Diogo Augusto reports on several domestic companies whose directors feature on the UK’s international sanctions list, that have so far evaded the authorities

Eleven UK companies with directorship links to individuals who are targets of Government sanctions due to their proximity to the Kremlin have not themselves been sanctioned, Byline Times has found.

After the invasion of Ukraine by Russia this past February, countries and international bodies have been implementing a series of sanctions in an attempt to hit Vladimir Putin and his regime.

Byline Times has searched the 1,267 individuals and 151 entities on the Consolidated List of Financial Sanctions Targets in the UK and has found 11 companies which, despite their link to designated persons, have not been sanctioned.

The firms are not accused of wrongdoing, though it is worth questioning the efficacy of the UK’s sanctions regime, when the companies associated with those sanctioned are able to operate seemingly unencumbered.


RCIF UK

The Russia-China Investment Fund (ICIF) was created through a bilateral agreement between the two countries and now includes Saudi Arabia. In an effort to seek mutual investment opportunities, the Chinese sovereign wealth fund contributed $1 billion and the Russian Direct Investment Fund (RDIF) – its Russian counterpart – contributed another $1 billion.

The fund is incorporated in China but also controls the RCIF UK, a British entity created to manage a UK branch of the fund. It was created in 2014 with a share capital of $3 million, now increased to $20 million.

One of the four directors of RCIF UK is, since 2014, Kirill Alexandrovich Dmitriev, a Kyiv-born Russian national featuring on the UK sanctions list.

According to the document, “As Chief Executive Officer of RDIF, Dmitriev is working as a director or equivalent of a Government of Russia-affiliated entity, and for a person which is carrying on business in a sector of strategic significance to the Government of Russia; and for a person which is carrying on business of economic significance to the Government of Russia, and is therefore obtaining a benefit from or supporting the Government of Russia”.

Companies House doesn’t specify any owners for RCIF UK and the fund is not listed on the sanctions list.

RCIF UK did not respond to our request for comment.

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Terra Services

Terra Services Limited (TSL) was incorporated in the UK in 2003 with sole director and owner Pavel Ezubov. TSL is a dormant company and declared in 2021 to have assets just over £300.000 and no employees.

Ezubov occupies entry number 245 on the UK sanctions list for being an associate of Russian oligarch Oleg Deripaska (entry 205).

Deripaska was the owner of TSL until, in January 2018, Ezubov took over.

TSL unsuccessfully sued the National Crime Agency in 2020 after a storage unit was searched and 11 boxes of TSL documents apprehended at the request of the US Department of State while investigating the case of Donald Trump associate Paul Manafort.

Under UK rules, TSL should be automatically subject to an asset freeze as it is owned by a designated person. However, it has not been included on the sanctions list.


Sberbanque de Russie

With a share capital of £1 billion, this currently dormant company incorporated in 2016 has 10 active directors, two of them are currently on the UK sanctions list.

51% of the company is owned by the Central Bank of the Russian Federation and the remaining 49% belongs to Sberbank of Russia, state-owned and the country’s largest bank. Sberbank is, itself, a target of financial sanctions. This information is on the company’s incorporation document and all subsequent updates have not reported a change. Yet, a spokesperson for Sberbank told Byline Times: “Sberbanque de Russie is not related to Sberbank Group.”

Sberbanque director Herman Gref is listed as number 316 of the UK sanctions list for being CEO and board chairman of Sberbank. According to the UK Government, “Sberbank has been designated as a person involved in obtaining a benefit from or supporting the Government of Russia. As the Chief Executive and Chairman of the board of Sberbank Gref is associated with a person involved in obtaining a benefit from or supporting the Government of Russia, and has received a financial benefit from that person”.

Lev Khasis, another director and first deputy chairman of Sberbank, was included in the list (431) through an urgent procedure after Canada imposed sanctions on him and the UK considered it in the public interest. There have been reports that Khasis, a dual US-Russian citizen, fled Russia suddenly shortly after the invasion of Ukraine.

Sberbanque, not owners is not listed on the UK sanctions list.


Eugene Tenenbaum

Tenenbaum is a Ukraine-born Canadian national, featured on the UK sanctions list due to his association with Roman Abramovich, the Russian billionaire who is still listed as the owner of Chelsea Football Club.

Tenenbaum is linked to six different companies which all seem to be in the Chelsea FC orbit. He is one of the directors of Fordstam Limited, the parent company of the group through which Abramovich’s financing of the club was facilitated. There are then five more companies under the umbrella of Fordstam Limited which all list Tenenbaum as their director: Fordstam Developments Limited, Chelsea Digital Ventures Limited, Chelsea FC Holdings Limited, Stamford Bridge Projects Ltd, Chelsea Football Club Limited.

As a result of sanctions imposed on Abramovich, he has announced his intention to sell the club. However, the process has been bumpy with one of the issues being the outstanding £1.6 billion debt that Fordstam owes Abramovich.

Roman Abramovich still shows as the ultimate beneficial owner of Fordstam Limited  (and Chelsea Digital Ventures Limited) and, although it is expectable that this will change once the sale is complete, it is unclear whether Tenenbaum will continue as director of these six companies.

All the other companies list Fordstam Limited as the sole owner and none have been listed on the UK sanctions list.

Chelsea FC did not respond to our request for comment.

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Nigina Zairova

Zairova (entry 1234 on the sanctions list) is the director and, since March 2022, owner of Reashon Holding Ltd and Athlone House Limited. Although Zairova was always director of both companies, before March, they were owned by Mikhail Fridman.

According to the UK list of sanctioned persons “there are reasonable ground to suspect that Zairova is acting on behalf or at the direction of Fridman”.

Mikhail Fridman is on the list himself, at number 264, for being “closely associated with President Vladimir Putin”. He is also owner of Alfa Bank, Russia’s largest privately owned bank. Alfa did not respond to our request for comment.

Athlone House is the name of the large Victorian house Fridman bought in 2016 for £65 million and Athlone House Limited’s declared nature of business is: “activities of households as employers of domestic personnel”.

These companies should be automatically subject to an asset freeze as they are owned by a designated person. However, they have not been included on the sanctions list.


A UK Treasury spokesperson told Byline Times that: “The UK does not designate entities in their own right that could have exposure to sanctions through their ownership and control structure, as that could change at any time.”

However, an official financial sanctions guide, says: “An asset freeze and some financial services restrictions will apply to entities… that are owned or controlled, directly or indirectly, by a designated person”.

It adds: “The UK Government will look to designate owned or controlled entities/individuals in their own right where possible”.

While ownership is sometimes easily accessible, control is a fuzzier concept. One of the roles of the Office of Financial Sanctions Implementation (OFSI) is to enforce financial sanctions. However, when asked if it knew whether these companies had or should have their assets frozen or how third parties could know whether a company was controlled by a designated person, the Treasury declined to comment.

The Treasury spokesperson also said that OFSI was not able to comment on specific companies due to data protection laws, but declined to specify which laws prevented this.

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