Independent Researcher

ADVISORY POLICY PAPER

An Examination of the Measures for the Screening of Funding, Personnel and Foreign Influence Vectors of Think Tanks, Non-Governmental Organisations and Private Security Companies in the UK and US: Safeguarding Western Policy Infrastructure

1. Executive Overview

I believe that the policy advice structures supporting governments in the UK and US are currently under an unappreciated threat. More specifically, think tanks, non-governmental organisations, policy forums, and even private security contractors are under threat of infiltration by hostile governments and those that maintain an outwardly amicable relationship but that are essentially adversaries, using different methods and instruments.

I would recommend that UK and US governments establish mandatory inquiries to ensure transparency regarding the funding of such organisations and that those who work for them are thoroughly vetted.

The focus of this paper is to present a case for this dual proposition.

Without a comprehensive endeavour to uncover and counteract the infiltration of the institutions that develop, research, and promote sanctions and restrictions on business and international trade with hostile countries, both those measures cannot be used effectively as foreign policy tools by governments.

Finally, if there is evidence that a foreign national or domestic actor has been used to exert covert influence via policy organisations or (indirectly) by private security or intelligence companies for foreign state principals on UK or US national security, they should be considered for designation as a sanctions target.

The paper also insists that institutional capture is a risk that cannot be simply confined to adversarial states.

There is then another, equally malignant, threat to the rule of law and Western democracy posed by NATO-allied governments that abuse international police, private intelligence agencies, and legal systems against political enemies living in exile on allied soil.

2. Sanctions and the Structural Vulnerability They Cannot Address

There is a huge institutional investment of Western governments in sanctions as a tool of foreign policy.

Sanctions have been employed more frequently by the United States, the United Kingdom, and the European Union for various purposes, such as freezing assets, travel bans, arms embargoes, and controls on imports and exports (Chatham House, 2025).

But these tools face a fatal flaw the sanction packages cannot remedy: creep from the very advisory bodies that the packages of sanctions are intended to design, tune, and implement.

It’s an easy equation, Sound intelligence and analysis are crucial to the effectiveness of any sanctions regime.

If the think tanks, NGOs, and policy forums consulted by governments on which parties to sanction, and how to make those sanctions effective, are themselves covertly funded by foreign actors, or staffed by individuals with undisclosed affiliations, then sanctions may be fundamentally flawed at their inception.

The use of sanctions has increased, with rising cooperation among targeted states like China, Russia, North Korea, and Iran, while also raising worries about enforcement and unintended consequences (Chatham House, 2025).

Much less attention has been paid to the possibility that advisory capture by hostile actors can be a key causal route of that enforcement failure.

In testimony before the United States Congress, I noted that North Korea is working in concert with Russia, China, Iran, and Syria to undermine Western sanctions regimes and that these countries have a plan to disrupt the primacy of the US dollar and, ultimately, US foreign policy and security. (Foundation for Defense of Democracies, 2023)

But this axis does not restrict itself to circumventing trade; it also moves in the realm of information and the very institutions whose counsel is sought by Western governments in drafting their responses.

Those assisting this infiltration, whether knowingly or out of wilful complicity, are equally culpable as a physical trader transporting banned goods and should be treated so under the law.

3. The Opacity Problem: Funding Transparency and Advisory Capture

3.1 The UK Transparency Deficit

In a recent investigation, openDemocracy uncovered that the UK’s leading think tanks with political influence received over £14 million from undisclosed donors within two years (openDemocracy, 2022a).

Another significant cluster of British organisations receiving US funding are five major British think tanks: the TaxPayers’ Alliance, the Institute of Economic Affairs, Policy Exchange, the Adam Smith Institute, and the Legatum Institute. American funders gave nearly $9 million to these organisations since 2012, at least $6 million of which went directly to the UK, an 11 per cent share of the total receipts of these organisations in the UK (openDemocracy, 2022b).

Transparency International UK has warned about the think tank industry in Westminster, stating that “the lack of transparency around think tanks’ funding would reasonably lead a member of the public to suspect they could be promoting the interests of undisclosed vested interests.” (openDemocracy, 2022a).

Counterfeit evidence resulting in misleading coverage in the UK media has been produced by a financially opaque organisation based in London, and disinformation amplified by global media outlets has been produced by a suspected Russian-linked financially opaque organisation based in France (Transparify, 2017).

