Name

Identifying information

Statement of Reasons

Date of listing

‘88.

Elena Gennadyevna BAGUDINA

(Russian: Елена Геннадьевна БАГУДИНА)

Position: General Director of Communication Platform LLC

DOB: 11.3.1954

Nationality: Russian

Gender: female

Elena Bagudina is the General Director of Communication Platform LLC, which is a subsidiary of VK (previously known as VKontakte) and the developer and manager of state-supported mobile phone application Max. In her position as General Director, she is responsible for the development and management of the Max application. The development of the Max application was supervised by the Federal Security Service (FSB), which established the requirements that the developers of the Max application had to meet. The Max application must be pre-installed on all mobile phones and tablets sold in Russia and is integrated with the Gosuslugi service.

According to numerous experts, the Max application has extensive surveillance features and can monitor communications, including the use of virtual private networks (VPNs), gather data on other applications installed on phones, monitor address books, identify the location of users and install autonomous updates. The introduction and promotion of the Max application by the Russian state have been accompanied by a crackdown on and blocking of other independent applications, such as WhatsApp and Telegram, as well as by a campaign to limit the use of VPNs, which allowed users to access content blocked in Russia.

Information gathered by Russian authorities through the Max application served as a basis to fine a Russian citizen for content posted on the application.

Therefore, Elena Bagudina provides technical support for the repression of civil society and democratic opposition, including by assisting and facilitating such acts.

13.7.2026

89.

Dmitry Valerianovich GACHKO

(Russian: Дмитрий Валерьянович ГАЧКО)

Position: General Director and ultimate owner of VAS Experts

DOB: 16.8.1976

Nationality: Russian

Gender: male

Dmitry Gachko is the General Director and ultimate owner of the limited liability company VAS Experts, which manufactures, develops and sells hardware and software related to the so-called System of Operative Investigative Measures (SORM). In his position as General Director and ultimate owner, he is responsible for VAS Experts’ activities relating to the manufacture and supply of SORM-related hardware and software.

SORM is a surveillance system used since the mid-1990s to control internet and mobile communications in Russia, namely the monitoring of phone calls, emails, internet use, text messages and social networks. Mobile phones and internet providers are legally required to install SORM. It is installed in all Russian data centres and at all internet exchange points and within major search engines. User traffic is copied to a separate server or to a data centre available to the Federal Security Service (FSB).

SORM gathers information about users’ physical location, activity patterns, time of device use, users’ behaviour and the use of different SIM cards in one or more devices. It can be used retroactively and without the provider’s knowledge.

SORM has been used to target journalists, opposition figures, minority groups and ordinary citizens. It has also been used to prosecute supporters of the Russian opposition, leaders such as Alexei Navalny, organisers of protests, individuals who ran internet accounts critical of the Russian authorities or produced reports on the political situations and activists who opposed the war of aggression against Ukraine. SORM has also been used to pre-emptively detain individuals suspected of anti-government activities. SORM has had a profound impact on the ability of Russian citizens to access unbiased information about the war of aggression against Ukraine. It was also used to block traffic from, and access to, thousands of Western websites and services.

VAS Experts is involved in the development, supply and maintenance of SORM, including hardware and software integrated into telecoms networks, therefore allowing intelligence agencies to directly access all traffic. VAS Experts is a key supplier of SORM that complies with interception requirements mandated by the FSB and supports the operation of Russia’s communications surveillance infrastructure. VAS Experts operates within a framework established and supervised by the Russian authorities. These authorities approve technical requirements for SORM deployment, require operators to coordinate implementation plans, oversee compliance and use the equipment for direct interception activities. Consequently, VAS Experts develops and supplies equipment specifically designed to satisfy surveillance requirements established by the FSB.

Therefore, Dmitry Gachko provides material support for serious violations and abuses of human rights and for the repression of civil society and democratic opposition.

13.7.2026

90.

Sergey Anatolevich OVCHINNIKOV

(Russian: Сергей Анатольевич ОВЧИННИКОВ)

Position: Executive Director and ultimate owner of Closed Joint-Stock Company “Norsi-Trans”

DOB: 5.5.1955

Nationality: Russian

Gender: male

Sergey Ovchinnikov is the Executive Director and ultimate owner of Closed Joint-Stock Company “Norsi-Trans”, which manufactures, develops and sells hardware and software related to the so-called System of Operative Investigative Measures (SORM). In his position as Executive Director and ultimate owner, he is responsible for Norsi-Trans’ activities relating to the manufacture and supply of SORM-related hardware and software.

