Credit: Timon Studler via Unsplash
The reach beyond the list
In October 2022, Ukraine's National Security and Defence Council designated Eugeny Giner, 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 Kyiv extended measures against three more people it ties to a financial-industrial group Giner co-founded, his son Vadim among them.
Thirteen months later, in November 2023, a company called Yakhonty Kursk 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 outside Moscow, half of which is, in turn, owned by Giner.
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 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, directorship, membership, employment, association, family and 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.controlchain, 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, where another alleged member of the former Luzhniki criminal group, Alexander Babakov, has served as president since 2015.
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, a Moscow wholesale business set up in 2019, which, in turn, owns a trading house of the same name and further companies in Astrakhan and the Moscow region. None of them are listed under any sanctions regime.
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.
