Frequently asked questions

#161:

Why does the database include Russian company data from 2022?

Category: Policy · Last updated: · Permalink

Following its full-scale invasion of Ukraine, the Russian government has passed special rules regarding the reporting duties of entities targeted by international restrictive measures. In effect, this means that a small set of Russian companies - those targeted by international sanctions - have been enabled to falsify the records they file with the company registry.

For OpenSanctions, this leads to the paradox situation that the official EGRUL registry, which is operated by the Russian Federal Tax Service (FNS), is no longer a trustworthy source on the structure, control and ownership of that specific group of companies - the subset we are most interested in.

In order to compensate for this company information blackout, our data factory processes both up-to-date and historic data going back to January 1, 2022, before the full-scale invasion and the full disengagement of the Russian economy from the rule of law. The EU has validated this approach with Council Decision 2025/904: “In cases where Russian legislation allows for the suppression or the concealment of information contained in national public registers or databases, or the entry of false or misleading information therein, it is appropriate for the last available information dating from before 24 February 2022 to be considered accurate unless more recent and reliable information is available”, the decision said.

Using this approach, we can show information about the control and ownership of companies that have had this information redacted from the latest data published by the official source. For an in-depth explanation of the why and how of our data processing, take a look at our blogpost on this topic.

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