SORM is a surveillance system used since the mid-1990s to control internet and mobile communications in Russia, namely the monitoring of phone calls, emails, internet use, text messages and social networks. Mobile phone and internet providers are legally required to install SORM. It is installed in all Russian data centres and at all internet exchange points and within major search engines. User traffic is copied to a separate server or to a data centre available to the Federal Security Service (FSB).

SORM gathers information about users’ physical location, activity patterns, time of device use, users’ behaviour and the use of different SIM cards in one or more devices. It can be used retroactively and without the provider’s knowledge.

SORM has been used to target journalists, opposition figures, minority groups and ordinary citizens. It has also been used to prosecute supporters of the Russian opposition, leaders such as Alexei Navalny, organisers of protests, individuals who ran internet accounts critical of the Russian authorities or produced reports on the political situations and activists who opposed the war of aggression against Ukraine. SORM has also been used to pre-emptively detain individuals suspected of anti-government activities. SORM has had a profound impact on Russians’ ability to access unbiased information about the war of aggression against Ukraine. It was used to block traffic from, and access to, thousands of Western websites and services.

Norsi-Trans is involved in the development, supply and maintenance of SORM, including hardware and software integrated into telecoms networks, therefore allowing intelligence agencies to directly access all traffic. SORM includes monitoring equipment installed in facilities of telecommunications providers. Such monitoring equipment provides information to the Russian government’s intelligence agency, including on phone calls, text messages, emails and internet traffic. SORM also facilitates access to communications data associated with messaging application, metadata, mobile numbers, phone identifiers, geolocation, names, email addresses and IP addresses.

Norsi-Trans is a key supplier of SORM that complies with interception requirements mandated by the FSB and supports the operation of Russia’s communications surveillance infrastructure. Norsi-Trans operates within a framework established and supervised by the Russian authorities. These authorities approve technical requirements for SORM deployment, require operators to coordinate implementation plans, oversee compliance and use the equipment for direct interception activities. Consequently, Norsi-Trans develops and supplies equipment specifically designed to satisfy surveillance requirements established by the FSB.

Therefore, Sergey Ovchinnikov provides material support for serious violations and abuses of human rights and for the repression of civil society and democratic opposition.

13.7.2026

91.

Mikhail Mikhailovich FOMIN

(Russian: Михаил Михайлович ФОМИН)

Position: Executive Director of LLC Citadel

DOB: 22.3.1981

Nationality: Russian

Gender: male

Mikhail Fomin is the Executive Director of LLC Citadel.

LLC Citadel operates in Moscow and Nizhny Novgorod and develops, implements and provides support for software and hardware of the so-called System of Operative Investigative Measures (SORM). LLC Citadel is the largest manufacturer and reportedly the most important supplier of SORM hardware and software in Russia. In his position as Executive Director, Mikhail Fomin is responsible for LLC Citadel’s activities relating to the manufacture and supply of SORM-related hardware and software.

SORM is a surveillance system used since the mid-1990s to control internet and mobile communications in Russia, namely the monitoring of phone calls, emails, internet use, text messages and social networks. Mobile phone and internet providers are legally required to install SORM. It is installed in all Russian data centres and at all internet exchange points and within major search engines. The user traffic is copied to a separate server or to a data centre available to the Federal Security Service (FSB).

SORM gathers information about users’ physical location, activity patterns, time of device use, users’ behaviour and the use of different SIM cards in one or more devices. It can be used retroactively and without the provider’s knowledge.

SORM has been used to target journalists, opposition figures, minority groups and ordinary citizens. It has also been used to prosecute supporters of the Russian opposition, leaders such as Alexei Navalny, organisers of protests, individuals who ran internet accounts critical of the Russian authorities or produced reports on the political situations and activists who opposed the war of aggression against Ukraine. SORM has also been used to pre-emptively detain individuals suspected of anti-government activities. SORM has had a profound impact on the ability of Russian citizens to access unbiased information about the war of aggression against Ukraine. It was also used to block traffic from, and access to, thousands of Western websites and services.