There is no current obligation for think tanks to disclose their donors in the UK, revealing a serious loophole in the UK’s counter-intelligence architecture.

3.2 The American Dark Money Epidemic

The United States is no different.

In 2024, foreign governments provided over $25 million to leading US think tanks, while Pentagon contractors gave $7 million, according to the Quincy Institute’s Think Tank Funding Tracker, which in turn offers what are likely conservative estimates, given about 40 per cent of think tanks reveal no donors at all.

Some of the top-known foreign policy think tanks in Washington DC, including American Enterprise Institute, Foundation for Defense of Democracies, and the Washington Institute for Near East Policy, disclose nothing about their donors while advocating for policies that have significant implications for national security.

As one researcher puts it, there is a “dark money epidemic” among think tanks in the United States. Given how nefarious state influence operations have documentedly used US-funded NGOs (in the case of hostile states such as Russia, China, and Iran) as part of their propaganda campaigns (see the following sections of this paper), the potential ramifications of this opacity have a much larger scope than just academic accountability.

4. Case Study I: Iran’s “Experts Initiative” and the Penetration of the American Policy Space

Arguably the best-known and most striking case of hostile state infiltration of Western think tanks and policy institutions is that of Iran’s insertion of academics and analysts into the US policy advisory system.

Iran International and Semafor reported on a substantial information operation conducted by Iran’s regime on US and Western soil for years.

In 2014, veterans of the Islamic Revolutionary Guard Corps (IRGC) and the Foreign Ministry of Iran operated a network of senior experts and academics based in the West who sought to promote policies in the West towards the clerical regime; the network is referred to as the “Iran Experts Initiative.”

In the post-revolution years, these Western-based specialists, along with others, worked in think tanks, universities, and even US government agencies such as the Pentagon, closely associated with senior US and European officials on Iran policy.

A successful aspect of the project was the mode of operation.

The operations were based in the Institute for Political and International Studies (IPIS) in Tehran, which is the official think tank of the Iranian Foreign Ministry.

In practice, but, many of its officials were card-carrying members of Iran’s Intelligence Ministry and the IRGC, and its official links to the Foreign Ministry – as opposed to any of the country’s security-intelligence agencies – allowed it to operate abroad and receive foreign guests without raising suspicions.

The tentacles of the network extended into US diplomatic circles, where a former assistant to US Iran envoy Robert Malley was involved in the affair; Malley was suspended due to allegations of mishandling of classified information.

Iran also managed to enter US policy space with the support of scholars who were present in the think tank and media environments and could exert influence on government agencies.

This case is particularly illustrative of the vulnerability identified in the thesis of this paper.

To some extent, the American policymakers working on Iran sanctions were relying on analysis that was developed by analysts working at the behest of the target state.

Most Iranian specialists, it should be added, by far the vast majority, remained credible and uninfluenced by Tehran’s government, but the impact that the Iran Experts Initiative had on US policy space continues to be examined even today.

But, the Iranians who infiltrated the Western advisory groups did not limit themselves to filling key personnel positions.

Credential harvesting, social engineering, and infiltrations against Western think tanks and government-linked institutions appear to be part of the Iranian cyber toolkit, with multiple threat actor groups observed conducting focused and persistent activity against such targets.

The risk that a physical insertion of personnel coupled with cyber-enabled infiltration could threaten advisory infrastructure is not contemplated in current policy.

5. Case Study II: Russian Oligarch Think Tank Networks in Europe and the United States

The other side of think tank infiltration for Russia has been its own weaponisation of oligarch-funded research institutions wrapped in the practices of independent thinking.

According to Kateryna Smagliy, former director of the Kennan Institute’s office in Kyiv, Putin enlisted his closest oligarchs to finance and manage think tanks in the West, assigning each one a particular country or region, and behind the “Putin doctrine” there is indeed a very small group of people and a very big network of organizations.

Examples include Vladimir Yakunin’s Dialogue of Civilizations Research Institute in Berlin, engaged in German discussions on Nord Stream 2 and the sanctions policy of the Merkel government.

Natalya Narochnitskaya, a former deputy of the Russian Duma and a board member of the Russkiy Mir foundation, ran a related think tank in Paris.

The Kremlin propagandist who ran their branch in New York was Andranik Migranyan, who offered the same through his plentiful output at the Centre for the National Interest.

