About the author(s):
Aurélien LLorca holds a PhD in Law from Neuchâtel University and two Masters in political science from Sciences Po Grenoble and Paris-Est university. He served during ten years as an Expert for several United Nations Security Council Committees and as Coordinator of the Panel of Experts on the Central African Republic, appointed by the UN Secretary General. He lectures in International Security and IOs at the International Relations Institute of Paris (ILERI) and the Grenoble Law Faculty. His research focuses on UN Security Council subsidiary organs and sanctions. His latest publication on UN sanctions committees and the evolution of their working procedures and decision-making processes was published by Helbing Lichtenhahn Verlag in June 2025.
This post forms part of the Wagner Symposium hosted by the Armed Groups and International Law blog. The introductory post can be found here. The symposium seeks to foster deeper discussion on how best to address the Wagner Group and its affiliated entities.
To maintain and restore international peace and security, the United Nations Security Council (UNSC) may impose on State or non-State actors, under Chapter VII of the UN Charter, coercive measures other than the use of force, known as “UN sanctions”. The UNSC, in its resolutions establishing sanctions regimes, also creates a dedicated subsidiary organ, named “sanctions committees”, to administer those targeted measures – including but not limited to arms embargoes, assets freeze and travel bans. Sanctions committees notably decide on listing or de-listing requests of individuals and entities responsible for sanctions violations, and grant exemptions to arms embargoes, among other activities.
To support the implementation of their Security Council mandate, sanctions committees are assisted by panels of independent experts, appointed by the UN Secretary-General, who investigate sanctions violations, gather evidence in the field, map actors, trace financial and logistical networks. Experts panels submit detailed reports of their findings to the UNSC, for circulation to its 15 Members and publication as an official Security Council’s document, and confidential sanctions recommendations to their respective committees for their consideration.
In theory, such legally-binding framework should prevent, or at least constrain, operations of private military companies or mercenary activities wherever a sanctions regime exists and in absence of specific exemptions. For instance, arms embargoes in Libya and Sudan (Darfur) prohibit the supply of weapons, ammunition, UAVs or military training to local belligerents; asset freezes and travel bans could target individually military contractors and commanders, and asset freezes could apply to private military/security companies and their local branches, commodity brokers or logistical facilitators.
This article provides a brief overview of the UNSC’s monitoring of Wagner Group activities in Sudan (Darfur), Libya, the Central African Republic and Mali, based on public reports submitted to the UNSC by its panels of experts from 2014 to present. Panels serve exclusively in support of their respective UNSC sanctions committees and act independently pursuant to a strictly detailed UNSC mandate, one expressly tailored by a specific UNSC resolution to the circumstances of the conflict or post-conflict situation concerned. Thus, the purpose of this overview is to demonstrate the different approaches taken by the panels towards Wagner, both in terms of its labelling and the effective reach of sanctions over the group. However, unilateral sanctions – such as sanctions imposed by the European Union, the United States, the United Kingdom, etc. – are excluded; such regimes lack independent enforcement mechanisms and do not provide for public reporting.
Sudan
According to the review of Panel’s publications, activities in Sudan of private military or security contractors of Russian origin, or employed by a Russian-based organisation, were not reported during the period under review to the UNSC. The reports’ accounts of foreign fighters, mercenaries, and illicit arms flows only focus on actors from Darfur itself, as well as individuals and groups from neighbouring Chad, South Sudan, and Libya.
The only instances where Russian nationals are mentioned concern training activities taking place in Darfur with prior authorization of the UN Security Council Committee established pursuant to resolution 2127 (2013), as reported by the Panels respectively on Sudan (S/2019/34, p. 11, para. 36) and on the Central African Republic – the latter report mentioning five Russian military and 170 civilian instructors from the Russian Federation, without indicating whether such civilians were employed by a private military company or individual contractors (S/2018/729, p. 7, paras. 12-13 and annex 2.1, pp. 30-31). By contrast, activities related to Wagner in Sudan have been the subject matter of several international media articles since at least 2022.