LLC Citadel is involved in the development, supply and maintenance of SORM, including hardware and software integrated into telecoms networks, therefore allowing intelligence agencies to directly access all traffic. SORM includes monitoring equipment installed in facilities of telecommunications providers. Such monitoring equipment provides information to the Russian government’s intelligence agency, including on phone calls, text messages, emails and internet traffic. SORM also facilitates access to communications data associated with messaging application, metadata, mobile numbers, phone identifiers, geolocation, names and email addresses and IP addresses.

LLC Citadel is a key supplier of SORM that complies with interception requirements mandated by the FSB and supports the operation of Russia’s communications surveillance infrastructure. LLC Citadel operates within a framework established and supervised by the Russian authorities. These authorities approve technical requirements for SORM deployment, require operators to coordinate implementation plans, oversee compliance and use the equipment for direct interception activities. Consequently, LLC Citadel develops and supplies equipment specifically designed to satisfy surveillance requirements established by the FSB.

Therefore, Mikhail Fomin provides material support for serious violations and abuses of human rights and for the repression of civil society and democratic opposition.

13.7.2026

92.

Alexander Vladimirovich GNUTOV

(Russian: Александр Владимирович ГНУТОВ)

Position: Head of Penal Colony No 10 (since 2024)

Former Deputy Head of Penal Colony No 10 (from 2022 to 2024)

DOB: 9.8.1980

Nationality: Russian

Gender: male

Passport number: 6100202615

Alexander Gnutov is the Head of Penal Colony No 10, which is located in the village of Udarny in the Zubovo-Polyansky District of the Republic of Mordovia. In that position, he directly oversees and is responsible for actions carried out in the Penal Colony No 10, and has failed to ensure the protection of detainees’ rights and safety and the maintenance of law and order. Alexander Gnutov therefore bears responsibility for the abuse of prisoners committed by the staff of Penal Colony 10.

Hundreds of Ukrainian prisoners of war as well as Ukrainian civilians captured in the occupied Ukrainian territories have been held in Penal Colony No 10. Former detainees report inhuman and degrading treatment and torture, including electric shocks, beating, stress positions causing trophic ulcers, sexual violence, mock executions and the denial of medical care. Civilians are subjected to the same treatment as prisoners of war and are held without trial or status. Human rights defenders have reported about inhuman conditions and torture in Penal Colony No 10 since 2012, including towards Russian prisoners.

Therefore, Alexander Gnutov is responsible for serious violations or abuses of human rights, including torture and other cruel, inhuman or degrading treatment.

13.7.2026

93.

Alexei Vladimirovich ANASHKIN

(Russian: Алексей Владимирович АНАШКИН)

Position: Deputy Head of Penal Colony No 10

DOB: 9.6.1978

Nationality: Russian

Gender: male

Passport number: 8902524698

Alexei Anashkin is the Deputy Head of Penal Colony No 10, which is located in the village of Udarny in the Zubovo-Polyansky District of the Republic of Mordovia. In that position, he directly oversees and is responsible for actions carried out in Penal Colony No 10, and has failed to ensure the protection of detainees’ rights and safety and the maintenance of law and order. Alexei Anashkin therefore bears responsibility for the abuse of prisoners committed by the staff of Penal Colony No 10.

Hundreds of Ukrainian prisoners of war as well as Ukrainian civilians captured in the occupied Ukrainian territories have been held in the Penal Colony No 10. Former detainees report inhuman and degrading treatment and torture, including electric shocks, beating, stress positions causing trophic ulcers, sexual violence, mock executions and the denial of medical care. Civilians are subjected to the same treatment as prisoners of war and are held without trial or status. Human rights defenders have reported about inhuman conditions and torture in this facility since 2012, including towards Russian prisoners.

Therefore, Alexei Anashkin is responsible for serious violations or abuses of human rights, including torture and other cruel, inhuman or degrading treatment.

13.7.2026

94.

Egor Viktorovich AVERKIN

(Russian: Егор Викторович АВЕРКИН)

Position: Deputy Head of Penal Colony No 10

DOB: 8.10.1992

Nationality: Russian

Gender: male

Passport number: 8912267789

Egor Averkin is the Deputy Head of Penal Colony No 10, which is located in the village of Udarny in the Zubovo-Polyansky District of the Republic of Mordovia. In that position, he directly oversees and is responsible for actions carried out in Penal Colony No 10, and has failed to ensure the protection of detainees’ rights and safety and the maintenance of law and order. Egor Averkin therefore bears responsibility for the abuse of prisoners committed by the staff of Penal Colony No 10.

