2] The Minister called the UK’s lethal aid and support to the Ukrainian military “front and centre of our effort”.189^[3]As of 23 May 2023, the UK was the second largest donor of military assistance to Ukraine and had committed £4.6 billion so far.^[4] Calling it “gruesome”, Christo Grozev of Bellingcat told us that “Ukraine is doing part of the job for all of us now” by killing so many Wagner fighters on the battlefield.^[5]

34. In addition to defence support to Ukraine, the UK is responding to the Wagner Network via:

•sanctions (see paragraphs 43–61),

•bilateral and multilateral diplomacy,^[6] including work with partner states on “nation building and investing in institutions”;^[7]

•ministerial statements^[8]of condemnation;^[9] and

•tracking activity by the Ministry of Defence and the Foreign Office.^[10]

The UK has also committed to [emphasis added]:

a new approach to countering state threats below the threshold of armed conflict, organising cross-government activity into four lines of effort: protecting ourselves, our allies and partners from the impact of this activity; engaging domestically and internationally to raise awareness of it and to deepen cooperation on countering it; building a deeper understanding of states’ activity and how to respond effectively; and competing directly with these states in creative and assertive ways, when appropriate.^[11]

The details of this new approach are not yet clear. Some aspects of the UK response are unlikely to be public, for example, activity to counter malign Russian disinformation.^[12]

A focus on Ukraine, not Africa

35. Given that Ukraine is “front and centre”, we asked the Department at what point the network’s activities in other countries should become a point of interest for the UK Government, given the negative effects of its presence and the likely use of resources from African operations to fund Russia’s renewed illegal invasion of Ukraine. The FCDO did not directly answer. Instead, it re-emphasised the use of sanctions and noted:

We are stepping up what we are doing inside Government on this. We have, frankly, much more activity inside Government aimed at understanding Wagner and trying to take steps against it than we did six months ago.^[13]

36. Mikhail Khodorkovsky—a Russian dissident, former senior businessman, and the founder of the Dossier Center—suggested that the UK and its allies under-estimated the significance of the network’s activities in Africa.^[14] In some cases, it is not clear that the disruptive and destabilising influence of the Wagner Network has informed important decisions over the UK’s policy towards specific countries and regions:

• In March 2021, wider aid cuts led to the premature ending of a £2.6 million UK-funded programme designed to foster stability in Sudan,^[15] a country where the Wagner Network had been involved since 2017. We disagree with the Foreign Secretary that there is no connection between ODA expenditure and the conflict in Sudan.202^[16]

• In late 2022, the UK, along with many other countries,^[17] announced that it would withdraw its peacekeeping forces from Mali, ending involvement earlier than expected. Wagner involvement appears to have contributed to this decision.^[18] It is not clear what efforts the UK made to encourage the Malian authorities to allow the UN Mission to operate freely. The decision to withdraw was taken collectively via the National Security Council, via a “write-round process initiated by the Defence Secretary”. We do not know whether FCDO officials raised alternatives to withdrawal for discussion with the Ministry of Defence.^[19]

Cross-departmental working

37. Responsibility for responding to the Wagner Network sits across several departments within the UK Government and reaches across multiple directorates within the FCDO. Among departments, the FCDO and Ministry of Defence receive the greatest focus in the Government’s written evidence to this inquiry. However, relevant powers also sit within:

• the Home Office, which has the power to proscribe organisations as terrorist entities and to ban foreign nationals from entering the UK when “conducive to the public good”;^[20] and

• the Treasury, which has day-to-day decision-making power over sanctions implementation measures, including sanctions waivers.^[21]

Ben Fender (Director, Eastern Europe and Central Asia, FCDO) told us:

Day to day, Government are coming together to look at Wagner as a problem, because we think it is a growing issue.^[22]

It has not been possible during this inquiry to ascertain which minister has lead responsibility. The Government’s evidence to this inquiry arrived several months late, due to the challenges of obtaining input from multiple departments.^[23]

38. Mechanisms to enable departments to work together include, at the highest level, the National Security Council, a Cabinet committee dedicated to the discussion of national security issues “in the round” and “in a strategic way”.^[24] Among civil servants, the Russia Unit within the FCDO brings together officials from the Foreign Office and other departments.^[25] It is intended to support “joined-up policy” on the Wagner Network and other Russia-related issues.^[26] In February, the Minister said it had surged resources to this unit in the past year.^[27] Referring to this unit, the Minister told us:

I am confident that we have a joined-up cross-Whitehall mechanism for ensuring the best possible execution of our policy… ^[28]

He added that:

…there are more people looking at this as part of a very defined effort over the last year—to surge resource into a very considerable ramping up of our efforts around Ukraine and wider issues…^[29]

39. Supporting Ukraine militarily is the Government’s priority when it comes to countering the Wagner Network. We fully support the continued supply of defence assistance and wider support to Ukraine as it fights to liberate itself from Russian illegal occupation. Through this, the UK has enabled Ukrainian Armed Forces to challenge Wagner fighters directly, often resulting in a high rate of attrition.