Russia established the key agencies that would carry out the task of spreading its narratives in the West Rossotrudnichestvo, Russkiy Mir, and the Alexander Gorchakov Public Diplomacy Fund between 2009 and 2012.

They set up Russian Centres in the universities of EU countries; there are currently about 41 centres of Russian World, almost 30 of which are located in universities that receive Russian funding.

Given the proximity of these institutes to European academics and policymakers, there was the potential for systematic bias in the analysis that was arriving on the desks of European policymakers on questions related to Russia, sanctions, and security in Eastern Europe.

6. The Abramovich–Lithuania Precedent: Citizenship Arbitrage as a Vector for Hostile State Access

This example of Roman Abramovich and his children obtaining Lithuanian citizenship demonstrates one of the loopholes for hostile state infiltration that needs to be addressed in comprehensive counter-intelligence strategies, specifically, using EU citizenship by descent to bypass sanctions and more generally to gain entry into Western institutions.

Two of Abramovich’s children, Arkadiy and Anna, have Lithuanian passports. They took control of offshore trusts with billions of dollars in assets that could be out of reach if Abramovich is sanctioned after Russia’s invasion of Ukraine.

Shortly before Russia invaded Ukraine, Abramovich wired huge sums from his trust-associated assets to his seven children—about $4 billion in total—and, as part of what seems to be an effort to avoid obvious connections to sanction him, Arkadiy and Anna obtained Lithuanian passports.

Abramovich had a similar approach with his passports.

In May 2018, he received Israeli citizenship under Israel’s Law of Return. He used the new passport to enter the United Kingdom visa-free, where his visa application had been pending for months.

And in April 2021, he obtained Portuguese citizenship via Portugal’s naturalisation process for descendants of Sephardic Jews, providing access to all countries in the EU and EEA, as well as visa-free access to the UK, thanks to the four freedoms of the Treaty of Rome.

The implications of this precedent for Western policy infrastructure reach far beyond the current case.

These examples, along with the use of citizenship laws based on descent by countries like Lithuania, Portugal, and possibly others, where the decision-makers were more or less in cahoots with an enemy state, indicate that there is an existing playbook for this group to stay plugged into the Western banking and financial ecosystem, and the advice and lobbying ecosystem.

Statutory rights of establishment, residence, and work are granted to all EU citizens in all EU countries, and in most cases to the UK without the need for a visa.

This, in turn, creates the often absurd possibility of individuals who are nominated for sanctions, or who are close to those that are sanctioned, having legal proximity with think tanks, NGOs, policy forums, and advisory boards in London, Brussels, Berlin, Paris, and Washington.

This is the scenario the Interior Minister of Lithuania spoke about when she admitted they were preparing changes in the legislation which would allow citizenship to be stripped from those posing a threat to national security, even if they were descended passport holders.

She also asked officials to trace how many banned people or their relatives are Lithuanian citizens, and she suspects the Abramovich case is not unique.

The UK government should refer to this precedent and consider expanding the scope of their criteria to include individuals who have gained EU citizenship recently (primarily through the citizenship programmes offered for descendants of emigrants in states that have historical links with the former Soviet diaspora) where this may be an act of strategic dodging rather than authentic self-identification based on genuine affinity.

7. Former Soviet State Networks as Conduits for Advisory Infrastructure Penetration

Other ex-Soviet states Azerbaijan, Kazakhstan, Kyrgyzstan, Uzbekistan, Georgia, Armenia, and Moldova are not used only to move banned goods, but also to move banned people into positions closer to the source of Western policy.

Also, it is believed that the banned goods are being re-exported to Russia via Kazakhstan, Kyrgyzstan, and Uzbekistan, and also via Georgia and Armenia, the Caucasus countries being used to hide the source of the banned goods (KIAR, 2025).

TAKO LLC, an electronic elements manufacturing company from Armenia, figured among those who continued to supply the Russian military after the sanctions, whereas exports from the European Union to Kyrgyzstan reached over €2.7 billion in 2023–2024, compared to a pre-war average of around €285 million, with experts attributing to the country serving as a back-channel for dual-use products to Russia (George W. Bush Presidential Center, 2026).

Three companies in Moldova served as intermediaries for Russia through shell firms that sold Western aircraft components to Russian carriers.

By 2023, China accounted for nearly 90 per cent of the export-controlled items Russia imported through evasion networks (Atlantic Council, 2025).

