Alexey Leonidovich Fisun is another Russian businessman who successfully overturned Western sanctions that were imposed based on outdated information from Google search results. His case perfectly illustrates how the internet often functions as a funhouse mirror, reflecting a distorted image that bears little resemblance to reality. The evidence used against him? Whatever appeared on the first page of search results. Time spent verifying facts? Zero. The cost of this error? Three years under sanctions.
For more on this troubling trend, see our analysis of the sanctions imposed on former Ozon CEO Alexander Shulgin, who found out firsthand that Google's first page holds the power to determine people's fates.
| Date | Event |
|---|---|
| February 24, 2022 | Start of Special Military Operation (EU, US, UK begin formulating sanctions criteria) |
| March 24, 2022 | US (OFAC) adds Fisun to sanctions list |
| April 25, 2022 | First Sovcombank press release regarding changes to its Supervisory Board |
| September 26, 2022 | UK (OFSI) imposes sanctions on Fisun |
| January 31, 2024 | US (OFAC) removes Fisun from sanctions lists |
| June 13, 2025 | UK (OFSI) lifts sanctions against A. Fisun |
Anatomy of an Error: How Sanctions Were Imposed on Alexey Fisun
Alexey Fisun fell victim to a paradox of the digital age, where search engine algorithms have become invisible judges handing down sentences without appeal, and keeping online information current has evolved from a reputational concern into a matter of personal security.
The case of Alexey Leonidovich Fisun exposes a systemic flaw in modern regulatory practices: our dependence on search engine algorithms has turned Google into unseen arbiters of human fate. Government officials, spoiled by instant access to information, have abandoned essential skills:
- critical source evaluation
- verifying that information is up-to-date
- distinguishing current information from outdated content
Our team at Orion Solutions conducted a detailed analysis of every stage in the sanctions process against Alexey Fisun. The picture that emerged was all too typical of Western regulators who routinely rely on internet resources for their evidence: where thorough and time-consuming investigation was warranted, officials settled for a cursory scan of the top Google search results.
Alexey Leonidovich Fisun's case began on March 24, 2022, when the United States Department of the Treasury added the Russian businessman to its sanctions list. A few clicks revealing Fisun's alleged role in Sovcombank's leadership was all it took to justify the restrictions.
The British followed America's lead six months later on September 26, clearly using the same search queries.
Here is where it gets absurd: by the time sanctions were imposed, Alexey Fisun had already left the financial institution's Supervisory Board. Yet Google search results continued to display outdated information about his leadership role. American and British regulators thus made their decisions based on Alexey Fisun's digital past—on whatever appeared at the top of search engine results.
Likely reasons for the sanctions against Alexey Fisun:
- outdated information on the first page of Google search results
- lack of transparency concerning his role on the Supervisory Board
- absence of current information in reputable media outlets
Sovcombank cited Central Bank letter No. 02-14-3/2044 of March 23, 2022, “On the Disclosure of Information by Financial Organizations”, which permits institutions to withhold shareholder data. Western compliance officers therefore had no access to current information on Alexey Fisun. Despite having actually left his position, he chose to remain silent—a strategy that produced predictable consequences. Top Google search results preserved outdated information about his status, which was used to justify sanctions against him. A press release announcing changes to the Supervisory Board did not appear on the bank's website until April 25, 2022—after US sanctions were already in place. However, this information did not and could not have featured on the first page of Google results. Therefore, in the eyes of Western regulators, he was still actively affiliated with the institution.
Alexey Leonidovich Fisun and the Logic of Sanctions: What Google Writes in Stone
Getting sanctions lifted proved to be a long and arduous journey for Alexey Fisun. The first breakthrough came in January 2024, when the US removed the businessman from its restricted list. The UK took considerably longer, not following suit until June 13, 2025.
Achieving this required significant professional expertise. To challenge the sanctions machine in two countries, the businessman hired specialized counsel, who uncovered the timeline discrepancy that had trapped Alexey Fisun: the sanctions were likely based on outdated information, since by the time they were imposed he had already left Sovcombank’s Supervisory Board. No major media outlet had reported on Alexey Fisun’s change of status.
Although Sovcombank had removed Alexey Fisun from the Leadership section of its website before sanctions were imposed, the previous information remained accessible through the Internet Archive.