40. However, it is a significant failing to see the Wagner Network primarily through the prism of Europe, not least given its geographic spread, the impact of its activities on UK interests further abroad, and the fact that its wealth creation sits largely in Africa.

41. The Government believes that it is becoming more important to consider the network’s activities, although it did not say where it would do so. In February 2023, the FCDO told us there was now “much more activity” in Government to understand and respond to the network than there had been six months earlier. The Government also said it had surged resources into the Russia Unit over the last year.

42. The Wagner Network began its activities in 2014. By early 2022, when the Government began to invest greater resource in understanding the network, Wagner fighters had already undertaken military deployments in at least seven countries. It is deeply regrettable that it took this long, and that the Government continues to give so little focus to countries beyond Ukraine. This leaves us even less prepared to respond to the evolution of this notoriously shape-shifting network.

Specific actions taken by the UK Government

Tracking and sanctioning

43. The FCDO’s geographical Directorates track and respond to the activities of ‘Private Military Companies’, working with the Ministry of Defence.^[30]At a minimum, this work covers the network’s military activities in Ukraine.^[31] The intelligence on its activities in Africa appears more limited. Ben Fender acknowledged a lack of “granular understanding” of the network’s numbers in Africa, but added: “it doesn’t look as if it is growing—it is certainly not growing fast”.^[32]The Minister emphasised the need not to over-estimate the network’s importance.^[33] Contributors pushed for the Government to invest in “network analysis tools and systems”, to better understand and respond to organisations like the Wagner Network.^[34]

44. Sanctions are one tool that the UK Government uses to respond to the Wagner Network, with 39 geographic and thematic regimes for making designations.^[35] Sanctions can include asset freezes (for individuals and entities), trust services sanctions^[36] (for individuals and entities) and travel bans (for individuals). The Minister told us in February that that UK sanctions against Wagner have “focused on high-impact targets and disrupting its overall network”; the Government is “considering further sanctions,” but makes it “a matter of policy not to speculate on whether or not we are considering specific cases.”^[37]There are now 150 staff members in the FCDO’s Sanctions Taskforce (“treble its previous number”), as well as many others in Government who work “substantially or partially on sanctions policy and implementation.”^[38]

45. According to the Dossier Center, identifying and sanctioning all Wagner-linked individuals and entities is “almost impossible”, due to the “efforts employed by [Prigozhin’s] staff to disguise their activities and companies”.^[39] The sanctions process is “comparatively slow” relative to the time needed to register a new company,^[40] and Prigozhin’s affiliates have “managed to evade sanctions through continuous turnover”.^[41] Wagner operatives have also changed their names to avoid sanctions, and there is evidence that officials of at least one host government have assisted Wagner-linked individuals to register companies in a way that obscures their true connection.^[42]

46. The Government told us at the end of February that it had sanctioned Yevgeny Prigozhin, as well as a further seven Wagner-linked individuals, including Dmitri Utkin, commanders in Syria and officials supporting Wagner recruitment in Russian prisons.^[43] To understand the level of sanctioning of Wagner actors, we compared and analysed the official sanctions lists of the United Kingdom, the United States and the European Union, as of 7 July 2023.230^[44] We identified 44 individuals and 37 entities that had been sanctioned—in one or more of these three jurisdictions—for their direct connection to the Wagner Network, or for relevant activities in support of Prigozhin.^[45] According to our analysis (presented in Appendix 1), the UK has sanctioned Wagner-linked targets at a lower rate than either the EU or the US. Specifically:

• Among the individuals identified, the UK has sanctioned 15 of 44, i.e. around one in three (34%). In comparison, the US has sanctioned 61% and the EU 68%.

• Among the entities identified, the UK has sanctioned 5 out of these 37 (13.5% sanctioning rate). By comparison, the EU has sanctioned 16 of these entities (43%) and the US has sanctioned 30 (81%).

Beyond these 44 individuals and 37 entities, the UK may have applied sanctions to additional targets, without making clear their association to the Wagner Network or to Prigozhin when doing so. When questioned on this point, the Minister appeared unsure as to why the UK may have sanctioned fewer individuals and entities than the US and EU, suggesting it may be because they are “larger”.^[46] He added:

We work with our allies. If you have a list there that you think we should be seeing, I imagine that that list will be considered by our sanctions team.^[47]

Beyond these 44 individuals and 37 entities, the UK may have applied sanctions to additional targets, without making clear their association to the Wagner Network or to Prigozhin when doing so. When questioned on this point, the Minister appeared unsure as to why the UK may have sanctioned fewer individuals and entities than the US and EU, suggesting it may be because they are “larger”.^[48] He added:

In subsequent correspondence, the Minister disputed that the UK has sanctioned fewer people than the United States. However, the supporting statistics he provided referred to individuals sanctioned under the wider Russia sanctions regime, rather than those sanctioned specifically for their role within the Wagner Network.^[49] Appendix 1 provides our own list for the FCDO’s consideration. We acknowledge that there are specific reasons why the UK may have sanctioned at a lower rate than these allies.^[50]

47. The Government further implied that its limited sanctioning of specific Wagner-linked entities is irrelevant. It stated that its designation of the ‘Wagner Group’ in 2022 automatically freezes the assets of entities that the Wagner Group owns or controls.^[51] However, the Wagner Network encompasses a complex web of entities (paragraph 3). It is unclear how organisations that implement Government sanctions, such as banks and other financial institutions, are expected to know which entities are within their scope.