Libya
Russian private military involvement in Libya initially surfaces in the 2017 Panel’s report, and concerns a Russian private company founded by Oleg Krinistyn and called Rossiskie System Bezopasnosti (RSB) Group, contracted then for mine-clearance by a cement factory in Benghazi (S/2017/466, 1 June 2017, p. 49, para. 170 and annex 3, p. 176).
Wagner is first highlighted in the Panel’s 2021 final report, which provides the most exhaustive case to date. Experts devote an entire subsection (S/2021/229, p. 32, paras. 93-97), together with a detailed 38-page annex (op. cit., annex 77, pp. 428-466) which includes the group’s background, command structure (op. cit., annex 77, p. 449, table A.77.1) and activities in Libya since October 2018. The report also refers to Yevegeny Prigozhin and Dimitry Utkin, among others, reproduces pay slips, photographs and documents, and also reports on the arrival of MiG-29A (op. cit., annex 31, p. 149) and Su-24M (op. cit., annex 32, p. 150) combat jets flown by Russian Air-Force pilots under Wagner control. Experts note in the section on “foreign armed groups and fighters” that Syrian 2,000-strong contingent aligned with Haftar Affiliated Forces (HAF) “operate alongside ChVK Wagner” (op. cit., p. 8, para. 23).
In 2022 (S/2022/427), experts reported additional details on breaches of the sanctions regime on Libya, including violations of International Humanitarian Law (IHL), committed by Wagner. More specifically, a Samsung tablet abandoned south of Tripoli (op. cit., annex 100, pp. 317-344) contained live tactical overlay of minefields, detailed resupply information dated 19 January 2020 and signed “DA” for Dimitry Utkin listing advanced military equipment and weapon systems previously not identified by the Panel.
Finally, in its 2024 report (S/2024/914) that follows Prigozhin’s August 2023 death, the Panel found that “no substantial changes” were made to the nature of the activities of armed elements formerly known as ChVK Wagner in Libya; “these elements continued to support HAF, by providing technical assistance, conducting repairs and maintenance of materiel at Jufrah airbase, and delivering tactical training at Birak al-Shati” (op. cit., pp. 12-13, para. 37).
The Panel considers that such provision of fighters, training, heavy weapons and military equipment constitutes the “direct or indirect supply […] of arms and related materiel” and “other assistance, related to military activities”, as set out in resolution 1970 (2011. However, no individual or entity related to Wagner’s operations in Libya was added so far to the UN sanctions list.
The Central African Republic
“Russian instructors” first surfaced in the Central African Republic (CAR) in the Panel’s 2018 mid-term report (S/2018/1119), which recorded 175 ex-military personnel contracted through the local firm Sewa Security to train FACA units, protect senior officials and escort convoys moving military equipment from Sudan to the CAR (op. cit., pp. 40-41, para. 176). A year later the Panel noted the contingent had grown to 235 and was active in seven provincial towns, still described as “Russian instructors,” but already involved in securing weapons flows and in frontline mentoring of government forces (S/2019/608, annex 6.1, p. 143).
In its 2021 final report (S/2021/569, p. 19, para. 65), experts mention a statement from the coordinator of Russian instructors saying “that all instructors were of Russian nationality and were recruited by the Ministry of Defence of the Russian Federation from an association of primarily former military officers called the Officers Union for International Security”; he added to the Panel “that those individuals had arrived in the Central African Republic in an official capacity on board a military aircraft of the Russian Federation and had not been hired by a private company”.
Nevertheless, experts documented in the same report a significant shift: the instructors were now armed, much more numerous than the authorized threshold of 500 granted by the sanctions committee, leading FACA combat operations, and transporting newly imported armoured vehicles and helicopters whose arrival had never been cleared by the sanctions committee (op. cit., pp. 19-20, paras. 65-69, and p. 23). Witness testimonies collected by the Panel detailed accounts of excessive force, prompting experts to qualify such incidents as “indiscriminate killing by Russian instructors” (op. cit, pp. 23-24, paras. 89-91) as well as “widespread looting” (op. cit, p. 24, paras. 92-93). The June 2024 report confirms the pattern: “Russian instructors” have, alone, “carried out a coordinated air and ground attack on a location known as “Yemen” around 70 km south-east of Sam Ouandja” (S/2024/444, p. 14).
