Source · Select Committees · Foreign Affairs Committee

Recommendation 15

15 Accepted Paragraph: 56

Government's blanket Wagner Group sanctions approach creates enforcement gaps for linked entities.

Conclusion
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.
Government Response Summary
The government partially agrees, reaffirming that the Wagner Group was fully designated in 2022 and explaining that the UK's sanctions regime relies on 'ownership and control' provisions, meaning subsidiaries are not designated separately. It also notes recent additional designations and will consider the committee's analysis in detail for future action.
Paragraph Reference: 56
Government Response Accepted
HM Government Accepted
Partially agree. 12. The Wagner Group was designated in its entirety under the Russia (Sanctions) (EU Exit) Regulations 2019 in March 2022. Yevgeny Prigozhin, its then leader, was designated under The Libya (Sanctions) (EU Exit) Regulations 2020 in December 2020. 13. We continue to use sanctions policy to deter and disrupt malign Wagner activity. On 20 July, the UK designated 13 individuals and businesses involved with the Wagner Group in Mali, Central African Republic (CAR) and Sudan. They include Konstantin Pikalov, Prigozhin’s ‘right hand man’, as well as Al-Solag mining, a Wagner front company not designated by the EU or US. The designations limit their financial freedom by preventing UK citizens, companies and banks from dealing with them, alongside freezing any assets held in the UK, and imposing travel bans on the individuals. 14. The Government’s ability to sanction individuals and entities depends on being able to build individual cases in line with the statutory requirements of the relevant geographic or thematic sanctions regime. These may differ from the grounds available to the United States and the European Union. Each country’s sanctions regimes are different, and each country uses them for different purposes and has different approaches in applying sanctions. For example, the UK relies on ‘ownership and control’ provisions, which means that subsidiaries are not designated separately. 15. The Government welcomes the analysis provided in Appendices 1 and 2 of the FAC’s report and will consider this in detail when considering further action.