48. Witnesses were sceptical of the level of effort that national governments—including the UK—had devoted to mapping and tracking the Wagner Network,^[52] with the exception of Ukraine.^[53] Christo Grozev judged that sanctions on Prigozhin himself are “maxed out”. However, he believed that

stopping all of those [Prigozhin-linked] people from being able to travel internationally—at least to the western world—might, incrementally, have a much bigger impact than slapping one more sanction on Prigozhin^[54]

Grozev believed a travel ban could be a meaningful deterrent, because many in the Wagner Network see their involvement as transactional.^[55] He felt this tool could be stronger if the UK worked with Turkey: a popular holiday destination for many Russians.^[56] The Centre for Information Resilience, the not-for-profit organisation that carried out open-source research for this inquiry, also argued in favour of expanding sanctions targets, noting:

Sanctions are rarely applied to individuals working as civilian specialists in key fields, for example mineral extraction, where Wagner-affiliated entities employ specialists in fields such as geology, gemology or logistics. Whilst some may not know who their ultimate benefactors are, these ‘faceless’ individuals make the wider network’s activities possible. Similarly, those who act as frontmen – directors of key companies, for example – are also largely ignored as avenues of research or accountability.^[57]

49. Alongside calls for the UK to apply further sanctions to the Wagner Network,^[58] some witnesses expressed doubt over the impact of the sanctions imposed to date.^[59] An FT investigation published in February 2023 analysed corporate records of Prigozhin-linked companies and concluded that Prigozhin had generated over $250 million from his commercial empire in the four years prior to the full-scale illegal invasion of Ukraine, despite ever-increasing sanctions on him.^[60] In February, the Minister told us he was “confident” that there were no significant assets of the Wagner Network in the UK that could be frozen.^[61]Furthermore, the existence of sanctions is no guarantee of their implementation and enforcement: a point we have made in previous reports.^[62] The Sentry called for the UK to ensure the effectiveness of its sanctions:

The UK must deploy a cross-government approach, including the NCA, FCDO, and HM Treasury, to effectively implement these sanctions and ensure that they have the maximum impact and lead to the actual seizure of UK based assets, travel bans, and the denial of services. This must be coupled with effective in-country and international messaging that clearly sets out the reason for and aim of the sanctions.^[63]

50. There is concern that the financial benefits of the Wagner Network’s activities may be reaching the Russian government. Professor Blazakis told us last November that the Wagner Network had “become instrumental in Putin’s ambitions in gaining access to natural resources throughout Africa”, adding: “whether gold, oil or diamonds, the Russian Federation has acquired fungible assets that keep the war machine churning in Ukraine”.^[64] It is also unclear whether the Government has assessed the likelihood that Wagner Network activities have helped Russia to evade sanctions:^[65]The Minister was “sure that the Department is tracking that”, but said that he had no “particular knowledge” of such activity.^[66]

51. On 23 January 2023, it was reported that HM Treasury—specifically, the Office of Financial Sanctions Implementation (OFSI)—had granted special licenses to Yevgeny Prigozhin to enable him to circumvent UK sanctions against him and to launch a legal campaign against Eliot Higgins, founder of Bellingcat.^[67] The aim of this case appears to have been to rebut allegations made by Bellingcat against Prigozhin, which played a role in his original sanctions designation. The Treasury approved a British firm, Discreet Law, to work on this case, and enabled Prigozhin to pay the fees. Responding to an Urgent Question on 25 January 2023, Treasury Minister James Cartlidge MP noted that such decisions are routinely taken by officials in OFSI, without ministerial oversight.^[68] He noted that, under the UK’s sanctions regime, there can be circumstances when frozen assets are used to pay for sanctioned individuals’ legal fees, due to the universal right to legal representation. On 30 March 2023, the Treasury Minister, Baroness Penn, announced that, when assessing future applications for sanctions waivers, OFSI takes “a presumption that legal fees relating to defamation and similar cases will be rejected”.^[69] She also noted that updates to the decision-making framework would clarify “when it is appropriate for Ministers to take these decisions personally, or where officials can take these decisions”.