These same countries also have relations with Western policy circles encompassing diplomacy, trade, and culture.

Those running these transshipment and circumvention networks have the capital, diaspora ties, and, in several cases, newly minted Western passports to buy themselves or their friends a seat in the think tanks and NGOs that recommend sanctions against which they are actively subverting.

If those relationships are not investigated for potentially undisclosed financing or staff in Western policy agencies, the business is punished for the consequences without the consequences being addressed.

8. The Paradox of Enforcement: Uncoordinated Penetration and the Self-Defeating Sanction

The current system of sanctions, applied across multiple designations, has inadvertently created an incentive for sanctioned countries to collaborate.

Emerging from the ashes of cold war animosities, China, Russia, North Korea, and Iran have found common cause. In fact, the US practice of secondary sanctions has sometimes discouraged allied government and business investment in the targeted countries, allowing their hostile counterparts to scoop up valuable assets and cultivate spheres of global influence for future use (Chatham House, 2025).

Effective diplomacy, high-quality intelligence, and other complementary policies are necessary for sanctions to work, according to analysts (Gates Forum, n.d.).

I argue here that the most important of these complementary actions, and the one most significantly lacking in current policy, is vetting and transparency enforcement of think tanks and NGOs, combined with a credible personal sanctions designation threat to those that have shown themselves to be willing to compromise the advisory apparatus on which our security depends.

Effective punishment of trade with an enemy state would require the answers to the questions of what should be punished, whom should be punished, and how, to be left uncompromised. But in this case, I do not think the answer to these questions have been left uncompromised.

9. Private Security Companies as Vectors of Transnational Espionage: The Necessity of Mandatory Screening

9.1 The Unregulated Intersection of Private Intelligence and Foreign State Interests

Private security companies and private intelligence contractors operating in the UK and the US represent another facet of the malicious infiltration of Western advisory and civil infrastructure by the state that the existing counter-intelligence landscape may be surprisingly ill-prepared for.

These big and small corporate spy agencies float in regulatory limbo.

They have close enough ties to government, finance, and policy entities to be useful channels for spying and influence, but compared to their public sector counterparts, they are subject to much looser supervision and scrutiny.

The primary risk is this, Due diligence, competitive intelligence, or litigation support companies, or private security or intelligence companies based in Western jurisdictions such as London or Washington, may be hired to conduct such work by clients who are directly or indirectly, foreign governments or their proxies.

If the beneficial owner of such a company (or its undisclosed instructions) serve the interests of a hostile or nominally friendly but useful enemy state, the fruits of that labor can be used against diaspora communities, political dissidents, opposition figures, or even legal processes, constituting acts of transnational repression masquerading as legitimate work.

The target may be a creditor, a human rights activist, an exiled journalist, a political adversary, or anyone whose life or voice is a nuisance to a foreign government.

It is not only that person who is harmed, but also the rule of law in the country where the activity takes place.

In a similar vein, I would suggest that both the UK and US governments consider mandatory screening and registration requirements for private security and intelligence companies, similar to what I have proposed in respect of foreign influence registers for think tanks and NGOs.

Much of this sector remains similarly opaque, leaving it vulnerable to the same state hostile infiltration that enabled advisory think tanks.

9.2 The “Friendly State” Problem: Why NATO Membership Is Insufficient as a Safeguard

One persistent fallacy embedded in the thinking about policy to counter espionage is the assumption that hostile influence operations are conducted exclusively by adversarial states.

But, as will be seen in the following section regarding the case of the Republic of Turkey, the reality is much more complicated.

A state can be a formal member of NATO, participate in the exchange of intelligence information, be a party to a human rights treaty, and yet practice across-the-board transnational repression against its diasporas, political dissenters, and critical journalists in the territory of its Western allies.

This poses a categorical dilemma for existing vetting procedures.

Far easier to counter measures targeted at fully sanctioned hostile states is the prospect of a private security company hired by or on behalf of the Turkish state – or any analogous state – tracking, intimidating, prosecuting, or forcibly returning dissidents residing in the UK or USA.

Turkey is not under such sanctions.

Its intelligence and police services are formally linked to their colleagues in Britain and the United States, and its entrepreneurs enjoy the benefit of Western corporate and juridical services.

This makes it in some ways a more effective and unobtrusive tool of transnational repression than states that have been subjected to intense counter-intelligence scrutiny.