The experts noticed therefore a significant evolution from ostensibly unarmed trainers (2018-19) to combat-leading forces (2020-21), to combat forces operating alone, with a focus on mining areas (2023-24), repeatedly in violation of the sanctions regime, including the embargo, which was eventually lifted in 2024 following the adoption of resolution 2745 (2024).
Taken together, the Panel does not mention Wagner – only “Russian instructors”. Even the joint investigation on a military cargo aircraft registered TL-KMZ conducted by the Panels on Libya and on the CAR does not conclude using the same language: while Libyan experts mention a “cargo aircraft operated by ChVK Wagner” (S/2023/673, p. 31, para. 99, and annexes 68, p. 219, and 69, p. 220), CAR experts say about the same aircraft that it was “used for the rotation of Russian instructors and their equipment” (S/2023/360, pp. 20-21, paras. 97-102).
Mali
In its final 2022 report (S/2022/595), the Panel on Mali records growing anxiety among former rebels, party to the Algiers Peace and Reconciliation (APR) agreement whose application is monitored by the UNSC, that “government forces supported by new partners” might launch operations in the north (op. cit., p. 7, para. 20). The Panel quotes a press communiqué expressing rebels’ “concerns about, inter alia, the potential deployment in northern Mali of the non-conventional military forces known as the Wagner Group” (op. cit., p. 12, para. 47 (b)).
Later, when describing the “Robinet-El-Ataye” massacre of 5-6 March 2022, the Panel details how “white-skinned soldiers” landed by helicopter (op. cit., p. 21, paras. 99 and 103), joined Malian troops, and executed 33 civilians. While the term Wagner never appears, these neutral descriptors mark the first acknowledgement that non Malian military personnel were operating alongside the Forces armées maliennes (FAMa), after the eviction of French forces, and committing violations that could fall under the sanctions regime. The mid-term report of February 2023 confirms the pattern: in the Gao/Ménaka theatre, FAMa “supported by foreign security personnel” deploys in close proximity to signatory armed groups and jihadists terrorist groups, fuelling civilian casualties and inter-communal tension (S/2023/138, p. 10, para. 44, and p .14, para. 62).
In contrast with the Panel’s cautious naming convention, Russian officials actually confirmed to experts, during the Panel’s visit to Moscow on 30 March 2023, the presence of Wagner Group elements in Mali as private contractors (S/2023/578, p. 19, footnote number 29). They also confirmed the presence of a small number of Russian military instructors at Bamako airport. The Mali regime was terminated following the negative vote of the Russian Federation at the UNSC on 30 August 2023 (S/PV.9408).
Conclusion
Across the four UN sanctions regimes under review, experts’ panels adopted manifestly different approaches:
- Sudan (Darfur): no mention of Russian personnel;
- Libya: explicit references to “ChVK Wagner”, exposure of its command structure (Prigozhin, Utkin), investigation on large-scale arms transfers, combat aviation, and documentation of IHL and embargo violations;
- The Central African Republic: references only to “Russian instructors”, usually embedded with the FACA; documentation of indiscriminate killing and looting;
- Mali: consistently euphemistic – using “foreign security partners” or “white-skinned soldiers” when documenting IHL violations, and naming Wagner only when citing a communiqué from an armed-group coalition.
If the lifting of the CAR embargo and the termination of the Mali sanctions regime can be read as attempts to curb neutral, independent monitoring of Wagner, Libya appears to contradict that hypothesis: the sanctions regime there remains in force, and experts continue to document Wagner’s activities. It remains also unclear whether the experts’ use of euphemistic language for Wagner was intended to avoid a diplomatic backlash from the Russian Federation in the Security Council; in any case, the Mali example shows that such caution did not prevent sanctions from being terminated in 2023.
One can only speculate on the reasons why independent experts differ in their analysis and reporting on a similar issue. Even so, it is plausible that Wagner would operate more freely in the absence of UN sanctions mechanisms, much as it had in Syria, given the demonstrable coercive, constraining and signalling effects of such measures (Giumelli, 2011).