52. The FCDO’s direct involvement in Treasury decisions over sanctions waivers appears limited. The Foreign Office had no involvement, for example, in OFSI’s decision over the general conditions under which persons and entities sanctioned under the Russia Regulations and Belarus Regulations could pay legal fees to UK service providers.^[70] In the Prigozhin case, the Minister was not confident that the FCDO had been involved in OFSI’s decision, although he thought it “extremely likely”^[71] When pressed on how the FCDO monitors sanctions waivers, he noted that there would be “communication between Departments”.^[72] He indicated that relevant advice on sanctions waivers would come to him via officials, but clarified that he had received “none specifically”.^[73] While defending the joined-up nature of UK policy in general, he conceded:

This case is a cause for reconsideration, and I think we will reflect and work with Treasury colleagues to consider what might have been done differently.^[74]

53. In relation to the Prigozhin case, the Centre for Information Resilience stated:

Though Wagner-affiliated individuals likely have property and investments held through proxy companies in the UK and EU, their physical (and most profitable) activities take place outside of these territories. This means there is limited data available on sanctions evasion. It is clear, however, that Prigozhin and his affiliates see value in attempting to evade certain sanctions in the UK and EU, particularly where it relates to their reputation.^[75]

54. We have received no evidence of any serious effort by the Government to track the Network’s activities in countries other than Ukraine. We recommend that the Government improve its intelligence-gathering on the Wagner Network’s activities in a wider range of countries, particularly in the countries where we have medium-confidence of attempts at Wagner involvement. This intelligence should make use of network-mapping capabilities. A cross-Government taskforce would be particularly useful as the Wagner Network transforms, following the attempted march on Moscow.

55. The UK’s efforts to sanction the Wagner Network are underwhelming in the extreme, compared to those of the European Union and the United States. The responses from the Minister leave us with limited confidence that the UK coordinates effectively with its allies to share intelligence on the Wagner Network and to impose sanctions on relevant individuals and entities. Equally, the Government left us with very little confidence that those British nationals pursued by the Wagner Network receive any meaningful support from the British Government; indeed, they were made more vulnerable due to decisions made from within Government.

56. The Government claimed that its sanctioning of the ‘Wagner Group’ automatically covered all the entities that the Group owns or controls. This approach under-appreciates the complexity of the network. It is also completely unrealistic. It leaves both enforcement agencies and implementing organisations, such as banks, estate agents and other financial services, with no idea which affiliated entities they should target. This makes it possible, if not probable, that Wagner-linked entities are continuing to benefit from access to the UK’s financial markets. The lack of certainty about this denotes a scandalous failure to exercise due diligence. At its worst, this could mean the UK is inadvertently undermining the efforts of our allies.

57. The Minister had no specific knowledge of work within his Department to analyse whether Wagner activities undermine the financial impact of UK sanctions on the Russian war machine. Despite finding it “likely”, he could not confirm that the FCDO had had any input to HM Treasury’s unwise decision to issue sanctions waivers to Prigozhin. Despite assuring us that the Treasury and FCDO communicate over sanctions waivers in general, the Minister himself had not received any official advice specifically on sanctions waivers. Given his position as the Parliamentary Under Secretary of State for Europe, we would expect him to have an interest and role in questions relating to sanctions waivers linked to Russia and Ukraine. His statements also lead us to question whether the Russia Unit is providing the necessary join-up between the FCDO and Treasury, given the central role of sanctions as a tool of UK foreign policy.

58. We recommend that the Government move faster and harder in sanctioning Wagner-linked individuals and entities. Specifically, it should:

a) Sanction all individuals and entities provided in Appendix 1, which the United States and European Union have already targeted but which the UK has not;

b) Consider bringing forth sanctions on civilian enablers and corporate ‘frontmen’ for the network’s activities; and

c) Close enforcement gaps.

59. We recommend that the Government establishes a specific and regular mechanism for coordinating with the United States and the European Union over Wagner-linked sanctions; it should report back to us on what these mechanisms are, and how frequently and effectively they are being used.

60. We further recommend that the Government prioritises introducing and enforcing travel bans for Wagner-linked individuals as a likely deterrent to involvement in the network, in particular working with Turkey, a popular holiday destination for Russians.

61. In the public interest, we have compiled Wagner-linked names that are already a matter of public record, as identified via our commissioned open-source research (see Appendix 2). In doing so, we hope to challenge the mystique that the Wagner Network cultivated in many countries, make it as difficult as possible for it to operate, create a deterrent effect, and enable the Government to improve its apparently limited understanding of the network. We implore the Government to urgently assess these names and impose sanctions on these individuals and entities if the necessary threshold is met.

Carrot and stick diplomacy

If we do not turn up and work with allies […]—if we do not show up and stay active—then certainly, proxies of this nature do see an opportunity^[76] 62. The UK’s future foreign policy depends on its ability to form relationships with a wide group of countries, “in the Commonwealth, in the African Union, in ASEAN and elsewhere”.^[77] When the Wagner Network is involved in a country, it becomes harder for the UK to engage there, both diplomatically and militarily.^[78] Although working with the Wagner Network is a sovereign decision of national governments, the UK can seek to influence these decisions.

