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Rh However, the Wagner Network encompasses a complex web of entities (paragraph 3). It is unclear how organisations that implement Government sanctions, such as banks and other financial institutions, are expected to know which entities are within their scope.

48. Witnesses were sceptical of the level of effort that national governments—including the UK—had devoted to mapping and tracking the Wagner Network, with the exception of Ukraine. Christo Grozev judged that sanctions on Prigozhin himself are “maxed out”. However, he believed that

"stopping all of those [Prigozhin-linked] people from being able to travel internationally—at least to the western world—might, incrementally, have a much bigger impact than slapping one more sanction on Prigozhin"

Grozev believed a travel ban could be a meaningful deterrent, because many in the Wagner Network see their involvement as transactional. He felt this tool could be stronger if the UK worked with Turkey: a popular holiday destination for many Russians. The Centre for Information Resilience, the not-for-profit organisation that carried out open-source research for this inquiry, also argued in favour of expanding sanctions targets, noting:

"Sanctions are rarely applied to individuals working as civilian specialists in key fields, for example mineral extraction, where Wagner-affiliated entities employ specialists in fields such as geology, gemology or logistics. Whilst some may not know who their ultimate benefactors are, these ‘faceless’ individuals make the wider network’s activities possible. Similarly, those who act as frontmen – directors of key companies, for example – are also largely ignored as avenues of research or accountability."

49. Alongside calls for the UK to apply further sanctions to the Wagner Network, some witnesses expressed doubt over the impact of the sanctions imposed to date. An FT investigation published in February 2023 analysed corporate records of Prigozhin-linked companies and concluded that Prigozhin had generated over $250 million from his commercial empire in the four years prior to the full-scale illegal invasion of Ukraine, despite ever-increasing sanctions on him. In February, the Minister told us he was “confident” that there were no significant assets of the Wagner Network in the UK that