After the onset of the 2022 invasion of Ukraine, the Russian Federation became the most sanctioned country in the world, leaving behind long-sanctioned states such as Iran and North Korea (Bergmann et al., 2023). In contrast to the limited response from democratic countries to the 2014 annexation of Crimea (Rabinovych and Pintsch, 2024), this time, the full economic weight of sanctions was directed at the Kremlin. As the war continues with increasingly little prospect of resolution, more sanctions have been imposed on Russia. While Western decision-makers have the final say in introducing these measures, the sanctions regime design owes much to the involvement of the Russian opposition (European Council, n.d.). The most prominent and active actor driving sanctions was the Anti-Corruption Foundation, founded by the late Russian opposition leader Alexei Navalny. The ACF’s most notable achievement was the creation of the “ACF 6,000 List” targeting Russian “bribe-takers and warmongers” (The Anti-Corruption Foundation, n.d.). Serving as a guideline for the international community, this list has been adopted, in varying proportions, by the EU, US, and UK, becoming the foundation for the international sanctions regime (Radio Liberty, 2022). This essay explores how, why, and with what legitimacy the Anti-Corruption Foundation shapes international sanctions policy against Russia following the 2022 invasion of Ukraine.

Theoretical Framework and Key Concepts

Transnational Governance and Civil Society

Traditionally, transnational governance was approached through the lens of methodological nationalism and analysed through a state-centric perspective (Jong, 2023). However, decision-making in transnational governance is inherently polycentric, meaning that there is no single actor, such as the state, that formulates and implements global public policy (Cerny, 2017, as cited in Stone, 2019). Instead, various state and non-state actors collaborate and together constitute ‘global policy networks’ (Orenstein, 2005).

With this shift, civil society—or “global civil society”—became one of the crucial actors in transnational governance (Perret, 2006). Global civil society empowers individuals to pursue democracy and advocate for ‘humane governance’ worldwide, often through transnational social movements. Civil society, represented by different organizational forms such as social movement organizations, NGOs, and cross-country third-sector associations, is undisputedly incorporated into the structure of global governance (Martens, 2008).

The emergence of a transnational—or trans-societal—approach, which shifts the focus to transnationalism in global policy, has advanced discussions about the role of non-state actors in international relations and their contribution to (liberal) norms diffusion (Martens, 2008).  Thus, a transnational approach can provide insights into how democratic values are propagated through NGO-led advocacy and multilateral pressure vis-à-vis autocratic states (Risse-Kappen, et al., 1999). 

Activist NGOs: Parallels with Social Movements and Strategic Approaches

According to Spiro (2010), NGOs can be categorized as service-based or activist. While activist NGOs are not identical to social movements, their strategies and goals can be analyzed through a social movement theory. Demirovic (1998) argues that activist NGOs emerged partly from the protest cycles of new social movements and they follow similar paths: resource mobilization, issue framing, leveraging political opportunities, and employing identity-oriented approaches. Following the logic of social movements, NGOs must select messages that have potential to resonate with their audience, encompassing several dimensions: diagnostic (what is the problem?), prognostic (what can be done?), and motivational (how to inspire action) frames. Additionally, like social movements, in order to achieve their goals, NGOs should use a political opportunity, identifying the right time, place, and actors to have strategic partnerships with (Tarrow, 1998).

Transnational Advocacy Networks (TANs)

Activist NGOs, often being part of transnational advocacy networks—a network of individuals, organizations, or groups promoting policy change—pursue two primary pathways to amplify their effect in authoritarian contexts. According to Keck and Sikkink (1998), first, NGOs lobby for change by information production, utilizing “naming and shaming” strategies (Hafner-Burton, 2008). By exposing the misconduct of an authoritarian regime and calling out perpetrators, NGOs draw international attention to an issue. Second, NGOs contribute to mobilization of local population around specific problems and create strong linkages between domestic civil society and populations in democratic countries.

Empirical studies suggest that while local mobilization is important, information production plays a more decisive role in transnational advocacy (Murdie and Peksen, 2012). It’s NGOs’ unique expertise and message framing that significantly influence policymakers in democratic countries in introducing sanctions. However, while the ‘naming and shaming’ strategy is widespread among NGOs, improvements in a target country often remain anecdotal (Hafner-Burton, 2008).

