Unmasking the oligarchs – Using open source data to detect sanctions violations

Abstract

Russia’s invasion of Ukraine in February 2022 led Western governments to impose extensive sanctions on the Russian economy and the people who maintain the regime - the so-called oligarchs. The enforcement of these sanctions and the manoeuvres of these oligarchs to evade them have created new challenges for the authorities, industry and society at large. This study aims to unmask sanctioned oligarchs who are beneficial owners of companies in the UK. The approach is based on the assumption that the actions of oligarchs leave detectable traces in the UK company register. Inspired by simple tools developed by volunteers for citizens doing their own intelligence work, software has been developed to achieve three different research objectives: to develop indicators of sanctions evasion, to demonstrate that it is possible to do useful intelligence work using only the resources available to the average citizen, and to develop a software tool to identify officers in the UK company register who are suspected of being linked to sanctioned oligarchs. The findings underscore the importance of open source investigations, reflecting a burgeoning intelligence phenomenon introduced as ‘citizen intelligence’, which has the potential to enhance the protection of society by building a more democratic and diverse intelligence community. This study opens the door for further research into the actions and tactics of sanctioned individuals, providing insights to protect global financial integrity and security.