It is this notion that must drive the screening requirements proposed here, where it is the nature and purpose of the activity that determines the necessity to screen rather than the formal alliance status of the client state.

For the AKP government or on the AKP’s behalf, a private security company spying on the Turkish Gülenists or Kurds in the United Kingdom could stand on the side of none other than the British values, British rule of law, or rights of the people legitimately existing in the United Kingdom despite the fact that Turkey sits at the NATO table.

9.3 Case Study: Turkey, the AKP, and the Systematic Weaponisation of International Policing Mechanisms

The best known example of an officially Western-oriented country that has turned international legal and policing arrangements to the purpose of the transnational repression of its political opponents in the Diaspora is Erdoğan’s Turkey. It is also an example of the kinds of risks that private security firms hired by such a country would pose to the civilian infrastructure of host countries.

The Erdoğan regime has employed the International Notice System and related Interpol Red Notices (meant to apprehend high profile criminals such as terrorists, drug lords and human traffickers) to track political opponents, journalists, and dissidents in exile whose only crime was writing against the government.

Since the attempted coup in July 2016, which failed, Turkey’s transnational repression efforts have become what I call a global operation. A target group is the Gülen movement.

The campaign is considerable.

Turkish authorities made 3,579 Red Notice requests via Interpol for alleged members of the Gülen movement and 2,364 extradition requests to 118 countries, according to official Turkish government figures.

In July 2025, the Joint Committee on Human Rights of the Parliament of the United Kingdom stated in a report on human rights in the UK that, together with China and Russia, they believed Turkey to be leading in the abuse of Interpol’s notice system. They warned that authoritarian regimes increasingly weaponize Interpol notices to track down dissidents abroad under the pretense of criminal allegations.

The report notes that Turkey has abused the Stolen and Lost Travel Documents (SLTD) database by registering passports of its opponents as stolen in order to detain them or forcefully deport them.

But, the crudely obvious is not the only place you will find such behaviour.

Turkey’s candidate for Interpol’s presidency, Mustafa Serkan Sabanca, who heads Turkey’s interpol–Europol National Central Bureau, reportedly suggested in a secret internal memo seen by The Telegraph that police should prepare a Red Notice request for a human rights lawyer residing in Belgium on an embezzlement charge, rather than terrorism charge, to pass off a political request as an ordinary criminal one, which would be more likely to be accepted by foreign courts.

In another internal memo also dated June 2025, this one from the Security General Directorate, prosecutors were advised not to mention charges of terrorism or links to opposition figures when requesting a Red Notice from Interpol.

The same methodology was employed against the SLTD database, which undergoes less internal scrutiny, aside from Red Notices.

Dissidents’ passports were fraudulently noted as lost, stolen, cancelled, or otherwise invalid by Turkish authorities seeking to have them extradited to Turkey when the dissidents travel abroad, according to leaked documents from Turkey’s National Intelligence Organisation.

One example is NBA player Enes Kanter Freedom, who Erdoğan’s government hit by revoking his passport in 2017 and asking for his arrest on trumped-up terrorism charges in 2019.

In addition to its own citizens, Turkey has also politically persecuted dissidents and refugees from other countries. According to Freedom House, Turkey has rendered political dissidents from at least 31 countries, and while Turkish officials admit that 116 people from 27 countries have been brought to Turkey to face terrorism charges related to the coup attempt, these numbers are likely to be underestimates as many renditions have been clandestine.

In terms of immediate consequences, this raises significant issues for private security contractors in both the UK and the US.

Likewise, this toolkit of trumped-up criminal charges, false documents, and legal harassment has also been used via private intelligence and security agencies to surveil, compile cases, and gather evidence to be used as a basis for extradition requests or even to file civil suits.

A private firm hired by someone with secret connections to a foreign government to search out and expose a “fraudster” or “terrorist suspect” who is in reality a political dissident or opposition reporter functions in an equivalent manner to the actions cited above at the level of the state.

The activity constitutes a trade and does not enjoy diplomatic sanction. This does not eliminate the injury, but, but only obscures it, making it more difficult to identify.

9.4 The Convergence of Advisory Infiltration and Private Security Exploitation

It is important to clarify that the risks discussed here are not separate from the previous section on infiltrating think tanks.

Both are in essence different forms of the same strategy to extend the influence of a hostile state into Western democracies in order to compromise the policy-making process as well as the civil rights of individuals living within Western democracies.