Hundreds of Ukrainian prisoners of war as well as Ukrainian civilians captured in the occupied Ukrainian territories have been held in Penal Colony No 10. Former detainees report inhuman and degrading treatment and torture, including electric shocks, beating, stress positions causing trophic ulcers, sexual violence, mock executions and the denial of medical care. Civilians are subjected to the same treatment as prisoners of war and are held without trial or status. Human rights defenders have reported about inhuman conditions and torture in this facility since 2012, including towards Russian prisoners.

Therefore, Egor Averkin is responsible for serious violations or abuses of human rights, including torture and other cruel, inhuman or degrading treatment.

13.7.2026

95.

Alexander Anatolevich GRISHANIN

(Russian: Александр Анатольевич ГРИШАНИН)

Position: Deputy Head of Penal Colony No 10

DOB: 6.10.1991

Nationality: Russian

Gender: male

Passport number: 8911222216

Alexander Grishanin is the Deputy Head of Penal Colony No 10, which is located in the village of Udarny in the Zubovo-Polyansky District of the Republic of Mordovia. In that position, he directly oversees and is responsible for actions carried out in Penal Colony No 10, and has failed to ensure the protection of detainees’ rights and safety and the maintenance of law and order. Alexander Grishanin therefore bears responsibility for the abuse of prisoners committed by the staff of Penal Colony No 10.

Hundreds of Ukrainian prisoners of war as well as Ukrainian civilians captured in the occupied Ukrainian territories have been held in Penal Colony No 10. Former detainees report inhuman and degrading treatment and torture, including electric shocks, beating, stress positions causing trophic ulcers, sexual violence, mock executions and the denial of medical care. Civilians are subjected to the same treatment as prisoners of war and are held without trial or status. Human rights defenders have reported about inhuman conditions and torture in this facility since 2012, including towards Russian prisoners.

Therefore, Alexander Grishanin is responsible for serious violations or abuses of human rights, including torture and other cruel, inhuman or degrading treatment.

13.7.2026

96.

Semyon Viktorovich KUZNETSOV

(Russian: Семен Викторович КУЗНЕЦОВ)

Position: Deputy Head of Penal Colony No 10

DOB: 18.11.1982

Nationality: Russian

Gender: male

Passport number: 79271857062

Semyon Kuznetsov is the Deputy Head of Penal Colony No 10, which is located in the village of Udarny in the Zubovo-Polyansky District of the Republic of Mordovia. In that position, he directly oversees and is responsible for actions carried out in Penal Colony No 10, and has failed to ensure the protection of detainees’ rights and safety and the maintenance of law and order. Semyon Kuznetsov therefore bears responsibility for the abuse of prisoners committed by the staff of Penal Colony No 10.

Hundreds of Ukrainian prisoners of war as well as Ukrainian civilians captured in the occupied Ukrainian territories have been held in Penal Colony No 10. Former detainees report inhuman and degrading treatment and torture, including electric shocks, beating, stress positions causing trophic ulcers, sexual violence, mock executions and the denial of medical care. Civilians are subjected to the same treatment as prisoners of war and are held without trial or status. Human rights defenders have reported about inhuman conditions and torture in this facility since 2012, including towards Russian prisoners.

Therefore, Semyon Kuznetsov is responsible for serious violations or abuses of human rights, including torture and other cruel, inhuman or degrading treatment.

13.7.2026

97.

Ivan Vasilyevich VESHKIN

(Russian: Иван Васильевич ВЕШКИН)

Position: Deputy Head of Penal Colony No 10

DOB: 22.12.1991

Nationality: Russian

Gender: male

Passport number: 8903739994

Ivan Veshkin is the Deputy Head of Penal Colony No 10, which is located in the village of Udarny in the Zubovo-Polyansky District of the Republic of Mordovia. In that position, he directly oversees and is responsible for actions carried out in Penal Colony No 10, and has failed to ensure the protection of detainees’ rights and safety and the maintenance of law and order. Ivan Veshkin therefore bears responsibility for the abuse of prisoners committed by the staff of Penal Colony No 10.