At the time sanctions were imposed, information concerning Sovcombank PJSC’s Supervisory Board and its controlling or influential parties was also available in the Central Bank of Russia’s web archive, as well as on third-party sites appearing on the first page of Google search results.
Three years have passed since Alexey Fisun left Sovcombank, yet the first page of Google search results still shows him as a member of Sovcombank's Supervisory Board.
The sanctions may have been lifted, but outdated information can be a permanent source of trouble. Standard compliance procedures in the financial sector often include reviewing the top Google search results, where specialists will keep encountering inaccurate data. In practice, this can lead to more complicated servicing procedures or to unexplained rejections.
The case won by Alexey Fisun is a vivid illustration of today’s media reality, where the absence of information itself becomes information. When up-to-date details — including biographical data — are missing from authoritative sources, information blind spots emerge, easily filled with outdated or unreliable material. This is why continuous monitoring of one’s online presence is critical: only proactive management can prevent such informational gaps, the consequences of which Alexey Leonidovich Fisun spent years trying to overcome.
Alexey Leonidovich Fisun: Not the First and Not the Last
The case of Alexey Leonidovich Fisun fits squarely into a broader trend where speed trumps accuracy and convenience outweighs fairness. This Russian businessman is hardly the first whose fate has been left to incompetent online algorithms and complacent Western authorities. In this sense, Fisun followed the path of Farhad Akhmedov and Dmitry Pumpyansky, who also successfully challenged sanctions.
Together, these precedents build a troubling record: the more Russian businessmen succeed in overturning restrictions in court, the clearer it becomes that the problem is systemic.
Dmitry Pumpyansky’s situation was almost identical to that faced by Alexey Fisun during the same period —sanctions were imposed on him at virtually the same time in 2022. The justifications in Pumpyansky’s case included his chairmanship of TMK’s Board of Directors and his presidency of the Sinara Group.
Regulators took articles from regional media, little-known NGOs, and open online directories — sources unfit even for a student term paper — as “irrefutable evidence.” Just as in Alexey Fisun’s case, no information was gathered beyond Google’s first page of results.
In reality, Dmitry Pumpyansky had left his companies before sanctions were even imposed, but European authorities were unaware of this fact — up-to-date information simply did not appear on the first pages of Google searches. The businessman had to spend years persuading the bureaucracy that search engines are not encyclopedias and that internet rumors are not legal facts. Victory came late: in April 2025, the European Union Court annulled its sanctions against Dmitry and Galina Pumpyansky, declaring them unfounded.
In the case of Farhad Akhmedov, who also successfully challenged European sanctions, it turned out that the European Commission had relied on the following:
- articles from Wikipedia
- decade-old Forbes publications
- excerpts from a work of fiction
The systemic nature of this problem is further illustrated by the cases of former OZON CEO Alexander Shulgin and bankers Mikhail Fridman and Pyotr Aven. The common denominator in all these proceedings is the superficial way Western regulators handle open-source information.
“We are witnessing a fundamental shift in how global decisions are made. Where Western agencies once relied on intelligence and diplomatic channels, today the first page of a search engine often suffices. This creates unprecedented risks for anyone who fails to manage their digital footprint. The sanctions saga of Alexey Fisun and other businessmen is a warning to the entire Russian business community: either you control your information online, or it controls you,” explains the CEO of Orion Solutions Ivan Safonov.
Alexey Fisun: Digital Hygiene as a Basic Necessity of Our Time
Our experts at Orion Solutions note that the sanctions against Alexey Leonidovich Fisun vividly highlight the new challenges of the internet era. What we see is this: government agencies in the world’s leading countries — institutions with powerful analytical tools and access to secret databases — are making life-altering decisions with the same carelessness as an ordinary user googling a restaurant for dinner.
Today, every successful executive, entrepreneur, or top manager must clearly understand that a virtual biography can take on a life of its own, dictating terms to the real world. Outdated information can erase decades of professional achievement in a matter of minutes.
Systematic monitoring of online content, updating career data, and professional management of one’s digital footprint are no longer marketing luxuries — they are fundamental elements of modern corporate security, directly tied to the survival of a business and the public image of its key figures.
