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

​Appendix 1: Sanctions comparisons for the UK, United States and European Union
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. 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.
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) | 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 ​ |
| 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 ​ |
| 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 ​ |
| 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 ​ |
| 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 ​ |
| 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 |
| Name of entity, with supporting information from the time of designation | 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 ​ |
| 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 ​ |
| 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 ​ |
| 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 ​ |
| 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 ​ |
| 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 ​ |
| 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 ​ |
| “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 |
* ↑ 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.
* ↑ For example, Ukrainian Government, Personal sanctions tracker: War and sanctions (accessed 17 July 2023)
* ↑ U.S. designation information is drawn from the Treasury press releases.
* ↑ U.S. designation information is drawn from the supporting Treasury press releases.
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