Question of legitimacy

For an NGO to exert meaningful influence in transnational governance, it must establish legitimacy. The legitimacy of non-state actors in global politics revolves around the idea of how these agents’ power over others can be justified and why people recognize and accept this authority (Partzsch, 2018).  According to Willets (2020), legitimacy of non-state actors raises the question of how such acceptance is demonstrated and, more importantly, measured, in the absence of traditional democratic tools like popular elections.

Partzsch (2018) identifies three key criteria for evaluating legitimacy of an NGO in transnational governance: 1) legitimacy through political impact, 2) legitimacy through broad participation of the deme, and 3) legitimacy through control and accountability. Ultimately, to be considered legitimate, an activist NGO in transnational governance should also satisfy the core requirements of democratic legitimacy (Koppel, 2013). This legitimacy does not derive from direct elections but rather from of an NGO’s activities, its involvement in global networks and social movements that constitute the ‘global civil society’.

From Domestic Non-Profit to Global Actor: The Evolution of the Anti-Corruption Foundation

The Anti-Corruption Foundation (ACF) was founded in 2011 by Alexei Navalny, Russia’s most prominent opposition leader and a key opponent of Vladimir Putin. From the outset, the ACF was committed to pressuring the Russian government to bring about political change and reform, focusing primarily on campaigns targeting corruption and exposing the corrupt Russian elite. The ACF began by recording short YouTube investigations revealing corruption schemes of Russia’s most influential political and bureaucratic figures. Over time, the ACF’s activities gained greater visibility and, hence, started posing a threat to the stability of an increasingly authoritarian regime.

As the ACF gained attention both domestically and internationally, the intensity of state repression towards Navalny and his allies also increased. The organization’s activities were gradually outlawed, criminal cases were brought against Navalny and the ACF employees were forced into exile. Financially constrained and burdened by lawsuits, the ACF ceased to exist as a legal entity in Russia, only to be reborn abroad as an international non-profit (RFE/RL, 2022). Despite being imprisoned, Navalny continued to play a pivotal role behind the scenes until his death in a Russian Arctic prison in 2024 (RBC, 2021).

Today, the new leadership of the Anti-Corruption Foundation continues to follow in Navalny’s footsteps, focusing on exposing the corruption of the Russian elite internationally. Following the 2022 invasion of Ukraine, the ACF began compiling a sanctions list of “Russian war enablers”. However, the practice of designing sanctions targeting Russia, spearheaded by a Russian opposition, was not new. Its history goes back to the Magnitsky Act, adopted in the United States in 2012, which served as an inspiration for the ACF’s work. The Magnitsky Act emerged in response to the death in custody of Russian tax lawyer Sergey Magnitsky, who investigated massive fraud involving Russian officials and was advocated by the Russian opposition, including Vladimir Kara-Murza, a prominent Putin’s critic and political activist (Prins, 2023).

How the ACF Shapes a Sector of Transnational Governance—Sanctions Policy Towards Russia

Since its foundation, the Anti-Corruption Foundation (ACF) has been an active player in advocating for action against the Kremlin and Russia’s corrupt elite. Its activity noticeably increased after February 24, 2022, when the ACF started working on a list of 6,000 Russians titled “Bribe Takers and Warmongers”. This list was published in ­2022 and has been continuously updated since then. The list is organized into several categories, including war organizers, propagandists, corrupt officials, and compromised celebrities. Each entry includes a brief description in English, providing the context for why personal sanctions—a travel ban or asset freeze—should be imposed on this individual (The Anti-Corruption Foundation, n.d.).

By creating the “6000 list”, the ACF adopted a key pathway of transnational advocacy: information production. The ACF has not only exposed war enablers by providing detailed information about them but also employed a “shaming and blaming” strategy. In doing this, ACF activists highlighted the direct culpability of warmongers, emphasizing their real power in perpetuating the war in Ukraine, as opposed to the relative powerlessness of ordinary Russian citizens.

