The list names the directors, not the companies they run
7 min read
On 7 August 2026 the Council adopted two twin acts, published the same day in the EU Official Journal: Council Implementing Regulation (EU) 2026/1940 and Council Decision (CFSP) 2026/1939, amending Decision 2014/145/CFSP. Together they add five names to Annex I of Regulation (EU) No 269/2014, on restrictive measures tied to the war in Ukraine. They are five natural persons, each identified by the seat they hold: director general, director. The companies they run — drone software, satellite navigation receivers, gyroscopes for a ballistic missile — do not enter the list: they sit only in the statements of reasons. We are not commenting on the substance of the sanctions here: we are looking at what changes for anyone screening counterparties when buying technology.
Five entries, five seats
The annex opens plainly — quoted throughout in our translation from the Journal’s Italian text: “The following persons are added to the list of natural and legal persons, entities and bodies set out in Annex I to Regulation (EU) No 269/2014.” Five entries follow, numbered 2106 to 2110, all under the heading “Persons,” all with a listing date of 7.8.2026. What follows is what the statements of reasons assert: these are the Council’s allegations, not findings of ours, and we report them as such.
2106 — Ramil Nailevich Badgutdinov, “director general of JSC Serpukhov Plant ‘Metallist’,” which produces “gyroscopic motors, gyroscopic units and various precision electromechanical sensors and devices” and “takes part in manufacturing the 9B918 navigation system of the 9M723 ‘Iskander-M’ ballistic missile.”
2107 — Sergey Aleksandrovich Bashkov, “director of Limited Liability Company ‘Irz-Svyaz’,” a Russian manufacturer of communication systems for navigation receivers, used on the “Orlan-10” and “Tachion” UAVs; a company “of systemic importance in Russia” in GPS and GLONASS navigation receivers.
2108 — Sergey Nikolaevich Bessonov, “director general of LLC ‘AEROMAKS’,” which “develops software enabling drones to carry out various aeronautical operations, including aerial photography and the collection, processing and preparation of cartographic data and spatial information,” and produces the SH-3000/-750/-450/-350 helicopter drones.
2109 — Viktor Evgenevich Ivanov, “director general of JSC Research Institute of Precision Instruments NII TP,” part of the state corporation Roscosmos: working on the Kasatka-R synthetic-aperture space radar and the Compact-4 radar, “developed to capture highly detailed images of terrain and objects.”
2110 — Aleksandr Yurevich Dyukarev, “director general of Joint Stock Company ‘Krasnoyarsk Machine-Building Plant’,” which “produces the RS-28 ‘Sarmat’ ballistic missile.”
All five entries close with the same formula, verbatim: “[Name] therefore provides material support to the Russian military-industrial complex, including by taking part in the development, production or supply of military technology and equipment.” The person, not the company, is the subject of that sentence.
What the list actually freezes
The effect of listing sits in Article 2 of Reg. (EU) No 269/2014. Paragraph 1: “All funds and economic resources belonging to, owned, held or controlled by any natural person or any natural or legal persons, entities or bodies associated with them as listed in Annex I shall be frozen.” Paragraph 2: “No funds or economic resources shall be made available, directly or indirectly, to or for the benefit of the natural or legal persons, entities or bodies associated with them listed in Annex I.”
The two phrases that matter are “owned, held or controlled, directly or indirectly” and “for the benefit of.” They do not mean that JSC Serpukhov Plant “Metallist” or LLC “AEROMAKS” are beyond reach: if either company is controlled, even indirectly, by one of the five listed persons — or if a transaction with that company ends up benefiting one of them — the freeze can still reach it.
A distinction the act does not draw for you: being a general director is not the same as controlling. The role recorded in the list is managerial; control is a corporate fact, established on ownership and powers, not on job title. They often coincide — but they are verified separately.
That is not automatic. It is a check that falls to the operator: tracing who actually controls the counterparty, and whether that name appears in Annex I. The fact that the registered name is absent from the list does not close the question — it opens it. Article 3(2) explains why the check is possible: “Annex I shall include the reasons for listing the natural or legal persons, entities and bodies concerned.” The statements of reasons are public for exactly that purpose: they are the material a procurement office builds its own check on.
The perimeter is no longer made of steel mills
The second thing the statements of reasons say, read together, is the kind of product. No blast furnaces, no heavy assembly lines: software that plans drone flights and processes aerial imagery, there are GPS and GLONASS satellite navigation receivers, there is a synthetic-aperture radar built for “highly detailed images of terrain,” there are gyroscopic motors and units for a missile guidance system. Components and code: things that enter a civilian supply chain without looking, on the surface, anything like a weapon.
AEROMAKS is the clearest case. Entry 2108’s statement of reasons does not stop at drone software: it records that “by the end of 2024 the company had signed 13 government contracts,” and that “Gazprom Neft, Russian Post and the Moscow city department of information technology were among its clients.” A postal operator, a municipal IT department, an oil company: seen from outside, these are the clients of a civilian aeronautical software vendor, not a supplier to the military-industrial complex.
For anyone doing due diligence on a component or software supplier, outward appearance — who buys, what it sells — is not enough to rule out a link to the list: what is needed is tracing who runs and controls it, not stopping at the catalogue.
How we check it
In the counterparty screening we run for clients, we do not stop at matching company names against Annex I: we trace the directors and beneficial owners of every critical supplier, and check those names — not just the company name — against the list. We reread the statements of reasons in full, because they are public and say what a company actually does, not just its sector. And we keep the data and the conclusion in a register dated to the day of the check: a list that updates every few weeks makes a month-old check obsolete fast.
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What to do, in practice
- Screen people, not just companies: trace the directors and beneficial owners of every critical supplier, and check those names — not just the registered name — against Annex I.
- Reread the statements of reasons, not just the names: they say what a company actually produces, and let you recognise it after a change of name or structure.
- Date every check and repeat it: Annex I is updated constantly; an undated check is already stale.
- Extend the check to software and component suppliers, not just makers of finished goods: the 7 August entries concern code and sensors, not steel.
- Put in the contract the supplier’s duty to report changes of ownership and directors without delay.
The two axes, applied
Complying: counterparty screening becomes a check that runs on the supplier register and contract documents, with a dated log — who was checked, against which version of Annex I, with what outcome and statement of reasons read — ready to produce for an inspection or a board. Not an opinion that ends in a single email.
Decide: the same system holds registers, contracts, company searches, documents and systems together in a single operating model, on which AI agents execute decisions with a human operator in command, for large enterprises, defence, government and healthcare. When the annex changes — and it changes often, as 7 August shows — the answer to “which suppliers are affected, and under which contract” arrives in hours, not weeks.
Always in two modes: on-premises, on self-contained machines with no deep integration into the client’s network, or a dedicated cloud, with a data centre in Italy — always with shared management. It applies to procurement in defence as much as to compliance in manufacturing: the dual-use components of 7 August — gyroscopes, receivers, radar — move through the same suppliers.
Do you have a supplier list that no one has ever checked beyond the registered name? Talk it through with one of our engineers: the first session is at no cost.