This column suggests that the asymmetric treatment between the EU and the US may be a manifestation of biases in the procedure for imposing sanctions.
Simeon Djankov is Policy Director at London School Of Economics And Political Science
Cross-posted from VoxEU
Russian oligarchs, Photo: Creative Commons
Since the start of Russia’s invasion of Ukraine more than three years ago, the EU has adopted 16 packages of sanctions, including sanctions on 2,500 individuals who have allegedly contributed to the war in Ukraine through their business or public activities (Cecchetti and Berner 2022, Nigmatulina 2022, Lastauskas et al. 2023). The US has adopted a similar number of individual sanctions, though spread over many more decisions by the US Department of the Treasury.
After so many rounds of sanctions, one would think that there would be a near-complete overlap between the sanctions list of the EU and that of the US. This is, however, not the case and the apparent asymmetry raises the possibility that self-serving motives play a part in the omission of Russian individuals from the sanctions’ lists. Such motives have been demonstrated during the EU ministerial debates on imposition of sectoral sanctions (Djankov and Golovchenko 2024, 2025). For example, Belgium has been reported to have blocked sanctions on diamonds trade; Greece has blocked sanctions on oil tankers and Hungary has blocked sanctions on Russian gas supply.
In this column I investigate the asymmetry between EU and US sanctions for the case of individuals who according to Forbes were among the 50 richest Russians just before the war broke out. I identify individuals who are sanctioned in the US but not by the EU, and vice versa (Figure 1). I then attempt to discern patterns in their business activities that may explain this inconsistency (Guriev and Durnev 2007). One possible pattern arises: non-sanctioned individuals run businesses that either provide critical materials for European companies or own EU companies that themselves provide such critical inputs to EU markets. In other words, exemptions from EU sanctions seem to be related to integration in the European economy. There is weaker evidence that the same pattern holds true for individuals sanctioned by the EU, but not the US.
Figure 1 Sanction status of top 50 wealthiest Russians
Source: Own calculations based on Forbes December 2021 list and sanctions data.
These results relate to the growing literature on economic sanctions over the past half century, which shows that unilateral sanctions are often off the mark, while multilateral sanctions tend to be better-targeted (e.g. Morgan et al 2023, Djankov and Su 2025).
Cases of asymmetric sanctions in the EU
We identify eight cases among the top 50 wealthiest Russian businesspeople, where an individual is sanctioned by the US for his or his companies’ contribution to the war but is omitted from the EU sanctions lists until March 2025. This is a high proportion, as half of the top 50 richest people are on the EU list, so there is a discrepancy in a quarter of the sanctioned cases.
One such discrepancy is Russia’s richest individual in 2024. His company supplies over a quarter of Europe’s nickel imports and a third of the world’s palladium, making it crucial for European automotive and semiconductor industries. Its battery materials facility in Finland, developed in partnership with German chemical conglomerate BASF, is often cited in EU official documents as critically important for Europe’s green transition.
The co-owners of Russia’s Kalashnikov Group and Transmashholding, with both companies being major suppliers to the Russian military, remain unsanctioned by the EU. This omission appears rooted in their extensive business presence across Europe – the conglomerate Transmashholding is headquartered in Switzerland, owns controlling stakes in Dutch locomotive manufacturers TMH Alstom B.V. and Railcomp B.V., owns an engine plant in Germany, and has extensive industrial assets in Hungary. The partners also own the Riga Electrical Machinery Plant in Latvia, with related business operations to both Lithuania (supplying railway equipment) and Estonia.
Another wealthy Russian individual’s omission from EU sanctions may be due to his companies’ significant role in European aluminium production – with Rusal’s facilities providing 40% of aluminium products in the EU. Rusal has industrial facilities in Sweden (Kubikenborg Aluminium AB), Ireland (Aughinish Alumina), Germany (Aluminium Rheinfelden), and Italy (Eurallumina). Rusal also has trading operations in Germany, the Czech Republic, Austria, France, the Netherlands, Italy, Slovakia, Croatia, Poland, Spain, and Estonia through its Swiss subsidiary (RS International GmbH), the UAE (Al Plus Global DMCC), and Spain (C. Steinweg-Iberia S.L.). His investment group Renova owns major stakes in Swiss industrial firms Sulzer (pumps manufacturer), Oerlikon, and Schmolz + Bickenbach. It is also the controlling shareholder in Cyprus’s largest commercial bank.
Four other individuals fit this category. One is the owner of PhosAgro, Europe’s largest producer of phosphate-based fertilizers. PhosAgro products are also processed in Finland, Poland, Norway, Belgium and the Netherlands. Two others control Food City markets, which source products from nearly every EU country’s food and agricultural exporters. A final (pharmaceutical) businessman owns Frankfurt-Hahn Airport, serving European carriers Ryanair and Wizzair. His Augment Investments runs businesses in half-dozen EU countries through the acquisition of Mondi, a major European paper and packaging group.
Cases of asymmetric sanctions in the US
We identify only two cases among the top 50 wealthiest Russian businesspeople, where an individual is sanctioned by the EU but not the US. The omission of the first individual may stem from his extensive investments in US companies receiving government contracts. Through investment company Innes Worldwide, he has invested in two dozen US firms, including Kiana Analytics, a real-time location services startup, and Cellphire Therapeutics, with the latter receiving several federal contracts from the Department of Health. The second discrepancy is the majority owner of Acron Group, Russia’s largest fertilizer producer. Acron accounts for 16% of fertilizer in the US market, including more than half of urea-ammonium nitrate solution sales.
Relevance of this asymmetry
The asymmetric treatment between the EU and the US may be a manifestation of biases in the procedure for imposing sanctions. Sanction algorithms likely include the ‘local content”’of candidates and thus take into account characteristics other than the purported one – the contribution to the war in Ukraine (Djankov and Su 2025). This bias may be limited should sanctions be imposed by a multilateral body like the United Nations (Morgan et al. 2009).
A related question is whether and how the frozen wealth of sanctioned individuals may be used to pay for the reconstruction of Ukraine and the compensation of war victims. The needed amounts are colossal (Masters and Merrow 2024) and various scholars (e.g. Bogdanova 2023) have suggested a sizeable contribution from sanctioned individuals. Yet my analysis documents that in a small sample of sanctioned rich Russian individuals, one-third have escaped sanctions by one or the other major sanctioning entity (the EU or the US). This asymmetry does not bode well for the convergence around the usage of frozen assets in the reconstruction and compensation efforts.
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