63. UK diplomats have brought up the network’s activities in discussions with national authorities who have engaged with the network.^[79] The means by which the UK has sought to dissuade countries from working with the Wagner Network are unclear. Ben Fender (Director, Eastern Europe and Central Asia, FCDO) pointed out that many governments in West Africa are concerned about the Wagner Network’s activities in Mali, noting: “I like to think that our diplomacy and our efforts have contributed” to those concerns^[80] - but he did not elaborate on the role of UK diplomacy in informing these countries’ views. The Government has not provided examples of individual countries that it has successfully deterred from choosing to engage with the network.^[81] In other words, in its evidence to our inquiry, the Government was unable to provide any direct evidence of having limited or successfully challenged the Wagner Network’s efforts and ambitions in countries where it is invited. The United States is currently working to deter African countries from engaging with the network by sharing intelligence strategically with allies.^[82] US officials credited this approach with blunting a planned destabilisation operation in Chad.^[83]

64. Another mode of influencing governments’ decisions to engage with the Wagner Network may be to offer a ‘carrot’ in the form of a compelling alternative. The UK’s work with partner states on “nation building and investing in institutions” is

critical to the ability of often fragile states to build their own capacity so that they are not subject to the business model of a Wagner-type group^[84]

The Minister highlighted the UK’s work to strengthen institutions in “much of Africa and other regions”; he judged that the UK military and Foreign Office represent a “very successful agent of institutional state building and improving”.^[85] Our sister Committee, the International Development Committee, called on the Government in October 2022 to reassess whether a sufficient share of UK aid is reaching communities in fragile and conflict-affected states.^[86]

65. In contrast, a ‘stick’ to influence governments’ decisions could be to increase the negative consequences of associating with the network. One such tool would be to proscribe the network as a terrorist organisation.^[87] Contributors to this inquiry called for this action,^[88] as have other parliamentarians,^[89] and expert witnesses provided evidence that the activities of the network already fulfil the UK’s legal threshold for proscription.^[90] It was also suggested that making the proscription would have a deterrent effect,^[91]as it would “change the cost of doing business”^[92] with the network. Stigma from this designation “could be leveraged […] to limit Wagner’s access to ports, natural resources, and corridors of power that the group has been able to exploit for the benefit of the Russian Federation”.^[93] The Dossier Center said:

those supporting [Wagner] in host countries will also be subject to punishment. Moreover, it would restrict the use of European, African and Middle Eastern companies as vehicles for the movement of money, without which Wagner cannot operate. It would also impose greater responsibility on those countries that cooperate with and hire such organisations. It would also make it difficult for employees affiliated with Prigozhin to move around the world^[94]

A proscription may also support legal action against Wagner members in British courts,^[95] encourage whistle-blowers to come forward,^[96]and allow the use of pre-existing international mechanisms of counter-terrorist financing.^[97] Risks of a proscription include the possibility that it would drive the network “underground”,^[98] as well as causing damage to the UK’s diplomatic ties with affected countries.^[99]

66. The media have reported that proscription of the Wagner Group in the UK is imminent.^[100] The Government also committed “to use the full range of powers available to us—including considering our robust counter-terrorism powers, such as proscription —to tackle the threats we face from organisations such as the Wagner Group”.^[101]Despite these signs, the UK Government’s official policy remains not to comment on the possible proscription of the Wagner Network as a terrorist organisation,^[102] and UK allies such as the EU and US have also held back from proscription.^[103] Professor Blazakis suggested that the UK and Five Eyes countries have been “reticent” to use terrorist proscriptions against groups that are linked to a nation state, and that “precedent is a very difficult line for bureaucrats to cross”, due to its wider implications.^[104] It is worth noting that the UK lacks a system for proscribing a country as a ‘State Sponsor’ of Terrorism,^[105]as some have advocated for Russia, but the decision not to designate a state actor through terrorism legislation is nevertheless a policy decision, rather than a legal one.^[106]

67. Summing up options, Professor Blazakis recommended that the Government: [emphasis added]

consider deploying terrorism proscriptions, expand law enforcement investigations against individuals that facilitate activities on behalf of the Wagner Group, and ratchet up diplomatic efforts to tarnish Wagner’s reputation overseas. Of course, civil society should pursue legal action against known Wagner Group members […]. A combination of those activities could still erode Wagner’s effectiveness, but time is becoming short^[107]

68. There is an opportunity to disrupt the Wagner Network at a time when its future is uncertain. We recommend that the Government seizes this opportunity and works with international partners to deter countries from engaging with the Wagner Network, using a carrot and stick approach.

69. As the Government improves its intelligence on the network, it should declassify it strategically and share it with countries that are considering engaging with the Wagner Network, to demonstrate the organisation’s destabilising effects, following the lead of the United States administration.

70. The Government should offer a genuinely compelling alternative to priority countries in need of investment and security partnership, in collaboration with partners. Priority countries are especially likely to be neighbouring countries to those where the Wagner Network is engaged. A compelling alternative may involve customising packages of military, aid and trade support to specific countries, particularly in the Sahel region.

