Independent Researcher

ADVISORY POLICY PAPER.

1. Executive Overview.

The policy advisory ecosystem across the UK and the US faces a grave and underappreciated threat: The infiltration of think tanks, NGOs, and policy forums by hostile state actors that undermines their integrity.
It is recommended that governments in both the UK and US create obligatory investigative mechanisms that allows transparency in the funding sources, as well as vetting of the personnel in key positions within these entities. It is double central proposition.
To begin with, the sanctioning of businesses and trade restrictions with so-called hostile states cannot work as a policy instrument unless the governments first run a serious programme to identify and neutralise the covert penetration of the very institutions that design, analyse, and advocate those sanctions. In addition to targeting the entities through which these individuals operate, where for example, the evidence shows that a foreign national or domestic actor has been engaged in covert influence operations through policy organisations targeting UK or US national security, or producing material which is knowingly harmful, they should be designated as a sanctions targets themselves.

2. Sanctions having little impact on the infiltration what sanctions may create.

An enormous institutional capital has been invested by western governments in sanctions as a tool of foreign policy. Utilized with greater frequency by the United States, the United Kingdom and European Union for a host of purposes, including asset freezes, travel bans, arms embargoes as well as import and export controls, sanctions have now become a key tool of economic statecraft (Chatham House, 2025). The effectiveness of these instruments is undermined by a vulnerability that sanctions packages cannot address.
The encroachment of the advisory bodies that shape their design, calibration, and enforcement.

The reasoning is quite straightforward. The strength of sanctions regimes draws on the accuracy of intelligence, analysis informing its construction. This means that if the think tanks, NGOs and policy forums who advise governments which parties to sanction and how to ensure compliance are getting foreign funding which is not disclosed or they have people on their payroll who have undisclosed affiliations, then the architecture of sanctions itself is structurally compromised from inception.
Sanctions are increasingly being applied these days and their heightened use has led to sanctioned countries such as China, Russia, North Korea and Iran to enhance their cooperation. At the same time, it raises worries about enforcement and unintended consequences, Chatham House (2025) notes. Nonetheless, inadequate attention seems to have been paid to the possibility of advisory capture by hostile actors constituting a key causal mechanism of enforcement failure.

As was made clear during testimony before Congress, North Korea, Russia, China, Iran, and Syria are working together to undermine Western sanctions regimes. The incident is a demonstration of their plan to disrupt the primacy of the US dollar, which would ultimately impact US foreign policy and national security (Foundation for Defense of Democracies, 2023). This axis does not limit its activities to trade avoidance. It also reaches into the information sphere, the very institutions whose advice Western governments consult when determining their responses. In the first instance, it is critically important to take this route into account. Those who facilitate this infiltration, whether knowingly or by willful complicity, are equally liable to a physical trader transporting sanctioned goods and should be treated likewise by the law.

3. The Impacts of Lack of Transparency on Public Policy 3.3. Case Study: Anti-Climate Funding

Probes and transparency audits have repeatedly shown that most of the UK’s influential policy organisations enjoy minimal or no disclosure of their financial sponsors. According to an analysis conducted by openDemocracy, the UK’s most opaque think tanks, including some of the most politically influential outfits in Westminster, raised over £14 million from undisclosed donors over the last two years (openDemocracy, 2022a). An additional notable group is the various think tanks operating within the United Kingdom. Specifically, five major British think tanks which include the TaxPayers’ Alliance, the Institute of Economic Affairs, Policy Exchange, the Adam Smith Institute, and the Legatum Institute have collectively raised a total of $9 million from American donors since the year 2012. Of this amount, at least $6 million was immediately transferred to the UK. This represents 11% of the total UK receipts of these said organisations (openDemocracy, 2022b).

Transparency International UK has issued a warning about the think tank industry, which influences policy making in Westminster. It claims their funding opacity would lead a reasonable person to conclude that they are pushing positions in favour of undisclosed vested interests (openDemocracy, 2022a). In at least one instance, a financially opaque organization based in London presented fabricated evidence that resulted in false reporting in the British media. Also, a financially opaque French organization with suspected links to Russia produced disinformation which ended up being amplified by international media (Transparify, 2017).

