Four years into Russia's war in Ukraine, US lawmakers are pushing the Holding Accountable Russian Mercenaries Act to expand sanctions beyond the Wagner Group. The proposed legislation would require agencies to map command structures and funding chains of Russia's evolving paramilitary ecosystem, which now includes Africa Corps and other successor entities. Dubai-based companies have already faced US sanctions for their role in Wagner's gold operations.

Russia's paramilitary model has shifted from Wagner's overt operations to more deniable structures linked to the defense ministry. These networks generate revenue through mining concessions across Africa, with gold moving through opaque trading routes to refining hubs in the UAE and Switzerland. Secondary sanctions targeting commodity traders, maritime insurers, and logistics brokers could disrupt the financial arteries sustaining these operations.

The article warns that foreign terrorist organization designations alone won't solve the problem. While the 2019 IRGC designation expanded criminal liability, its practical economic impact was limited since many companies had already exited Iranian markets. Russia's networks similarly operate as instruments of state power rather than independent actors, requiring sustained pressure on commercial enablers rather than just terrorism labels.

Real leverage comes from exposing command relationships and disrupting supply chains that convert minerals and shipping routes into geopolitical leverage. The Kremlin's system thrives on deniability, making it essential to build evidence linking ground abuses to directing structures. Without targeting the commercial infrastructure, new designations will prove ineffective against this hydra-headed threat.