71. In its response to this report, the Government should set out the factors it will assess in determining whether countries are priorities for UK security partnerships. These factors should include (but not be limited to):

a) the UK’s capacity for influence in a specific country;

b) the level of security challenge faced by a country (in the short, medium and long term);

c) the level of demand for a bilateral/multilateral security partnership within a country;

d) the possible regional implications of the country’s ‘capture’ by a Russian or other malign proxy; and

e) the level of willingness on both sides to uphold transparency and standards of good governance as part of any future partnership.

72. The Government should revive its previous commitment to channel 50% of Official Development Assistance to fragile and conflict-affected countries and regions. The Government should also revive its 2019 manifesto commitment to spending 0.7% of the UK’s Gross National Income on Official Development Assistance at the earliest opportunity, in light of refugee and asylum pressure in multiple countries

73. As a ‘stick’, the Government should proscribe the Wagner Network as a terrorist organisation, recognising that—while there are risks of doing so—there are also risks of failing to do so, when the Network appears to meet the legal criteria.

1. Q223
2. Q108
3. Q108
4. Military assistance to Ukraine since the Russian invasion, Research Briefing 9477, House of Commons Library, 23 May 2023, p 4
5. Q59
6. The UK raised concerns directly with the Russian, Libyan and Sudanese authorities. The Government has also said it is working closely with international partners to counter the malign use of such proxies by Russia and it aims to “build consensus around responsible state behaviour and competition and promote understanding globally about the risks that PMCs acting as state proxies pose to international security and stability.” Foreign, Commonwealth and Development Office (WGN0025) section 4; PQ UIN 59567 [on Sudan: Gold], Answered on 18 October 2022
7. Q108 [Leo Docherty]
8. For instance, the FCDO’s written evidence notes that the Secretary of State for Defence has spoken out about Wagner activities in Africa, the Middle East and Ukraine; FCDO Minister Ford expressed concern over Wagner presence in Mali.
9. Foreign, Commonwealth and Development Office (WGN0025) section 4
10. Foreign, Commonwealth and Development Office (WGN0025) section 5
11. HM Government, Integrated Review Refresh 2023: Responding to a more contested and volatile world, CP 811, March 2023, para 16
12. “The National Security Bill will create a more challenging operating environment for states and other actors who seek to undermine UK interests, and we will make use of the full range of powers available to us – including considering proscription – to tackle the threats we face from organisations such as Wagner. We will also continue to develop our broader deterrence and defence toolkit, including information operations and offensive cyber tools, and make greater use of open source information alongside our intelligence capabilities.” HM Government, Integrated Review Refresh 2023: Responding to a more contested and volatile world, CP 811, March 2023, para 19(iv)
13. Q199 [Ben Fender]
14. Q107 [Mikhail Khodorkovsky]
15. The figures in the text specifically refer to CSSF funding. UK agrees to review if aid cuts left it ‘off guard’ in Sudan, Devex, 1 June 202
16. Oral evidence taken on 12 June 2023, HC (2022–23) 171, Q529 [James Cleverly]
17. For example, France, Sweden, Germany. See UN ends peacekeeping force in Mali, Research Briefing 9827, House of Commons Library, 3 July 2023, p 9
18. UK Government, ‘Minister for the Armed Forces statement on the UN Peacekeeping Mission in Mali’ 14 November 2022 (accessed 17 July 2023)
19. Correspondence with the Parliamentary Under-Secretary of State (Europe) following up on the FAC evidence session on 6 February 2023, dated 28/02/2023 and 09/02/2023
20. PQ UIN HL3473 [on Wagner Group: Sanctions], Answered on 30 November 2022
21. “OFSI is the authority for implementing the UK’s financial sanctions on behalf of HM Treasury. OFSI helps to ensure that financial sanctions are properly understood, implemented and enforced in the UK.” UK Government, ‘Russia sanctions: guidance’, 3 July 2023 (accessed 17 July 2023)
22. Q125
23. The original deadline for written evidence was May 2022; the Government’s evidence was submitted in October 2022.
24. UK Government, ‘National Security Council’ (accessed 17 July 2023)
25. Q135 [Ben Fender]
26. Q114 [Leo Docherty]. Ben Fender elaborated that the Unit “convenes people from human rights, Africa, and the multilateral people who look at policy on private military companies, and so on”. Q130
27. Qq114–115
28. Q128
29. Q117
30. The Minister of Defence “works across HMG to enable evidence sharing to support sanctioning of those involved in malign PMC activity”. Foreign, Commonwealth and Development Office (WGN0025) sections 4–5
31. Such activities have been the regular subject of public updates from Defence Intelligence since the start of the full-scale Russia-Ukraine war For example, Ministry of Defence (via Twitter), ’Defence Intelligence update on the situation in Ukraine – 28 March 2022’ (accessed 17 July 2023); Ministry of Defence (via Twitter), ‘Defence Intelligence update on the situation in Ukraine – 3 February 2023’ (accessed 17 July 2023)
