Credit: Timon Studler via Unsplash
## The reach beyond the list In October 2022, Ukraine's National Security and Defence Council designated [Eugeny Giner](https://www.opensanctions.org/entities/Q3059629/), CSKA Moscow's president since 2001 and, allegedly, a representative of the former Luzhniki criminal group. The listing runs for ten years, and Ukraine has kept returning to the network around him since. [In May 2026](https://www.president.gov.ua/en/news/ukrayina-zastosuvala-sankciyi-proti-rosiyan-i-kompanij-yaki-104377) Kyiv extended measures against three more people it ties to a financial-industrial group Giner co-founded, his son [Vadim](https://www.opensanctions.org/entities/Q136417700/) among them. Thirteen months later, in November 2023, a company called [Yakhonty Kursk](https://www.opensanctions.org/entities/ru-inn-4632299086/) was registered in the city of Kursk. It doesn't appear on any sanctions list. Yet, according to the Russian company register, one of its major shareholders is [a hotel management company](https://www.opensanctions.org/entities/ru-inn-5017116860/) outside Moscow, half of which is, in turn, owned by Giner. ```mermaid flowchart TD subgraph t1["TIER 1 · designated"] giner["Eugeny Ginersanction"]
end
subgraph t2["TIER 2"]
bluecastle["Bluecastle Enterprises Limitedsanction"]
yakhonty["Yakhonty Management Companysanction.control sanction.linked"]
yakhonty_other["Yakhonty Regionssanction.control sanction.linked"]
end
giner -- "owns 75% or more" --> bluecastle
giner -- "owns 50%" --> yakhonty
giner -. "owned 50%, ownership ended by dissolution" .-> yakhonty_other
yakhonty -- "owns 99%" --> kursk
classDef designated fill:#fef2f2,stroke:#9f0712,stroke-width:2px,color:#82181a
classDef derived fill:#fffbeb,stroke:#bb4d00,stroke-width:2px,color:#7b3306
classDef none fill:#fafafa,stroke:#d4d4d4,stroke-width:2px,color:#525252
class giner,bluecastle designated
class yakhonty,kursk derived
class yakhonty_other none
```
You won't find these companies on any sanctions list. But the list is only half of the story. Across many sanctions regimes, ownership can be as important as designation, with [OFAC's 50 Percent Rule](https://ofac.treasury.gov/faqs/topic/1521) being the best-known example: property of a designated party counts as designated whether or not its name hits a match on a screening list. And now it does.
Even though our data has always carried that ownership chain, only now can we tell which of those links are ownership and which mean mere adjacency.
## One tag doing two jobs
`sanction.linked` used to mark everything within reach of a designation. It covered the employer of a sanctioned person, a company director, a spouse, and a subsidiary sitting several layers below a sanctioned owner. All of these entities were related to the originally sanctioned entity in some way, but the links between them did not all carry the same weight.
That sprawl has now come to an end. From now on, `sanction.linked` covers two things:
- Direct adjacency to a designated entity across a curated set of relationships: [ownership](https://www.opensanctions.org/reference/#schema.Ownership), [directorship](https://www.opensanctions.org/reference/#schema.Directorship), [membership](https://www.opensanctions.org/reference/#schema.Membership), [employment](https://www.opensanctions.org/reference/#schema.Employment), [association](https://www.opensanctions.org/reference/#schema.Associate), [family](https://www.opensanctions.org/reference/#schema.Family) and [succession](https://www.opensanctions.org/reference/#schema.Succession), plus the relationship between a company and the securities it issues. These are all one-hop relationships, in either direction.
- Every entity in a `sanction.control` chain, because control is a subset of linkage: every controlled entity is linked, but not every linked entity is controlled.
The scope becomes evident when looking at the [Table Tennis Federation of Russia](https://www.opensanctions.org/entities/ru-inn-7704058539/), where another [alleged member](https://www.president.gov.ua/en/news/ukrayina-zastosuvala-sankciyi-proti-rosiyan-i-kompanij-yaki-104377) of the former Luzhniki criminal group, [Alexander Babakov](https://www.opensanctions.org/entities/Q2833421/), has served as president since 2015.
{% center %}
```mermaid
flowchart TD
babakov["Alexander Babakovsanction"]
zavalyuev["Oleg Zavalyuevsanction.linked"]
babakov -- "president since 2015" --> federation
zavalyuev -. "general director since 2025" .-> federation
classDef designated fill:#fef2f2,stroke:#9f0712,stroke-width:2px,color:#82181a
classDef derived fill:#fffbeb,stroke:#bb4d00,stroke-width:2px,color:#7b3306
classDef none fill:#fafafa,stroke:#d4d4d4,stroke-width:2px,color:#525252
class babakov designated
class federation derived
class zavalyuev none
```
{% /center %}
## The mechanics of `sanction.control`
`sanction.control` covers companies, assets, and vessels owned by a sanctioned person or company, whether the ownership is direct or through one or more layers of subsidiary ownership. While the directors and direct owners of a sanctioned company are assigned the topic `sanction.linked`, `sanction.control` is reserved for assets controlled through ownership. An end date on a shareholding stops the chain, so holdings that have since been sold fall away.
This is the starting point for *OFAC's 50 Percent Rule* analysis. We apply no percentage threshold, because reliable ownership figures are rare across most jurisdictions where this matters. `sanction.control` records that a relationship exists rather than whether it clears a particular bar. The threshold itself depends on the context in which the relationship is reviewed.
## The chain beyond
The Russian company registry also shows Giner holding a 50% stake in [Agroinnovatsiya](https://www.opensanctions.org/entities/ru-inn-9709050230/), a Moscow wholesale business set up in 2019, which, in turn, owns [a trading house](https://www.opensanctions.org/entities/ru-inn-9709061391/) of the same name and further companies in Astrakhan and the Moscow region. None of them are listed under any sanctions regime.
```mermaid
flowchart TD
giner["Evgeny Ginersanction"]
agro["Agroinnovatsiyasanction.control sanction.linked"]
trading["Trading House Agroinnovatsiyasanction.controlsanction.linked"]
astrakhan["Agroinnovatsiya Astrakhansanction.controlsanction.linked"]
region["Agroinnovatsiya Moscow Regionsanction.controlsanction.linked"]
giner -- "owns 50%" --> agro
agro -- "owns 100%" --> trading
agro -- "owns 70%" --> astrakhan
agro -- "owns 100%" --> region
classDef designated fill:#fef2f2,stroke:#9f0712,stroke-width:2px,color:#82181a
classDef derived fill:#fffbeb,stroke:#bb4d00,stroke-width:2px,color:#7b3306
class giner designated
class agro,trading,astrakhan,region derived
```
Until now, these entities were captured only by `sanction.linked`, a label that could just as easily have pointed to a shared director or another relationship entirely. `sanction.control` makes the ownership chain explicit.
Some ties are control; others are only proximity. The two topics now distinguish between what the data has always shown: some relationships are simply closer than others.