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........

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