32. Q109
33. “…it is easy to overstate their success. […] I think it is easy to overstate their growing impact […] they are very definitely a global force for bad and instability, but at the same time, we mustn’t assign them too much success...” Q109
34. Protection Approaches (WGN0024) para 4.1: “Network analysis brings to light the full spectrum of actors that enable the perpetration of violence, including supply chains, human trafficking networks, the arms trade, media outlets, armed groups, and communities themselves. Network analysis allows actors to target those weak spots – be they the financial flows of private companies such as the Wagner group, their communication systems, or other forms of enablement. Such analysis of private and proxy armed actors should inform the application of travel bans; sanctions; accountability the design of programming; and wider strategy.” See similar points within The Sentry (WGN0017) para 27
35. Correspondence with the Parliamentary Under-Secretary of State (Europe) following up on the FAC evidence session on 6 February 2023, dated 28/02/2023 and 09/02/2023
36. Since 21 March 2023, the Government has also used ‘trust services sanctions’ to make it harder for specific sanctioned individuals and entities to access services that would reduce the impact of sanctions on them. OFSI, ‘Trust Services Sanctions update’, 21 March 2023 (accessed 17 July 2023)
37. Correspondence with the Parliamentary Under-Secretary of State (Europe) following up on the FAC evidence session on 6 February 2023, dated 28/02/2023 and 09/02/2023
38. The others working on this include: “others across the FCDO in our overseas network, Trade Directorate, geographic and thematic directorates and others across Government”. Foreign, Commonwealth and Development Office (WGN0025) section 5
39. Dossier Center (WGN0009) para 57
40. Dossier Center (WGN0009) para 54
41. Dossier Center (WGN0009) para 43
42. Dossier Center (WGN0009) paras 55–56
43. Correspondence with the Parliamentary Under-Secretary of State (Europe) following up on the FAC evidence session on 6 February 2023, dated 28/02/2023 and 09/02/2023
44. 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 (see Appendix 1).
45. This is a non-exhaustive list. It is challenging to count all the sanctions that the UK and its partners have applied to ‘Wagner-linked’ individuals and entities. Some individuals and entities linked to the Wagner Network may be sanctioned for other reasons, beyond this association.
46. Qq150-151
47. Qq158
48. Qq150-151
49. Correspondence with the Parliamentary Under-Secretary of State (Europe) following up on the FAC evidence session on 6 February 2023, dated 28/02/2023 and 09/02/2023. It is possible that there is overlap between those sanctioned under the Russia regime and those within in the Wagner Network, even if the Wagner links are not explicit in their designation.
50. A challenge may be information-sharing. “If, for example, the US or another G7 counterpart has imposed sanctions, they will often do it based on their own analysis. Some of that analysis will be able to be shared across borders; some of it will not, to protect individuals who have provided the evidence. What you have within a sanctions designation, in general, is what is available if it goes to public scrutiny or into a court scrutiny environment. You also have the evidence underneath that, and sometimes the evidence cannot be shared across borders. That has, in the past, proved to be an issue in imposing multilateral sanctions.” Oral evidence taken on 8 March 2022, HC (2021–22) 1089, Q79 [Dr Walker]
51. “By designating Wagner Group, our asset freeze also applies to any other entity it owns or controls. The US has designated a number of entities that it considers controlled by Wagner Group; entities controlled by Wagner are already subject to a UK asset freeze through our ownership and control provisions”. Correspondence with the Parliamentary Under-Secretary of State (Europe) following up on the FAC evidence session on 6 February 2023, dated 28/02/2023 and 09/02/2023
52. Christo Grozev of Bellingcat stated that he assumes governments are generally incompetent when it comes to tracking individuals linked to the Wagner Group. To justify this assertion, he gave the example of a “known persona” in the Wagner Group, who it took his team around two weeks to identify, but who had been issued with visas by multiple European governments. Grozev stated that “nobody has really mapped out the whole structure and kept tabs on it”. Sean McFate agreed that there is limited tracking of the Network, stating that “the Five Eyes have not taken this issue seriously until maybe very recently”. Q30. See also Protection Approaches (WGN0024) para 2.2
53. Christo Grozev believed that Ukraine was exceptional (relative to other countries) for its in-depth work to map the Wagner Group, but that, as it is fighting a war, it now lacks resources. He judged that “any other country that wished to have a complete mapping might be able to do it at a much better rate”Q30.
54. Q249
55. Qq 55, 57
56. Q57
57. CIR open-source research