The forensic message is clear; if foreign donors who are against the western sanctions policy are allowed to fund the organizations carrying out the very analysis for that designation, then they can have a say in the analytical intelligence on which decisions to sanction are based. Currently, in the UK, there is no legal requirement for think tanks to disclose their donors, which represents a significant gap in the country’s counter-intelligence architecture. Most importantly, individuals facilitating these clandestine activities be it middlemen, placement agents or recipients of covert funding from hostile states are not able to be sanctioned through the sanctions regime itself.

4. The legal basis for designating individuals who undermine national security through advisory infiltration.

The legally necessary framework for designating such persons exists and can be extended as required. The Sanctions and Anti-Money Laundering Act 2018 enables ministers so that they can create sanctions regimes and designate individuals or entities either to meet international obligations or to further UK objectives (House of Commons Library, 2026). According to LSEG, sanctions freeze financial assets, prevent trade with offenders, and bar persons who threaten security from entering the UK. Under this framework, sanctions serve to freeze the financial assets of a person, company, or government that is involved in harmful activity ; block trade transactions with a company or person which is alleged to be involved in illegal activity; and prevents a person who is a security threat from entering the UK (LSEG, n.d.).

According to UK Government (2020), sanctions “should seek to influence behaviour by altering the cost-benefit calculus of a wide range of designated individuals, not just the target. Key individuals are those that can bring about the desired change in behaviour, so the level of influence and overall effect must match.” In a similar manner, any of these objectives will equally apply to an individual who can be proven to have actively undermined UK or US national security by covertly channelling hostile-state influence through policy think tanks.

The Sanctions and Anti-Money Laundering Act 2018 (SAMLA) provides that regulations must provide that an “involved person” means a person who is or has been involved in an activity specified in the regulations, is owned or controlled by such a person, is acting on behalf of or at the direction of such a person, or is a member of or associated with such a person. (Sanctions and Anti-Money Laundering Act 2018, c.13) The term “involved person” is broad enough to capture not only those employed by a hostile state but also those acting at its direction, or in the interests of it, through the use of a seemingly independent policy organisation. Existing precedent exists for designating individuals on the basis of activities that destabilise Western interests. In 2022, for example, a British journalist was designated and added to the UK Sanctions List on the grounds of work undermining the territorial integrity and sovereignty of Ukraine (Wikipedia, 2026)

In the U.S., this power is conferred by the International Emergency Economic Powers Act (IEEPA) and the various Executive Orders issued thereunder to the Office of Foreign Assets Control (OFAC) of the Treasury Department allowing it to designate people and entities whose activities pose a threat to national security. It would be entirely logical and proportionate to extend existing enforcement doctrine powers to those who covertly act in the interests of hostile state through infiltration of think tanks.

Consequently, this study thus recommends that the UK and US governments adopt the explicit position that any individual, regardless of nationality, who is proven through investigation to have actively acted against national security by facilitating covert hostile-state influence within policy advisory organisations shall be liable to designation as a sanctioned person, subject to asset freezes, travel bans, and the full suite of restrictive measures available under SAMLA, IEEPA, and accompanying legislation.

5. Case Study I: Misinterpretation of West on Iran and the Israel-Iran Case.

The continuing confrontation of Iran and Israel is perhaps the most vivid illustration of how compromised or ideologically captured advisory channels can distort the understanding of governments. Western policymakers have turned to expert opinion in the form of think tank analysis, briefing papers, and testimony for decades regarding Iran’s internal governance, nuclear programme, and regional posture. There is an increasing amount of evidence which suggests that a share of these analyses has been financially influenced or taken place by individuals with undisclosed affiliations taking place among parties which possessed a vested interest in policy outcomes.

There has been an enduring asymmetry of information. Often, western legislators and officials have exhibited an inadequate grasp of Iran’s internal situation, the complicated factional politics, and the security establishment’s motives. Instead of proper and objective analysis, those that policy-makers have often received are distortions that have the effect of reinforcing existing policy biases. The Iran–Israel conflict is not merely a kinetic conflict. It is at the same time an information war in which the quality of intelligence that reaches decision-makers is itself a strategic variable.

If the advisory infrastructure falters, then this is exactly the domain where sanctions policy fails. If an undisclosed foreign influence has distorted the analytical foundations of that posture in think tanks and policy forums, western governments cannot calibrate their sanctions posture towards either Iran or the actors facilitating its military capabilities. Such person or persons, who distort the integrity of the debate in issue, through misrepresentation of facts, suppression of relevant facts or provision of material assistance to a hostile foreign power, should be deemed as actively compromising national security and be sanctioned as such. Taking action against businesses is a downstream enforcement action; ensuring the upstream analytical process is not subject to hostile intrusion and holding those who compromise it accountable, is the necessary condition.

