the general conditions under which persons and entities sanctioned under the Russia Regulations and Belarus Regulations could pay legal fees to UK service providers.[1] 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”[2] When pressed on how the FCDO monitors sanctions waivers, he noted that there would be “communication between Departments”.[3] He indicated that relevant advice on sanctions waivers would come to him via officials, but clarified that he had received “none specifically”.[4] 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.[5]
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.[6]
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