Hundreds of Ukrainian prisoners of war as well as Ukrainian civilians captured in the occupied Ukrainian territories have been held in the Penal Colony No 10. Former detainees report inhuman and degrading treatment and torture, including electric shocks, beating, stress positions causing trophic ulcers, sexual violence, mock executions and the denial of medical care. Civilians are subjected to the same treatment as prisoners of war and are held without trial or status. Human rights defenders have reported about inhuman conditions and torture in this facility since 2012, including towards Russian prisoners.

Therefore, Ivan Veshkin is responsible for violations or abuses of human rights, including torture and other cruel, inhuman or degrading treatment.

13.7.2026

98.

Galina Vasilievna MOKSHANOVA

(Russian: Галина Васильевна МОКШАНОВА)

Position: Head of Medical Unit No 13, Penal Colony No 10

DOB: 16.1.1966

Nationality: Russian

Gender: female

Passport number: 8910200628

Galina Mokshanova is the Head of Medical Unit No 13 of Penal Colony No 10, which is located in the village of Udarny in the Zubovo-Polyansky District of the Republic of Mordovia. In that position, she plans, directs, orders and facilitates activities carried out in medical services of Penal Colony No 10. Galina Mokshanova therefore bears responsibility for the abuse of prisoners committed by the staff of Penal Colony No 10.

Hundreds of Ukrainian prisoners of war as well as Ukrainian civilians captured in the occupied Ukrainian territories have been held in the Penal Colony No 10. Former detainees report inhuman and degrading treatment and torture, including electric shocks, beating, stress positions causing trophic ulcers, sexual violence, mock executions and the denial of medical care. Civilians are subjected to the same treatment as prisoners of war and are held without trial or status. Human rights defenders have reported about inhuman conditions and torture in this facility since 2012, including towards Russian prisoners.

Therefore, Galina Mokshanova is responsible for serious violations or abuses of human rights, including torture and other cruel, inhuman or degrading treatment.

13.7.2026’

Name

Identifying information

Statement of Reasons

Date of listing

‘3.

VK (previously known as Mail.ru group, VK Company Limited)

(Russian: VK)

Address: Moscow, 125167, Leningradsky prospekt 39, bld. 79

Vk.com

Vk.company

INN (Russian tax ID): 3900015862

TIN (TIN): 3900015862

OGRN (Trade register number): 1233900010585

VK is one of the main technological companies in Russia. It provides email and chat services and runs applications and the social media website VKontakte.

VK is the parent company of Communication Platform LLC, the developer and manager of state-supported mobile phone application Max. The development of the Max application was supervised by the Federal Security Service (FSB), which established requirements that the developers of the Max application had to meet. The Max application must be pre-installed on all mobile phones and tablets sold in Russia and is integrated with the Gosuslugi service.

According to numerous experts, the Max application has extensive surveillance features and can monitor communications, including the use of virtual private networks (VPNs), gather data on other applications installed on phones, monitor address books, identify the location of users and install autonomous updates. The introduction and promotion of the Max application by the Russian state have been accompanied by a crackdown on and blocking of other independent applications, such as WhatsApp and Telegram, as well as by a campaign to limit the use of VPNs, which allowed users to access content blocked in Russia.

Information gathered by Russian authorities through the Max application served as a basis to fine a Russian citizen for content posted on the application.

The Max application has benefitted from government-imposed blocks on access to Western and independent competitors, such as Instagram, Facebook, Telegram and WhatsApp, enabling it to increase its revenue and market share.

VK has cooperated with Russian authorities in their repressive actions, including by providing them with data concerning users of its services who posted content criticising Russia’s war of aggression against Ukraine, or other content banned by the authorities.

VK has also participated in the government-ordered ban on the use of VPNs, through which Russian internet users could previously access independent content on the internet.

Therefore, VK provides technical support for the repression of civil society and democratic opposition, including by assisting and facilitating such acts.

13.7.2026

4.

Communication Platform LLC

(Russian: Акционерное Общество Инвестиционная Компания Коммуникационная Платформа)

Address: PR-KT LENINGRADSKII D. 39, STR. 79, 125167 MOSCOW, Russian Federation

www.complatform.ru

mail@complatform.ru

INN (Russian tax ID): 9714058267

TIN (TIN): 9714058267

Communication Platform LLC is a subsidiary company of VK (previously known as VKontakte) and is the developer and manager of state-supported mobile phone application Max. The development of the Max application was supervised by the Federal Security Service (FSB), which established the requirements that the developers of the Max application had to meet. The Max application must be pre-installed on all mobile phones and tablets sold in Russia and is integrated with the Gosuslugi service.