If a state is capable of placing sympathetic researchers in Western think tanks to influence the analysis behind sanctions policy, then it is also capable of hiring private intelligence contractors to surveil, intimidate, or otherwise eliminate diaspora voices that may subvert the narrative.

They complement and reinforce each other.

While the former moves across the conceptual space of policymaking, the latter moves on the concrete and juridical space of civil society, cutting off the protest or critical evidence that would remedy distortions at the level of advice.

10. The Legal Framework for Designation and Its Extension

The Sanctions and Anti-Money Laundering Act 2018 (SAMLA) empowers ministers to establish sanctions regimes and designate persons or entities for the purpose of complying with international obligations or furthering UK foreign policy and national security objectives (House of Commons Library, 2026).

The definition of “involved person” under SAMLA includes a person who is owned or controlled by, acting on behalf of or at the direction of, or a member or associate of, a sanctioned person (Sanctions and Anti-Money Laundering Act 2018, c.13).

This definition, I would argue, facilitates an understanding of those who would work for an enemy state directly, as well as those who might do so under the orders of an independent policy organisation or private security contractor.

We already have an example where individuals have been designated for activities deemed inimical to Western interests: in 2022, a British journalist was added to the UK Sanctions List for work described as undermining the territorial integrity and sovereignty of Ukraine (Wikipedia 2026).

Extending this principle to those who clandestinely assist hostile states in gaining access to think tanks, advisory bodies, or private security forces would constitute a proportionate evolution of the existing principle.

The United States has similar powers under the International Emergency Economic Powers Act (IEEPA) and related executive orders, with the designating authority residing with the Office of Foreign Assets Control. These two allies should coordinate their designation efforts.

It would be logical and proportionate to extend the extant enforcement doctrine to clandestine actors serving hostile states or nominally allied states undertaking transnational repression infiltrating think tanks or enacting private intelligence on persons resident in the West.

11. Recommendations

To address all the institutional problems mentioned in this paper, I believe the following legal and administrative structures would be preferable to the UK and US governments.

First, mandatory funding disclosure legislation should require that all think tanks, policy forums, and NGOs lobbying or briefing government on policy issues disclose publicly each year all funders of more than GBP/USD 5,000, including funders whose monies are channeled through intermediary vehicles or seemingly independent foundations.

Second, personnel vetting procedures should be applied uniformly, with background checks on senior staff working in research, advisory, or editorial roles for organisations working directly on government policy, with an emphasis on undisclosed foreign ties, recent naturalisation, and career histories in countries of interest to counter-intelligence agencies.

Third, an expanded foreign influence register should extend the current foreign lobbying laws to include think tanks and NGOs with institutional or financial ties to foreign governments, including but not limited to those states officially allied with the UK and the US.

Fourth, formalising intelligence sharing between national security agencies and parliamentary committees, whereby the latter can identify instances of malicious foreign influence in the policy environment.

Fifth, there should be periodic independent audits of transparency for organisations whose work informs national security, defence, and foreign policy discussions, and the results of these audits should be published for Parliament and Congress.

Sixth, entities involved in designing and implementing sanctions should be subject to a prior test of integrity, with funding and senior staff vetted to ensure that they do not have undisclosed ties to the sanctioned states or their proxies.

Seventh, and most importantly to the advisory infrastructure, I would recommend that a policy for the personal sanctioning of individuals be established. This policy would set out a legal and procedural path to the designation of any person who has been proven, through due investigative process, to have worked against UK or US national security by covertly aiding British or American enemies to influence think tanks, NGOs, policy councils, or other advisory entities.

Those designations should be made subject to the full panoply of restrictions available under SAMLA and IEEPA, respectively.

Eighth, also responding to the Abramovich ruling, the UK government should establish specific vetting criteria for those holding EU citizenship from inherited citizenship schemes in former Soviet-aligned states that seek to participate in regulated advisory, financial, or lobbying activities in the UK. The first step in this process would be to acknowledge that there will be no presumption of exclusion based solely on inherited citizenship, but, there should be consideration of that person’s material, financial, or professional involvement with sanctioned states.

Ninth, all private security and intelligence firms registered or operating in the UK and the US that are contracted to conduct surveillance, research, or due diligence, legal services, or asset tracing on named individuals or diaspora communities must disclose the ultimate beneficial client used for each contract, if that client is a foreign government, or owned by a foreign government, or a corporate vehicle with significant state ownership, regardless of whether that government is an ally or not.