Drawing on lessons learned during the development of the Magnitsky Act, global advocacy campaigns, and academic literature, the ACF tailored its strategy to the specific context of the authoritarian regime in Russia. Empirical studies show that sanctions designed by democratic countries and targeting authoritarian regimes remain largely unsuccessful—as in the case of Cuba, Iran, or Mozambique (Lektzian and Souva, 2007)—since economic pressure does not trigger public outrage and demands for government action (Allen, 2008). In authoritarian regimes like Russia, population often lacks the resources for mobilization and is unlikely to protest against its governments due to fear of repression (Lektzian and Souva, 2007). Moreover, sanctions often disproportionately affect ordinary citizens rather than the ruling elite, who continue to benefit from the political status quo. Recognizing these challenges, the ACF designed its sanctions to specifically target the Russian elite and cause maximum damage.

The ACF also focused on mobilizing both Europeans and the Russian diaspora in democratic countries to support sanctions against the Russian elite. The organisation framed sanctions against the Russian elite as the most effective, timely, and fair method to stop the war in Ukraine and promote democratic change in Russia. Additionally, the ACF fostered strong civil society linkages between Russia and Western democracies, presenting Russian civil society as aligned with the values and interests of people in democratic nations.

Tactics of Transnational Advocacy

The ACF employs several tactics common to transnational advocacy networks, including:1) symbolic politics, or the ability to call upon symbols; 2) leverage politic, namely the ability to call upon powerful actors to influence the situation and pressure the target state; and 3) accountability politics, which aims at holding powerful actors accountable for their actions.

As for symbolic politics, the ACF uses various symbols to illustrate the regime’s corruption and connect it to the war that had become possible with Putin in power. For instance, a “golden toilet brush”, discovered in a documentary about Putin’s alleged palace, became a widely recognized symbol of protest against Russia’s corrupt elite, both in Russia and the West (Baker, 2021).

Leverage politics, in this case standing for mobilization of powerful actors to exert pressure on the Kremlin, is the key aspect of the ACF’s work. The organization has formed strategic partnerships with Western policymakers, legislators, and NGOs to promote sanctions against the Russian elite, such as the US, the EU and the UK (Radio Liberty, 2022). The organization also amplifies its reach through social media channels, shaping public opinion in the West and influencing decision-makers. For instance, a film about Navalny’s life, promoted by his team, won the Oscar for best documentary feature, significantly shaping public perception of the ACF in the West in a positive light (Politico, 2023).

Lobbying and Representation in Transnational Advocacy

As part of its transnational advocacy strategy, the ACF employs a set of tools to pressure the Kremlin via Western states. First, the ACF consistently lobbies sanctions behind closed doors or publicly in European and international institutions (European Parliament, 2024). Second, the ACF regularly participates in international activities, including forums and conferences (Bayer, 2024), enhancing its visibility and credibility as legitimate representatives of Russians as opposed to the illegitimate Russian political elite (European Parliament, 2024).

Nevertheless, the ACF is constrained in advancing accountability politics. The organization has repeatedly criticized some Western countries for allowing Russian oligarchs, such as Boris and Arkady Rotenberg, to maintain their assets within their jurisdictions despite evidence of their connections to the Kremlin (OCCRP, 2023). However, while the ACF exposes Western inaction—often driven by economic interests—towards Russian corrupt yet influential figures, it lacks the leverage to hold the West fully accountable. The reason for that is the need to maintain strategic alliances, with democratic countries which occasionally requires accepting compromises.

Why Can the ACF Influence Global Sanctions Regime Against Russia

The ACF’s ability to shape sanctions policy towards Russia primarily lies in its unique expertise. The ACF produces local, in-depth knowledge of Russian corruption through its investigations. This insider understanding of the Russian context is the knowledge that is often inaccessible to Western actors or external observers, making decision-makers in democratic countries collaborate with the ACF and rely on its expertise.

In creating the 6000 List, the ACF leveraged its investigation findings and fieldwork, encompassing both qualitative and quantitative research (Filp, 2021). After analyzing and verifying a vast amount of information, the ACF compiled the most comprehensive and reliable list of individuals connected to corruption or war-enabling activities in Russia. The ACF’s credibility as the main and trustworthy Russian opposition group positions it as a key actor in an epistemic community—a network of experts who inform global governance—and transnational sanctions policy professionals, who connect globally to shape, implement or coordinate global policy (Stone, 2019). Although the ACF’s formal status in the West remains undefined, the organisation functions as a trusted source of expertise and is occasionally co-opted into private advisory bodies (The Anti-Corruption Foundation, 2024).