58. For example, Democracy & Human Rights Foundation (WGN0011); The Sentry (WGN0017); Center on Terrorism, Extremism, and Counterterrorism - Middlebury Institute of International Studies (WGN0023); Dr. Marc DeVore (Senior Lecturer at University of St. Andrews); Dr. Kristen Harkness (Senior Lecturer at University of St. Andrews); Professor Andrew Orr (Associate Professor at Kansas State University); Mr. Marcel Plichta (Ph.D. Candidate at University of St. Andrews) (WGN0008)
59. Q67 [Jason Blazakis]; Q55 [Sean McFate
60. Wagner leader generated $250mn from sanctioned empire, FT, 21 February 202
61. Qq155–156 [Leo Docherty
62. Foreign Affairs Committee, Second Report of Session 2022–23, The cost of complacency: illicit finance and the war in Ukraine HC 168, paras 29–30. See, for example, Three Russians under sanctions own UK property via overseas entities, The Guardian, 31 January 2023
63. The Sentry (WGN0017) para 27
64. Q67
65. Q161 [Leo Docherty]
66. Q162 [Leo Docherty]
67. How Rishi Sunak’s Treasury helped Putin ally sue Bellingcat’s Eliot Higgins, openDemocracy, 23 January 202
68. HC Deb, 25 January 2023, col 1013 [Commons Chamber]
69. Statement UIN HLWS686 by Baroness Penn [on Office of Financial Sanctions Implementation update], 30 March 2023
70. Specifically, General Licence INT/2022/2252300. Correspondence with the Parliamentary Under-Secretary of State (Europe) following up on the FAC evidence session on 6 February 2023, dated 28/02/2023 and 09/02/2023
71. Q167
72. Q170
73. Q173
74. Q182
75. CIR open-source research
76. Q232 [Leo Docherty]
77. The Foreign Secretary also highlighted the opportunity for the UK to be a “reliable, trustworthy and long term partner” via “investments of faith”. UK Government, ‘British foreign policy and diplomacy: Foreign Secretary’s speech, 12 December 2022 (accessed 17 July 2023),
78. Qq221–222 [Leo Docherty]
79. The UK raised concerns directly with the Russian, Libyan and Sudanese authorities. Foreign, Commonwealth and Development Office (WGN0025); PQ UIN 59567 [on Sudan: Gold], Answered on 18 October 2022
80. Q108
81. Q108
82. To counter Russia in Africa, Biden deploys a favored strategy, POLITICO, 7 May 2023
83. To counter Russia in Africa, Biden deploys a favored strategy, POLITICO, 7 May 2023
84. Q108 [Leo Docherty]
85. Q110
86. International Development Committee, Third Report of Session 2022–23, From Srebrenica to a safer tomorrow: Preventing future mass atrocities around the world, HC 149, para 9
87. Among other things, proscription of a group as a terrorist entity makes it a criminal offence to belong to the organisation in the UK or overseas, to invite support for it or to arrange a meeting in support of it. Proscription also means that the financial assets of the organisation become terrorist property and can be subject to freezing and seizure. Proscribed Terrorist Organisations, Research Briefing 00815, House of Commons Library, 23 November 2021, p 6
88. Q75 [Jason McCue]; Dossier Center (WGN0009) para 58; Q87 [Jason McCue]. Center on Terrorism, Extremism, and Counterterrorism - Middlebury Institute of International Studies (WGN0023) called for governments to consider it.
89. For example, MEPs and MPs in Canada. Conservative MPs call for Russia’s Wagner Group to be listed as terrorist entity, Western Standard News, 30 January 2023; European Parliament ‘European Parliament declares Russia to be a state sponsor of terrorism’, 23 November 2022
90. Q75 [Jason McCue]; Qq76, 91–95 [Jason Blazakis]. McCue listed Wagner’s relevant actions, including the planting of explosives around a nuclear facility, assassination attempts on President Zelensky, threats to use chemical and biological weapons, war crimes and the promotion of atrocities
91. Qq-86
92. Center on Terrorism, Extremism, and Counterterrorism - Middlebury Institute of International Studies (WGN0023)
93. Center on Terrorism, Extremism, and Counterterrorism - Middlebury Institute of International Studies (WGN0023)
94. Dossier Center (WGN0009) para 58
95. Q87[Jason McCue]
96. Q87 [Jason McCue]
97. Jason Blazakis, Sanctions: Bringing the Wagner Group and State Proxies into the CTF Fold, 2023
98. Q90 [Jason Blazakis]
99. However, Professor Blazakis noted that, despite Iran being listed as a state sponsor of terrorism since 1983, it was still possible for the international community to negotiate the JCPOA. Qq 79–80
100. For example, Home Office preparing to proscribe Wagner Group as a terrorist organisation, The Telegraph, 3 February 2023
101. Oral evidence taken on 12 June 2023, HC (2022–23) 171, Q508 [James Cleverly]
102. UK poised to label Wagner group terrorists as France urges EU to act, The Guardian, 10 May 2023. However, the US has labelled the Wagner Group as a transnational criminal organisation. US Department of the Treasury, ‘Treasury Sanctions Russian Proxy Wagner Group as a Transnational Criminal Organization’, 26 January 2023 (accessed 16 July 2023)
103. UK poised to label Wagner group terrorists as France urges EU to act, The Guardian, 10 May 2023. However, the US has labelled the Wagner Group as a transnational criminal organisation. US Department of the Treasury, ‘Treasury Sanctions Russian Proxy Wagner Group as a Transnational Criminal Organization’, 26 January 2023 (accessed 16 July 2023)
104. Q78
105. PQ UIN88866 [on Russia: Terrorism], Answered on 23 November 2022
106. Given the Government’s power to change law.
107. Q67

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