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Rh as of 7 July 2023.230 We identified 44 individuals and 37 entities that had been sanctioned—in one or more of these three jurisdictions—for their direct connection to the Wagner Network, or for relevant activities in support of Prigozhin. According to our analysis (presented in Appendix 1), the UK has sanctioned Wagner-linked targets at a lower rate than either the EU or the US. Specifically:


 * Among the individuals identified, the UK has sanctioned 15 of 44, i.e. around one in three (34%). In comparison, the US has sanctioned 61% and the EU 68%.


 * Among the entities identified, the UK has sanctioned 5 out of these 37 (13.5% sanctioning rate). By comparison, the EU has sanctioned 16 of these entities (43%) and the US has sanctioned 30 (81%).

Beyond these 44 individuals and 37 entities, the UK may have applied sanctions to additional targets, without making clear their association to the Wagner Network or to Prigozhin when doing so. When questioned on this point, the Minister appeared unsure as to why the UK may have sanctioned fewer individuals and entities than the US and EU, suggesting it may be because they are “larger”. He added:

"We work with our allies. If you have a list there that you think we should be seeing, I imagine that that list will be considered by our sanctions team."

Beyond these 44 individuals and 37 entities, the UK may have applied sanctions to additional targets, without making clear their association to the Wagner Network or to Prigozhin when doing so. When questioned on this point, the Minister appeared unsure as to why the UK may have sanctioned fewer individuals and entities than the US and EU, suggesting it may be because they are “larger”. He added:

In subsequent correspondence, the Minister disputed that the UK has sanctioned fewer people than the United States. However, the supporting statistics he provided referred to individuals sanctioned under the wider Russia sanctions regime, rather than those sanctioned specifically for their role within the Wagner Network. Appendix 1 provides our own list for the FCDO’s consideration. We acknowledge that there are specific reasons why the UK may have sanctioned at a lower rate than these allies.

47. The Government further implied that its limited sanctioning of specific Wagner-linked entities is irrelevant. It stated that its designation of the ‘Wagner Group’ in 2022 automatically freezes the assets of entities that the Wagner Group owns or controls.