Copy-paste from Brussels: The EU’s error-riddled new sanctions package was generated using an LLM

As previously noted by investigative journalist Sergei Ezhov, EU officials failed to specify the patronymic, date of birth, or taxpayer identification number of Promsvyazbank CEO Mikhail Dorofeev when imposing sanctions against him, thereby creating risks for all people named “Mikhail Dorofeev” worldwide. When compiling the new list, the European Commission expanded this practice: in fact, in the case of the 743 individuals on the current sanctions list, none are supplemented with a date of birth or passport number. However, tax identification numbers (TINs) — rarely used in previous sanctions designations — are provided.

The absence of birth dates and passport numbers significantly increases the risk of false matches or missed matches during automated sanctions screening. When processing a Schengen or other visa application, consular officials typically verify an applicant’s passport information and date of birth, but not a Russian taxpayer identification number. After all, if a person is not publicly linked to a Russian company as a founder or director, authorities may have no reliable way to match a TIN to that individual using open-source records, as such information is not generally public. (The same problem can arise in bank compliance checks, which typically rely on a person’s full name and transliterations, date of birth, passport details, address, job title and employer — but not a Russian TIN.)

The Insider has already seen the consequences of this approach: one of our employees was temporarily unable to receive their salary simply due to the fact that they share a surname with a person added to the latest sanctions list, prompting the bank to freeze the payment.

Previously, journalists had repeatedly pointed out factual errors made by European officials when compiling sanctions lists. For example, the EU imposed sanctions on comedian Mikhail Galustyan by using his stage name (the artist’s official name is Nshan). An error was also made regarding his date of birth: Galustyan was born in 1979, not in 1970, as stated in the EU Council’s implementing regulation. These errors have not been corrected a year and a half after the document was published.

These oversights may seem minor, but they can have serious legal consequences for EU authorities. In May 2025, for example, an EU court lifted sanctions against Andrei Kharkovsky, described as a “representative of the Cossack Union,” after Brussels failed to establish his connection to the organization. The sanctions listing did not include his date of birth or other identifying information sufficient to distinguish him unambiguously.

Documents such as the October package are examples of “Potemkin sanctions.” They create the appearance of intense activity, and the sheer scale of the lists might impress an outside observer. In reality, however, the latest package completely ignores the Chinese manufacturers and banks that continue to supply Putin’s war machine.