Since Russia’s invasion of Ukraine in February 2022, the multilateral Russian Elites, Proxies, and Oligarchs (REPO) Task Force has immobilized approximately $300 billion worth of Central Bank assets. Russia will attempt to utilize individuals, entities, and alternative means of avoiding sanctions. Due diligence has never been more important for the private sector – and Open-Source Intelligence (OSINT) can help.
On March 20, 2024, the United States Treasury Department announced sanctions against Ilya Gambashidze, founder of a Moscow-based company Social Design Agency (SDA), and Nikolai Tupikin, CEO and current owner of the Russia-based Company Group Structura LLC (Structura). Both individuals were involved in a “persistent foreign malign influence campaign at the direction of the Russian Presidential Administration.”
These sanctions stem from an April 2021 Executive Order to “impose costs for Russian Government actions that seek to harm us.” A lot has changed since then – as these sanctions show. The Russian invasion of Ukraine has brough a flurry of sanctions that are illuminating the breadth and depth of foreign adversaries skulking around in the digital environment. In a global commercial environment, companies must be vigilant to protect their intellectual property, reputation, and their people. Due diligence is an often-overlooked security threat. The traditional hiring practices are not enough. Business-to-business relationships must also be vigorously vetted. Foreign entities can easily set up U.S. subsidiaries with data and information transfers back to governments and intelligence agencies. U.S. companies must now monitor customers, partners, and data to maintain compliance in a dynamic geopolitical environment. Many small and mid-sized companies have been surprised to find sanctioned individuals or entities within their partner or customer base by doing minimal due diligence. Due to limited resources, this process is often overlooked. Adversarial nations are not only targeting companies that focus on National Defense or Security, the wide array of dual-use products and services allow for a much bigger attack surface.
Due diligence is not only a defensive measure, but protection against adversarial offensive actions. Structura and Social Design Agency were no doubt collecting information but also disseminating harmful mis-and-disinformation to undermine the United States and her allies. With record-breaking sanctions-related settlements and increasing penalties, the private sector must be able to identify and report sanctions violations or potential violations in a timely manner. OSINT can provide the key to success by linking publicly available information together through tailored methodology.
There will be more sanctions related to malign influence and foreign ownership or involvement. Populations around the world are waking up to malign influence operations and subversion – look no further than the United States House of Representatives Bill to force TikTok to divest from Chinese ownership. There are more sanctioned individuals and companies than any time in history – and the world is not getting any safer. Russia is now the most sanctioned Nation in the world, with more than 16,100 sanctions on individuals and entities currently in place, Russia has more than six times more sanctions than any other nation on the planet since its invasion of Ukraine. The ubiquity of adversarial entities and capital is something the world will continue to wrestle with at the expense of bystander companies. OSINT offers a solution to mitigate the risk commerce faces.
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