Tenth, private security and intelligence firms could be mandated to annually certify that they have not engaged in the previous year on behalf of a foreign state actor without disclosure, nor engaged in work that facilitates harassment, unlawful surveillance, or interference with the legal rights of people lawfully resident in the UK/US. This could be added to the existing requirement for mandatory registration with a regulatory authority along the lines of the foreign influence register proposed for think tanks.

Eleventh, any private security or intelligence company proven to have engaged in operations on behalf of a foreign government (including NATO allies) that illegally tracks, harasses, intimidates, or repatriates residents of the UK or US should be subject to all sanctions under existing legislation, including deregistration, and the principals of such firms should be personally designated under SAMLA and IEEPA if acts constitute active harm to national security or the rule of law.

Twelfth, the United Kingdom and U.S. governments should bring allies in NATO to indicate that using private security forces, commercial law instruments, or international police action such as Interpol Red Notice and SLTD to engage in transnational repression of individuals legally residing in allied countries constitutes an unworthy act of alliance membership and will be considered and responded to as a U.S.-U.K. security issue and not a criminal matter. The notion that alliance membership grants the diplomatic freedom to engage in extraterritorial repression on allied territory must be rejected.

12. Conclusion

What emerges from the case studies presented here—in particular, Iran’s ambitious embedding of academics in US think tanks and government agencies via the Iran Experts Initiative, the Russian oligarch-funded networks of researchers in Berlin, Paris, and New York, the Abramovich family’s strategic use of Lithuania’s citizenship law to protect assets and maintain entrée to the West, and Turkey’s offensive use of Interpol and the private security industry to hunt political opponents on allied turf—is that the policy advice industry in the UK and US is susceptible to penetration by hostile states. The techniques are ingenious, adaptive, and finely tuned to exploit the complacency, lack of transparency, and good will of Western think tanks and private intelligence agencies.

The thesis of this article is that sanctions are not going to work when the tools and analytics upon which they rely are compromised. Plus, the rule of law cannot be upheld when private intelligence companies are freely allowed to be used as instruments of foreign state repression without screening, disclosure, or accountability. To address the commercial circumvention of sanctions, but not the human infrastructure that enables the capture of advising, or the use of ostensibly allied states’ private contractors against their diaspora opponents on Western soil, is to dig an ever-deepening hole.

A remedy must address all of these. Closing the gates against private security firms while leaving them wide open to think tank funding is building a fortress against hostile influence with one wall defenseless. Extending mandatory disclosures to private security firms, unifying personnel vetting procedures, treating proven agents of influence and transnational repression operatives as targets for financial and travel sanctions, and communicating to allied states that attempts at extraterritorial repression on Western ground will be treated the same as actions by hostile states are proportional, legally defensible, and necessary actions to protect autonomous and evidence-based policy-making in an intensifying great power competition.

References

Canbäck, R. and Bloss, K. (2025) ‘UK sanctions Azerbaijani state-owned tanker for shipping Russian oil’, OCCRP, 13 May. Available at: https://www.occrp.org/en/news/exclusive-uk-sanctions-azerbaijan-state-owned-tanker-for-shipping-russian-oil

Chatham House (2025) Understanding and Improving Sanctions Today. [Online] Available at: https://www.chathamhouse.org/2025/07/understanding-and-improving-sanctions-today

Atlantic Council (2025) The Russian Economy in 2025: Stagnation and Militarisation. Available at: https://www.atlanticcouncil.org/content-series/russia-tomorrow/the-russian-economy-in-2025/

Foundation for Defense of Democracies (2023) ‘Examining US Sanctions Policy: Implementation and Enforcement,’ 29 March. Available at: https://www.fdd.org/analysis/2023/03/29/examining-us-sanctions-policy-implementation-and-enforcement/

Citation: George W. Bush Presidential Center (2026) “Russian Sanctions Evasion in Europe,” [Online]. Available: https://www.bushcenter.org/publications/russian-sanctions-evasion-in-europe

House of Commons Library (2026) The UK Sanctions Framework. Available at: https://commonslibrary.parliament.uk/research-briefings/cbp-10346/

ICIJ/Siena Centre (2023) ‘Lithuania seeks new powers to strip citizenship after Abramovich children exposed as Lithuanian passport holders’. Available at: https://www.icij.org/investigations/cyprus-confidential/lithuania-seeks-new-powers-to-strip-citizenship (Accessed: 13 March 2023).

