The CIS layer is where sanctions evasion happens operationally. A Kazakhstani trading LLC with a UAE parent and a Belarusian bank relationship is not a Russian entity on paper — and for a compliance team running a names-only sanctions screen, it clears. We work the layer underneath the paper.
The CIS proxy pattern
Since 2022, designated Russian individuals and entities have routed trade, banking, and ownership relationships through a small number of recurring jurisdictions: Kazakhstan (KZ), Belarus (BY), Kyrgyzstan (KG), Armenia (AM), the UAE (specifically DMCC, JAFZA, and RAKEZ free zones), and Turkey. The pattern is consistent enough that a counterparty whose structure touches two or more of these jurisdictions and whose principals' names are transliterated from Cyrillic warrants an enhanced review by default.
What we map
- Kazakhstan corporate extraction. Direct pulls from the Ministry of Justice Business Identification Number (BIN) registry, Statistics Bureau, and KGD tax registry. Identification of Russian-national directors, Russian-address registered addresses, and proxy beneficial owners.
- Belarus hidden-ownership reconstruction. EGR (Unified State Register) extraction, cross-referenced against the Belarusian bank-account registry and the personified-tax-account data where public. Identification of Russian-parent structures.
- UAE free-zone beneficial owner mapping. DMCC, JAFZA, RAKEZ, and ADGM free-zone disclosures where accessible; commercial-licence extraction via the relevant Department of Economic Development portals; director-interlock analysis across free zones to surface the same individual behind multiple nominally unrelated entities.
- Turkey and Armenia parallel-trade signals. Trade-statistics anomalies (e.g., sudden exports of sanctioned categories from Turkey and Armenia to Russia post-2022), company-registry extraction from TOBB and the Armenian State Register, and banking-correspondent mapping.
- Sanctions cross-match. Every identified individual and entity is cross-matched against the OFAC SDN and consolidated non-SDN lists, EU Official Journal, UK OFSI consolidated list, and the Ukrainian NABC Sanctions Tracker.
Typical engagement
A 5–10 business-day package delivering: a reconstructed ownership chain with every node citable to a primary registry pull, a sanctions cross-match report with direct-link evidence for every matched individual, a behavioural assessment (trade flows, banking footprint, adverse-media exposure in Russian-, Kazakh-, and English-language sources), and an executive summary graded as clear / watch / do-not-proceed with a defensible rationale.
A CIS counterparty with structure you cannot fully map?
Commission a CIS Intel Package- Cyprus to UAE: The 18.4B Russian Deposit Exodus — CIS-OSINT due diligence on UAE free-zone counterparties; the deposit corridor mapped from Cypriot bank data and free-zone licence registries.
- EU Crypto Sanctions on Russia: The CASP Ban, Decoded — the Kyrgyz CASP exposure (TengriCoin / A7A5 / Grinex) is now an EU sanctions target.
- Russia's Shadow Fleet: 287 Sanctioned Tankers — the maritime expression of the same UAE-and-CIS proxy architecture this service maps in corporate structures.