Transnational Advocacy and a Political Opportunity Window

A crucial factor in the ACF’s success in influencing transnational policy is its ability to seize the political moment. According to political opportunity structure theory, external conditions—such as public sentiment and political crises—create openings for advocacy. Research (Peksen, 2009) highlights that sanctions become a tool that democratic elites use against an authoritarian regime to respond to national calls-for-action at the time of national and international crises. The invasion of Ukraine created an ideal political opportunity window (Ruhlman, 2019), aligning Western political moods with the need for decisive action against Russia and the pillars of its authoritarian regime. At the same time, sanctions were seen as a relatively low-risk yet impactful response, signalling the strong disapproval of the Kremlin’s actions without escalating tensions to extreme levels (Kim and Whang, 2018). 

Following the invasion, it became clear that the West had to act, not just to uphold democratic values but also to appeal to voters in the West. Public demand for action in support of Ukraine was clearly pronounced (European Parliament, 2023), and sanctions became a way for political leaders to respond to these public demands for justice and appease domestic constituencies.

Effective Framing of Grievances by the ACF

The ACF’s success in influencing sanctions policy can also be attributed to how effectively the organisation frames grievances (Snow and Benford, 1992) for both Russian and Western publics. The messages resonated with the audiences as they addressed three critical elements: they were diagnostic (the corrupt regime in Russia made the war in Ukraine possible), prognostic (the Russian elite should be sanctioned) and motivational (“let’s cut the lifeline of Russian war-enablers”). As Gerhards and Rucht (1992) argue, framing plays a decisive role in transnational advocacy campaigns—such as the ACF’s efforts to build momentum for imposing sanctions on the Russian elite.

The ACF’s Role in Shaping International Sanctions: Where Does Its Legitimacy Come From?

Understanding what legitimacy enables the Anti-Corruption Foundation to shape international sanctions policy towards Russia requires answering how the ACF’s influence is justified and why international state and non-state actors recognize and accept its authority. To answer this question, different kinds of legitimacy should be analysed and applied to the case of the ACF.

First, legitimacy through political impact. Indeed, the ACF wields significant political influence over Western state and non-state actors, as they often heed its calls to act against the Russian government—most notably through the sanctions. Democratic countries have not only listened to and acted upon, but have also largely adopted the sanctions list proposed by the ACF. This adoption reflects the trust and credibility Western decision-makers place in the organisation (Radio Liberty, 2022).

Second, legitimacy through public support, or the ‘participation of the deme’, among both Russians and Western audiences (Lallouyet, 2024). This support manifests itself in the organization’s extensive network of allies, donors, and volunteers around the globe. Political endorsement by influential Western academic and policy figures—such as Francis Fukuyama, Anne Applebaum and Guy Verhofstadt (RFE/RL, 2022) on the advisory board—further reinforced the ACF’s legitimacy.

Democratic Legitimacy

Democratic legitimacy—a core requirement for a non-state actor operating in transnational governance (Koppell, 2023)—is another pillar of the ACF’s influence. As the leading opposition force to Vladimir Putin in the eyes of many in the West, the ACF derives much of its legitimacy from its advocacy for democratic values in Russia. However, as an international NGO positioned to work in the interests of Russians, the ACF needs to strike a delicate balance between aligning with Western priorities—such as supporting Ukraine—and maintaining connection to the Russian society. Critics argue that this dual focus has led to the ACF losing its touch with the domestic population (Walker, 2023). As a former activist from Navalny’s team said, “[t]heir priority seems to be lobbying sanctions rather than helping people in the country.”

Operating under an authoritarian regime like Russia poses unique challenges for an NGO’s legitimacy. Designated as an extremist organization and outlawed by the Russian government, the ACF had to establish its legitimacy on the international arena while countering the Kremlin’s efforts to discredit it.

Additionally, the legitimacy of the ACF has been questioned in the ‘post-Navalny’ era (Walker, 2023). While the organisation continues to carry Navalny’s name, reputation, and legacy, no current member can fully substitute the late opposition leader in his role. Even Navalny’s widow, Yulia Navalnaya, who has gained visibility as an emerging opposition figure engaging with Western politicians, does not enjoy the same level of legitimacy as her husband.

