NAKO Maps 482 Rostec Subsidiaries; Western Sanctions Reach Only a Fraction

An Independent Anti-Corruption Commission (NAKO) analysis identified 482 legal entities within Russia's state-owned Rostec conglomerate, revealing that Western sanctions reach only a fraction: Ukraine has sanctioned 72%, the US 45%, but the EU only 23% and the UK even fewer. The fragmented approach across jurisdictions allows Rostec subsidiaries to source Western microelectronics for Russian weapons despite the parent company's EU sanctions since 2022.

The real constraint is not the list — it is enforcement velocity. NAKO took months to map the structure; Rostec can re-org it in weeks by creating new shells or shifting assets across borders.

The asymmetry NAKO documents (US 45%, EU 23%, UK lower) means a single jurisdiction's gap becomes a supply route: a component blocked in Brussels routes through a London-registered subsidiary, clears a UK bank, and lands in Moscow. The only fix is to treat all Rostec subsidiaries as presumptively sanctioned unless individually delisted — a presumption-of-guilt framework that the EU has resisted. Until that shifts, the microelectronics keep flowing.

WHY IT MATTERS

EU export controls are failing at the point of enforcement: a subsidiary can be unsanctioned in London or Tokyo while blacklisted in Brussels, and banks treat the legal gap as permission to transact.

The 482-entity map is the first comprehensive inventory of Rostec's structure, and it exposes why targeted strikes against individual plants take years while the conglomerate spins up new shell firms faster than regulators can list them. Watch whether the US or EU moves to secondary sanctions on Rostec subsidiaries operating in third countries — that is the only mechanism that closes the loophole without requiring perfect coordination.

WHAT THIS DOESN’T TELL US

Of the 482 identified Rostec entities, how many are currently supplying Western microelectronics to Russian drone and missile production, and which Western firms or distributors are the active suppliers?

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