6. The Former Soviet States Like Azerbaijan as Evasion Conduit of Sanctions.

As you consider the business networks through which enemy countries evade the West’s sanctions, the investigation of think tank vetting and individual accountability becomes clearer. A recent OCCRP investigation has shown that the UK sanctioned an oil tanker owned by the state-controlled Caspian Shipping Company of Azerbaijan for transporting Russian oil. The tanker had made eleven voyages to the Russian port of Primorsk in the last year (Canbäck and Bloss, 2025). The UK’s sanctions package announced in May 2025 targeted five citizens from Azerbaijan as well as two companies and nearly 100 vessels in what was described as a shadow fleet operation by Kremlin allies (Canbäck and Bloss, 2025).

According to analyst Maximilian Hess of the Foreign Policy Research Institute, Britain’s sanctioning of an Azerbaijani state-owned tanker was a big step, especially as the UK has historically been reluctant to push back against Baku because of the big presence of BP in the country (Canbäck and Bloss, 2025). This case exposes the intersection of energy diplomacy, corporate interests and sanctions enforcement, precisely the kind of nexus that hostile actors seek to exploit through covert influence over policy advisory bodies.
If the firms consulting with the UK government on Azerbaijani energy policy have undisclosed financial or personnel links to Baku, it means that any subsequent ability to identify and act on sanctions evasion is compromised from the outset. Those who act as conduits for that influence ,be it researchers, members of boards, go-betweems ,need to be designated personally if their conduct is found to undermine national security.

Azerbaijan is a far from isolated case. Kazakhstan, Kyrgyzstan, Uzbekistan, Georgia and Armenia disrupt the transhipment of sanctioned goods to Russia, with the Caucasus countries being used for the obfuscation of the origin of restricted imports (KIAR, 2025). In Moldova, three companies acted as intermediaries for Russia through shell companies that sold Western aircraft parts to Russian airlines. The involved businesses in this trade were worth about $15 million shortly after the 2022 invasion. (George W. Bush Presidential Center, 2026). In Armenia, electronic components producer TAKO LLC kept supplying RDS-1 (Russia’s defence sector) even after sanctions were imposed (George W. Bush Presidential Center, 2026). In 2023-2024, exports of the EU to Kyrgyzstan exceeded EUR 2.7 billion, compared to a pre-war average of roughly EUR 285 million, with specialists continuing to identify it as a back channel for dual-use goods reaching Russia (George W. Bush Presidential Center, 2026).

China accounted for nearly 90 per cent of the export-controlled items Russia imported via evasion networks by 2023 (Atlantic Council, 2025). This is because the West has attempted to exploit Russia’s weaknesses through sanctions, but that approach backfired. In response, the Kremlin is developing and propagating tactics for circumventing sanctions for an alternative economic international system. Jamestown Foundation ,2025

The countries mentioned above have diplomatic, economic, and cultural ties to Western policy institutions. Without a systematic examination of the possibility of those links reaching undisclosed presence of funds or personnel in think tanks and NGOs, sanctioning their commercial activities would simply be treating the symptoms while leaving the disease untreated. It is essential that the human infrastructure that makes this infiltration possible ,the analysts who bury inconvenient findings; the board members who facilitate undisclosed financial flows; the placement agents who place compromised individuals on advisory boards ,also become subject to sanctions designation once proven.

7. The paradox of enforcement: uncoordinated penetration and accountability leads to self-defeating sanctions

The existing sanctions on a large number of sanctions have caused sanctioned countries to cooperate more with each other. This sanction cooperation has seen the likes of China, Russia, North Korea, and Iran get closer together. Similarly, the American use of secondary sanctions has prevented ally government and business investments in sanctioned countries. Consequently, this has allowed hostile state investors to grab valuable assets and expand their global long-term influence (Chatham House,2025).

The situation that ensues creates a paradox within a paradox: when Western powers impose sanctions aimed at isolating potentially hostile actors, those very actors ,when infiltrating counter-measures are not used ,could rather be incentivised to increase their penetration of Western policy institutions.