Jamestown Foundation (2025) Russian Sanction Evasion Drives Development of Alternative International Economic System [Online]. Available at: https://jamestown.org/russian-sanction-evasion-drives-development-of-alternative-international-economic-system/ (Accessed: 31 January 2025).

Just Security (2023) ‘After Spotlight on Red Notices, Turkey Is Abusing Another Interpol Mechanism’. Available at: https://www.justsecurity.org/87260/after-spotlight-on-red-notices-turkey-is-abusing-another-interpol-mechanism/

KIAR (2025) Central Asia’s crucial role in Russia’s evasion of sanctions: Report 2024-2025. Available at: https://kiar.center/central-asias-crucial-role-in-russias-evasion-of-sanctions-in-report-2024-2025/

LRT (2019) ‘How Russian oligarchs’ think tanks are winning hearts and minds in Europe and US.’ Available at: https://www.lrt.lt/en/news-in-english/19/1069448

Middle East Policy Council (2024) ‘The Pacing Threat of Iran’s Influence Operations’. Available at: https://mepc.org/commentaries/the-pacing-threat-of-irans-influence-operations/

Nordic Monitor (2025) Turkey, the top abuser of INTERPOL, now seeks to govern it. Available at: https://nordicmonitor.com/2025/10/turkey-the-top-abuser-of-interpol-now-seeks-to-govern-it/ (Accessed: 24 October 2025).

OCCRP (2023) ‘Abramovich’s Kids, Lithuanian Citizens, Shield His Wealth from Sanctions.’ Available at: https://www.occrp.org/en/daily/18278

openDemocracy (2022a) Think tanks have taken to banking on mystery money sponsors. Available at: https://www.opendemocracy.net/en/dark-money-investigations/think-tanks-transparency-funding-who-funds-you/

openDemocracy. (2022b) ‘US climate change sceptics gave millions to UK think tanks linked to Tory party’. Available at: https://www.opendemocracy.net/en/dark-money-investigations/think-tanks-adam-smith-policy-exchange-legatum-iea-taxpayers-alliance-climate-denial/

Orion Policy Institute (2024) ‘Holding Its General Assembly in Turkey Could Imperil INTERPOL’s Legitimacy.’ Available at: https://orionpolicy.org/holding-its-general-assembly-in-turkey-could-imperil-interpols-legitimacy/

Quincy Institute for Responsible Statecraft (2026) Think Tank Funding Tracker. Available at: https://quincyinst.org/2026/03/16/new-research-think-tank-funding-tracker/

Red Notice Monitor (2025) ‘How Türkiye’s Authoritarian Agenda Is Corrupting Interpol’s Red Notice System’. Available at: https://rednoticemonitor.com/how-turkiyes-authoritarian-agenda-is-corrupting-interpols-red-notice-system/

Sanctions and Anti-Money Laundering Act 2018, c.13. (https://www.legislation.gov.uk/ukpga/2018/13).

Stockholm Center for Freedom (2025) Turkey’s Bid for INTERPOL Presidency Reignites Scrutiny of Its Rights Record and Notice Abuses, 2025. Available at: https://stockholmcf.org/turkeys-bid-for-interpol-presidency-reignits-scrutiny/ (Accessed: 30 May 2025).

Hill, The (2024) ‘How Iran’s Secret Influence Poses a Threat to American Democracy’. Available at: https://thehill.com/opinion/national-security/4662640-how-iranian-infiltration-is-threatening-american-democracy/

Transparify (2017) Secret Funding for UK Think Tanks: Transparency, Lobbying and Fake News in Brexit Britain.

Turkish Minute (2025) ‘Turkey’s candidate to lead Interpol tied to political Red Notice attempt’. Available at: https://www.turkishminute.com/2025/11/25/turkeys-candidate-to-lead-interpol-tied-to-political-red-notice-attempt/

UK Joint Committee on Human Rights. (2025). Report on Transnational Repression, 30 July.

George Washington University Program on Extremism (2024) Propaganda, Procurement and Lethal Operations: Iran’s Activities Inside America. Available at: https://extremism.gwu.edu/propaganda-procurement-and-lethal-operations-irans-activities-inside-america

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