Compounding these challenges, recent scandals within the Russian opposition, including allegations of financial misconduct involving the ACF, have raised questions about the organization’s credibility (Meduza, 2024). Critics have also accused the ACF of perpetuating imperialist perspectives and adhering to a traditional Russian state-centric approach to governance, particularly concerning marginalized populations and indigenous peoples of Russia (Julian-Varnon, 2024).

Conclusion

This essay explores how, why and with what legitimacy the Anti-Corruption Foundation, founded by late Alexei Navalny, shapes a policy sector of transnational governance—international sanctions regime against Russia following the invasion of Ukraine. By leveraging its local expertise, effective advocacy strategies, and efficiently framing its messages to appeal both to the Russian diaspora and Westerners—policy-makers in particular—the ACF has seized an ideal political opportunity window to emerge as a significant transnational actor, designing a sanctions regime against the Russian elite. The ACF’s “6000 List,” targeting Russian warmongers, was in varying proportions adopted in the West, underscoring the organization’s legitimacy and credibility in the eyes of democratic states.

However, the ACF’s influence is constrained by the lack of formal status in the West, incapacity to maintain Navalny’s legacy and a non-inclusive approach to governance. Despite this, the ACF continues to operate as an international non-profit promoting sanctions against the Russian elite, while aiming to maintain its connection with Russians and respond to their domestic needs.

Bibliography

Allen, S. (2008). The domestic political costs of economic sanctions. Journal of Conflict Resolution, 52(6), 916–944.

Bayer, L. (2024, February 16). Yulia Navalnaya at Munich Security Conference: Fighting Putin’s regime. The Guardian. https://www.theguardian.com/world/2024/feb/16/yulia-navalnaya-munich-security-conference-navalny-putin

Bergmann, M., Toygür, I., & Svendsen, O. (2023). A continent forged in crisis: Assessing Europe one year into war. Center for Strategic and International Studies (CSIS). https://www.csis.org/analysis/continent-forged-crisis-assessing-europe-one-year-war

Cerny, P. G. (2017). The limits of global governance: Transnational neopluralism in a complex world. In Partnerships in international policy-making. London: Palgrave Macmillan.

Demirovic, A. (1998). Cycles of protest and political change in the 1990s. Theory and Society, 27(6), 843–875.

European Council (n.d.). Sanctions against Russia explained. Retrieved from https://www.consilium.europa.eu/en/policies/sanctions-against-russia-explained/

European Parliament (2024, February 23). Yulia Navalnaya: If you want to defeat Putin, fight his criminal gang [Press release]. European Parliament News. https://www.europarl.europa.eu/news/en/press-room/20240223IPR18080/yulia-navalnaya-if-you-want-to-defeat-putin-fight-his-criminal-gang

Filp (2021). Чему журналисты всего мира могут поучиться у расследователей из команды Навального [What journalists worldwide can learn from Navalny’s investigative team]. Global Investigative Journalism Network. https://gijn.org/ru/istorii/chemu-zhurnalistyi-vsego-mira-mogut-pouchitsya-u-rassledovateley-iz-komandyi-navalnogo/

Gerhards, J., & Rucht, D. (1992). Mesomobilization: Organizing and framing in two protest campaigns in West Germany. American Journal of Sociology, 98(3), 555–596.

Hafner-Burton, E. (2008). Sticks and stones: Naming and shaming the human rights enforcement problem. International Organization, 62(4), 689–716. https://doi.org/10.1017/S0020818308080247

Julian-Varnon, O. (2024). Navalny’s future: Russia did not include everyone. New Lines Magazine. https://newlinesmag.com/spotlight/navalnys-future-russia-did-not-include-everyone/

Jong, A. (2023). Modern episteme, methodological nationalism, and the politics of transnationalism. Frontiers in Political Science, 5, Article 1172393. https://doi.org/10.3389/fpos.2023.1172393

Keck, M. E., & Sikkink, K. (1998). Activists beyond borders: Advocacy networks in international politics. Ithaca, NY: Cornell University Press.