Sanctions are more likely to succeed, as research shows, when these are accompanied by skilful diplomacy and high-grade intelligence, and these must also be supported by complementary policies and measures (Gates Forum, n.d.). This paper argues that the most crucial of these complementary measures ,and the one most glaringly absent from current policy ,is the systematic vetting and transparency enforcement of think tanks and NGOs, combined with a credible personal sanctions designation threat for those who have been shown to actively compromise the advisory infrastructure on which national security depends. This measure by itself will be a necessary but fatally insufficient measure without both operating in concert.
It is impossible to effectively penalize trade with an enemy state if the analytical underpinnings that dictate what must be penalized, whom must be targeted, and the manner of enforcement have themselves been compromised with impunity.

The use of deterrence is powerful. Individuals currently facilitating sanction evasion, for example, operating a shadow fleet tanker, are designated, and their assets are frozen, and travel bans imposed against them. However, an individual who undermines the sanctions regime’s intellectual basis, either by influencing the analytical foundations on which the regime itself rests, or by covertly directing hostile-state funding into policy organisations, is not similarly punished. It is intolerable asymmetry. This activity is, at the very least, equally damaging to national security as the first-mentioned activity. Furthermore, one can argue that this action is of a more damaging nature due to its ability to undermine not just one enforcement activity but the entire strategic direction of western policy.

8. Suggestions provided

The UK and US government regimes must embrace the following legal and administrative arrangements.

The first recommendation involves making funding disclosure mandatory through legislation requiring all think tanks, policy forums, and NGOs that advocate on policy issues or provide briefings to government to publicly disclose all funders over GBP 5,000 (or USD 5,000) on an annual basis. This also covers funding through intermediary vehicles.

It is recommended that a standardised protocol be established for the vetting of personnel. The relevant governments must administer background checks on those in senior research, advisory, or editorial roles in any organisation directly engaged with government policy, especially for any secret foreign links.

The third recommendation is the creation of a foreign influence register as an expanded register which builds off of existing foreign lobbying legislation to a number of case think tanks and NGOs which are funded by or have institutional links with assets connected with foreign governments.

It has been suggested that inter-agency intelligence sharing should be formalised through structured cooperation between national security agencies and parliamentary oversight so as to recognition of hostile foreign influence within the policy advisory ecosystem.

Fifth, there should be periodic transparency audits commissioned through independent reviews of funding and personnel structures of organizations that add to national security, defence and foreign policy deliberations.

In particular, if they wish to offer any formal or informal advice, funding sources and senior staff of the organisation engaged in the sanctions design and enforcement should undergo a prior integrity assessment and be found to be free from any undisclosed links to sanctioned states or proxies.

As a seventh step, and most importantly, formal policy should be devised for designating personal sanctions for individuals found to have actively undermined national security. The UK and US governments should set out a clear legal and processual route to the designation of any individual who it is shown, by due investigative process, has actively acted against UK or US national security through covertly facilitating the influence of hostile states in think tanks, NGOs, policy forums or other advisory bodies. This could use existing powers under SAMLA and IEEPA respectively. The designation must entail the full array of restrictive measures, such as asset freezes, travel bans, and prohibition on economic activity in the UK and US. According to the proposed recommendations, the level of evidence is rigorous but proportionate. It is derived from intelligence assessments, financial forensic analysis, and counter-infiltration. This measure would serve three important functions. First, it would deter would-be agents of influence who might otherwise operate here by establishing that there are personal consequences to covert activity carried out against national security. Second, it would constrain those who are already active in this field by denying their access to financial and logistical resources. Third, it would send a clear signal to hostile states that the UK and US consider infiltration of their policy advisory infrastructure as a national security threat of the highest order, attracting the same enforcement response as the physical evasion of sanctions.

9. Finale.

The examined cases distance the Western understanding of Iran, Azerbaijan’s aid to the Kremlin for circumvention of sanctions, and the larger web of former Soviet states allowing the Kremlin to bypass international restrictions indicates that the policy advisory architecture of both the UK and the US is ugly to enemy forces. The author of the paper contends that globally sanctioning businesses and restricting trade with the hostile state cannot be successful in isolation. Thus, business enterprises must expand their sanctioning policy so as to discourage companies from carrying out business activities within the hostile state. Governments must set out a clear systematic programme to identify and neutralise such covert infiltration of the think tanks that shape sanctions policy, and the NGOs and policy forums that they rely on. In addition, individuals who are proven through intelligence and investigation to be working against national security through this infiltration must themselves be designated as sanctions targets. Submission and capture rather than any sort of organic growth must define sanctions success. If this does not happen, there will be structural problems in enforcement. The proposed remedial measures including an extension of personal sanctions designation to proven agents of influence in the advisory eco-system are proportionate, legally sound and necessary to safeguard sovereign, evidence-based policy-making in an increasingly competitive geopolitical landscape.

