On 13 December 2021, the EU imposed sanctions against the Wagner Group, a private military entity based in Russia, as well as related entities and individuals, citing human rights abuses and destabilising activities in various countries, including Ukraine (Donbas), Syria, Libya and the Central African Republic.1
In addition to the Wagner Group itself,2 the new sanctions personally target eight alleged key figures of the organisation3 as well as three Russian oil and gas companies alleged to be benefiting from and supporting the al-Assad regime in Syria. These entities and individuals will now all be subject to an asset freeze in the EU.pp
The newly listed entities are:
- Wagner Group a.k.a. Vagner Group;
- Velada LLC;
- Mercury LLC; and
- Evro Poli LLC.4
Under the EU asset freeze, all funds and economic resources in the EU belonging to or controlled by the listed persons will be frozen. Furthermore, no funds or economic resources may be made available – directly or indirectly – to or for their benefit. In limited situations, licences may be granted that would authorise such activities. Economic resources are broadly defined to include anything that can be used to obtain funds, goods or services. Listed individuals are further subject to a travel ban.
It is notable that these EU designations are done under four different existing sanctions regimes, namely the sanctions regimes concerning Libya,5 Ukraine6 and Syria,7 as well as the EU Global Human Rights Sanctions Regime.8
To ensure compliance with the newly imposed measures, economic operators should conduct due diligence to determine the beneficial owners of customers, agents, and other third parties with whom they conduct business. A rigorous screening of party names, as well as the ownership structure, against applicable sanctions lists is necessary to avoid potential sanctions violations.
1 According to the EU, the newly listed individuals are "involved in serious human rights abuses, including torture and extrajudicial, summary or arbitrary executions and killings, or in destabilising activities in some of the countries they operate in", see official Press release of the Council of the EU of 13 December 2021.
2 Added to the EU Global Human Rights Sanctions Regime, see Council Implementing Regulation (EU) 2021/2195 of 13 December 2021 implementing Regulation (EU) 2020/1998 concerning restrictive measures against serious human rights violations and abuses.
3 Aleksandr Kuznetsov (Added to EU Libya sanctions set out in Regulation 2016/44); Dimitriy Valerievich Utkin (Added to EU Ukraine-related Regulation 269/2014 and the EU Global Human Rights Regulation 2020/1998); Denis Yurievich Kharitonov and Sergey Vladimirovich Shcherbakov (Added to Regulation 269/2014); Andrey Nikolaevich Troshev and Andrey Mikhailovich Bogatov (Added to EU Syria sanctions set out in Regulation 36/2012); Stanislav Evgenievitch Dychko and Valery Nikolaevich Zakharov (Added to Regulation 2020/1998). The Common Foreign Policy Decisions and implementing Regulations adding these individuals to the various EU sanctions regimes have been pubilshed in Official Journal No L 445I.
4 Added to the EU Syria sanctions by Council Implementing Regulation (EU) 2021/2194 of 13 December 2021 implementing Regulation (EU) No 36/2012 concerning restrictive measures in view of the situation in Syria.
5 Council Regulation (EU) 2016/44 of 18 January 2016 concerning restrictive measures in view of the situation in Libya and repealing Regulation (EU) No 204/2011, latest consolidated version available here.
6 Council Regulation (EU) No 269/2014 of 17 March 2014 concerning restrictive measures in respect of actions undermining the territorial integrity, sovereignty and independence of Ukraine, latest consolidated version available here.
7 Council Regulation (EU) No 36/2021 of 18 January 2012 concerning restrictive measures in view of the situation in Syria and repealing Regulation (EU) No 442/2011, latest consolidated version available here.
8 Council Regulation (EU) 2020/1998 of 7 December 2020 concerning restrictive measures against serious human rights violations and abuses, latest consolidated version available here.
Julia Marssola (White & Case, Legal Trainee, Brussels) contributed to the development of this publication.
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