Kim, Y., & Whang, T. (2018). Non-governmental organizations and economic sanctions. International Political Science Review, 39(2), 209–224. https://www.jstor.org/stable/26956728

Koppel, J. G. S. (2013). Accountability and legitimacy in global governance. In Who governs the globe? Cambridge: Cambridge University Press.

Lallouyet, L. (2024). Framing and legitimacy in opposition movements: A Russian case study. Political Science Quarterly, 135(2), 250–273.

Lektzian, D., & Souva, M. (2007). An institutional theory of sanctions onset and success. Journal of Conflict Resolution, 51(6), 848–871.

Martens, K. (2008). Is incorporating civil society further into the structure of global governance really the way forward? Journal of Civil Society, 4(1), 73–75. https://doi.org/10.1080/17448680802051170

Meduza (2024, November 6). The banking scandal that broke Russia’s anti-Kremlin opposition. Meduza. https://meduza.io/en/feature/2024/11/06/the-banking-scandal-that-broke-russia-s-anti-kremlin-opposition

Murdie, A., & Peksen, D. (2012). Shaming and blaming: Using events data to assess the impact of human rights INGOs. International Studies Quarterly, 56(1), 1–16.

OCCRP (2023). Leaked emails reveal how Putin’s friends dodged sanctions with help of Western enablers. Organized Crime and Corruption Reporting Project. https://www.occrp.org/en/project/the-rotenberg-files/leaked-emails-reveal-how-putins-friends-dodged-sanctions-with-help-of-western-enablers

Orenstein, M. A. (2005). The new governance paradigm: Transnational networks and policy diffusion. World Politics, 57(3), 367–396.

Partzsch, L. (2018). Take action now: The legitimacy of celebrity power in international relations. Global Governance, 24, 229–241. https://heinonline.org/HOL/Page?collection=journals&handle=hein.journals/glogo24&id=241

Peksen, D. (2009). Better or worse? The effect of economic sanctions on human security. Foreign Policy Analysis, 5(3), 237–251.

Politico (2023, March 12). Navalny documentary wins Academy Award. Politico. https://www.politico.com/news/2023/03/12/navalny-documentary-academy-award-00086728

Prins, T. (2023). The Magnitsky Act: Origins and implications. Journal of International Justice, 12(3), 345–368.

Radio Liberty (2022). Anti-Corruption Foundation publishes sanctions list of bribe takers and warmongers. https://www.rferl.org/a/anti-corruption-foundation-russia-sanctions-list/31865432.html

Rabinovych, M., & Pintsch, A. (2024). The impact of international organizations on sanctions enforcement. Journal of Common Market Studies. https://onlinelibrary.wiley.com/doi/10.1111/jcms.13572

RBC (2021). Навальный получил девять лет колонии строгого режима [Navalny sentenced to nine years in maximum-security prison]. РБК. https://www.rbc.ru/society/2021/04/17/navalny-sentence

Risse-Kappen, T., Sikkink, K., & Ropp, S. C. (1999). The power of human rights: International norms and domestic change. Cambridge: Cambridge University Press.

Ruhlman, M. (2019). NGOs in global governance. In T. Davies (Ed.), Routledge handbook of NGOs and international relations (pp. 46–62). Routledge. https://doi.org/10.4324/9781315268927-4

Snow, D. A., & Benford, R. D. (1992). Master frames and cycles of protest. In Frontiers in social movement theory. Yale University Press.

Spiro, P. J. (2010). NGOs and the management of globalization. In The role of non-state actors in global governance. Oxford: Oxford University Press.

Tarrow, S. (1998). Power in movement: Social movements and contentious politics. Cambridge: Cambridge University Press.

The Anti-Corruption Foundation (n.d.). Bribe takers and warmongers. Retrieved from https://acf.org/sanctions-list

Walker, S. (2023, September 23). Alexei Navalny: The anti-corruption foundation and Putin’s retaliation. The Guardian. https://www.theguardian.com/world/2023/sep/23/alexei-navalny-incarceration-anti-corruption-foundation-putin

Willets, P. (2020). Non-governmental organizations in global politics: Revisiting legitimacy and accountability. In The construction of global governance. London: Routledge.

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