References

R. Canbäck Moreover, K. Bloss. UK sanctions Azerbaijani state-owned tanker for shipping Russian oil. 2025, OCCRP, 13 May. Source Link: https://www.occrp.org/en/news/exclusive-uk-sanctions-azerbaijan-state-owned-tanker-for-shipping-russian-oil.

Who funds you? Open democracy “Tank think have taken to bank on try money sponsor.” Link: source

openDemocracy reported that US climate change skeptics gave millions to UK think tanks linked to the Tory party in 2022. Find the document at: https://www.opendemocracy.net/en/dark-money-investigations/think-tanks-adam-smith-policy-exchange-legatum-iea-taxpayers-alliance-climate-denial/.

In 2017, ‘Secret Funding for UK Think Tanks: Transparency, Lobbying and Fake News in Brexit Britain’, HuffPost Contributor;Read full: 313874. Accessed at: https://www.huffpost.com/entry/secret-funding-for-uk-think-tanks-transparency-lobbying_b_58a9eadde4b0b0e1e0e20c87.

Report of Byline Times, 3 November, Centre Think Tanks’ (2023) ‘Follow the Money: Dark Money in UK Politics’. Accessible at: https://bylinetimes.com/2023/11/03/time-to-tackle-dark-money-in-politics/.

Chatham House (2025) ‘Understanding and Improving Sanctions Today’ Accessible at: https://www.chathamhouse.org/2025/07/understanding-and-improving-sanctions-today.

Chatham House (2024) – Sanctions Work with Foreign Policy Toolkit. Accessed at: https://www.chathamhouse.org/2024/03/making-sanctions-work-foreign-policy-tool.

Foundation for Defense of Democracies 2023 U.S. Policies for Enforcement, and Implementation of Sanctions. Accessed on: https://www.fdd.org/analysis/2023/03/29/examining-us-sanctions-policy-implementation-and-enforcement/.

Draft your content hereHouse of Commons Library (2026) ‘The UK Sanctions Framework’ Accessible at : https://commonslibrary.parliament.uk/research-briefings/cbp-10346/.

UK Government proposes 2020 Information Note On Operating Within Counter-Terrorism Legislation Counter-Terrorism Sanctions And Export Control Accessible via Gov.uk

Sanctions and Anti-Money Laundering Act 2018, c.13. Accessible at the following link: https://www.legislation.gov.uk/ukpga/2018/13.

“The West Gets the Wrong Message Over Russia Sanctions” (2026, NWCP). Accessible at: https://www.bushcenter.org/publications/russian-sanctions-evasion-in-europe.

KIAR (2025) ‘Central Asia’s Role in Russia’s Evasion of Sanctions: Report 2024–2025’. Find it at https://kiar.center/central-asias-crucial-role-in-russias-evasion-of-sanctions-in-report-2024-2025/

The Jamestown Foundation (2025) opines, Russian sanction evasion drives development of alternative international economic system. Accessible at: https://jamestown.org/russian-sanction-evasion-drives-development-of-alternative-international-economic-system/.

According to a report from the Atlantic Council (2025), the Russian Economy in 2025 will be in stagnation and militarization. Link: https://www.atlanticcouncil.org/content-series/russia-tomorrow/the-russian-economy-in-2025/

Russia Sanction Evasion 2025 an Article by Harvard International Review. Accessible via: https://hir.harvard.edu/fortune-hunting-russia-and-sanctions-evasion/.

‘Back and Forth 3: Do Sanctions Work?’ – CSIS (2025)’. download CSIS report

The Economic Sanctions: What Are What Are? CFR (2024)’. Accessed at https://www.cfr.org/backgrounders/what-are-economic-sanctions.

An Examination of Screening in the UK and US, their Western Policy,Infrastructure Safeguarding © 2025 by Monarchguard.uk is licensed under CC BY-ND 4.0

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