According to numerous experts, the Max application has extensive surveillance features and can monitor communications, including the use of virtual private networks (VPNs), gather data on other applications installed on phones, monitor the address books, identify the location of the users and install autonomous updates. The introduction and promotion of the Max application by the Russian state have been accompanied by a crackdown on and blocking of other independent applications, such as WhatsApp and Telegram, as well as by a campaign to limit the use of VPNs, which allowed users to access content blocked in Russia.

Information gathered by Russian authorities through the Max application served as a basis to fine a Russian citizen for content posted on the application.

Therefore, Communication Platform LLC provides technical support for the repression of civil society and democratic opposition, including by assisting and facilitating such acts.

13.7.2026

5.

VAS Experts

(Russian: Общество с ограниченной ответственностью Вас Экспертс)

Address: Saint Petersburg, Avenue Liteyny 26, building a, office 5-13

OGRN: 1137847014337

INN (Russian tax ID) 7841476577

VAS Experts manufactures, develops, and sells hardware and software related to the so-called System of Operative Investigative Measures (SORM).

SORM is a surveillance system used since the mid-1990s to control internet and mobile communications in Russia, namely the monitoring of phone calls, emails, internet use, text messages and social networks. Mobile phone and internet providers are legally required to install SORM. It is installed in all Russian data centres and at all internet exchange points and within major search engines. User traffic is copied to a separate server or to a data centre available to the Federal Security Service (FSB).

SORM gathers information about users’ physical location, activity patterns, time of device use, users’ behaviour and the use of different SIM cards in one or more devices. It can be used retroactively and without the provider’s knowledge.

SORM has been used to target journalists, opposition figures, minority groups and ordinary citizens. It has also been used to prosecute supporters of the Russian opposition, leaders such as Alexei Navalny, organisers of protests, individuals who ran internet accounts critical of the Russian authorities or produced reports on the political situations and activists who opposed the war of aggression against Ukraine. SORM has also been used to pre-emptively detain individuals suspected of anti-government activities. SORM has had a profound impact on the ability of Russian citizens to access unbiased information about the war of aggression against Ukraine. It was also used to block traffic from, and access to, thousands of Western websites and services.

VAS Experts is involved in the development, supply and maintenance of SORM, including hardware and software integrated into telecoms networks, therefore allowing intelligence agencies to directly access all traffic.

VAS Experts is a key supplier of SORM that complies with interception requirements mandated by the FSB and supports the operation of Russia’s communications surveillance infrastructure.

VAS Experts operates within a framework established and supervised by the Russian authorities. These authorities approve technical requirements for SORM deployment, require operators to coordinate implementation plans, oversee compliance and use the equipment for direct interception activities. Consequently, VAS Experts develops and supplies equipment specifically designed to satisfy surveillance requirements established by the FSB.

Therefore, VAS Experts provides material support for serious violations and abuses of human rights and for the repression of civil society and democratic opposition.

13.7.2026

6.

Norsi-Trans

a.k.a. Closed Joint-Stock Company “Norsi-Trans”

(Russian: Закрытое Акционерное Общество “Норси-Транс”)

Address: 127015 Moscow, Bolshaya Novodmitrovskaya Street 12, building 15, floor 2, room 36)

Date of registration: 16.1.2003

OGRN: 1037700030477

INN (Russian tax ID): 7705051215

Closed Joint-Stock Company “Norsi-Trans” manufactures, develops, and sells hardware and software related to the so-called System of Operative Investigative Measures (SORM).

SORM is a surveillance system used since the mid-1990s to control internet and mobile communications in Russia, namely the monitoring of phone calls, emails, internet use, text messages and social networks. Mobile phone and internet providers are legally required to install SORM. It is installed in all Russian data centres and at all internet exchange points and within major search engines. User traffic is copied to a separate server or to a data centre available to the Federal Security Service (FSB).

SORM gathers information about users’ physical location, activity patterns, time of device use, users’ behaviour and the use of different SIM cards in one or more devices. It can be used retroactively and without the provider’s knowledge.

SORM has been used to target journalists, opposition figures, minority groups and ordinary citizens. It has also been used to prosecute supporters of the Russian opposition, leaders such as Alexei Navalny, organisers of protests, individuals who ran internet accounts critical of the Russian authorities or produced reports on the political situations and activists who opposed the war of aggression against Ukraine. It was also used to pre-emptively detain individuals suspected of anti-government activities. SORM has had a profound impact on Russians’ ability to access unbiased information about the war of aggression against Ukraine. It was also used to block traffic from, and access to, thousands of Western websites and services.

Norsi-Trans is involved in the development, supply and maintenance of SORM, including hardware and software that is integrated into telecoms networks, therefore allowing intelligence agencies to directly access all traffic. SORM includes monitoring equipment installed in facilities of telecommunications providers. Such monitoring equipment provides information to the Russian government’s intelligence agency, including on phone calls, text messages, emails and internet traffic. SORM also facilitates access to communications data associated with messaging application, metadata, mobile numbers, phone identifiers, geolocation, names, email addresses and IP addresses.

Norsi-Trans is a key supplier of SORM that complies with interception requirements mandated by the FSB and supports the operation of Russia’s communications surveillance infrastructure.

Norsi-Trans operates within a framework established and supervised by the Russian authorities. These authorities approve technical requirements for SORM deployment, require operators to coordinate implementation plans, oversee compliance and use the equipment for direct interception activities. Consequently, Norsi-Trans develops and supplies equipment specifically designed to satisfy surveillance requirements established by the FSB.

Therefore, Norsi-Trans provides material support for serious violations and abuses of human rights and for the repression of civil society and democratic opposition.

13.7.2026

7.

LLC Citadel

(Russian: Общество с ограниченной ответственностью “Цитадель”)

Address: 127015 Moscow, Intra-city municipal territory municipal district Butyrsky, Novodmitrovskaya Street 2B

OGRN: 1157746895690

INN(Russian tax ID): 9701012339

Address: 603098, Nizhny Novgorod, pr. Gagarina, 50 (Korpus 9), BTS “Chiornaya Zhemchuzhina”

OGRN: 1055238018098

INN (Russian tax ID): 5260146265

LLC Citadel operates in Moscow and Nizhny Novgorod and develops, implements and provides support for software and hardware of the so-called System of Operative Investigative Measures (SORM). LLC Citadel is the largest manufacturer and reportedly the most important supplier of SORM hardware and software in Russia.

SORM is a surveillance system used since the mid-1990s to control internet and mobile communications in Russia, namely the monitoring of phone calls, emails, internet use, text messages and social networks. Mobile phone and internet providers are legally required to install SORM. It is installed in all Russian data centres and at all internet exchange points and within major search engines. The user traffic is copied to a separate server or to a data centre available to the Federal Security Service (FSB). SORM gathers information about users’ physical location, activity patterns, time of device use, users’ behaviour and the use of different SIM cards in one or more devices. It can be used retroactively and without the provider’s knowledge.

SORM has been used to target journalists, opposition figures, minority groups and ordinary citizens. It has also been used to prosecute supporters of the Russian opposition, leaders such as Alexei Navalny, organisers of protests, individuals who ran internet accounts critical of the Russian authorities or produced reports on the political situations and activists who opposed the war of aggression against Ukraine. SORM has also been used to pre-emptively detain individuals suspected of anti-government activities. It has had a profound impact on Russians’ ability to access unbiased information about the war of aggression against Ukraine and was used to block traffic from, and access to, thousands of Western websites and services.

LLC Citadel is involved in the development, supply and maintenance of SORM, including hardware and software integrated into telecoms networks, therefore allowing intelligence agencies to directly access all traffic. SORM includes monitoring equipment installed in facilities of telecommunications providers. Such monitoring equipment provides information to the Russian government’s intelligence agency, including on phone calls, text messages, emails and internet traffic. SORM also facilitates access to communications data associated with messaging application, metadata, mobile numbers, phone identifiers, geolocation, names, email addresses and IP addresses.

LLC Citadel is a key supplier of SORM that complies with interception requirements mandated by the FSB and supports the operation of Russia’s communications surveillance infrastructure.

LLC Citadel operates within a framework established and supervised by the Russian authorities. The authorities approve technical requirements for SORM deployment, require operators to coordinate implementation plans, oversee compliance and use the equipment for direct interception activities. Consequently, LLC Citadel develops and supplies equipment specifically designed to satisfy surveillance requirements.

Therefore, LLC Citadel provides material support for serious violations and abuses of human rights and for the repression of civil society and democratic opposition.

13.7.2026’