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Alexander Shulgin is yet another Russian businessman who came face to face with the reality that today, Google's first page decides people's destinies.
The former CEO of Ozon found himself in a situation that vividly illustrates a new challenge of the modern era: his EU sanctions were renewed twice not because of anything he had actually done, but because of a false digital trail. Shulgin had been on the restrictive lists of European countries since April 2022, and was only removed in September 2023.
One click on the first link in Google. Eighteen months of international sanctions. Millions in losses from frozen assets. The math of the modern online age is harsh and unforgiving — minimal effort by regulators translates into maximum consequences for the businessman.
This case, examined in detail by the Orion Solutions team, once again demonstrates how managing one's digital profile has ceased to be a matter of image and become a matter of business survival.
EU Sanctions Against Shulgin: A Verdict Based on Search Results
The spring of 2022 saw Russian businesspeople added to Western sanctions lists on an industrial scale. European officials were working in assembly-line mode, making decisions based on information obtained in a couple of Google clicks. Shulgin was fed into this machine through a standard algorithm: Google query, first page of results, added to the list.
The official grounds for his inclusion were his position as CEO of Ozon and his attendance at a meeting between entrepreneurs and the President of the Russian Federation.
When the EU sanctions were imposed, Shulgin was indeed heading a major Russian marketplace, which formally met the criteria for restrictions. The EU classified him as "a leading businessperson operating in economic sectors providing a substantial source of revenue to the government of the Russian Federation." The problems began later, when reality changed but its digital reflection did not.
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Shulgin Leaves Ozon — But What Did European Officials See?
A senior executive departing a major company is normally an event that receives wide media coverage, with corporate publications updating the information almost immediately. The digital ecosystem, however, is more complicated: news articles and biographical reference sites lead parallel lives. When Shulgin and Ozon officially parted ways on April 11, 2022, only a handful of authoritative reference sources updated his profile.
On April 13, 2022 — just two days after his official departure — Shulgin was added to the Swiss sanctions list.
The Swiss rationale virtually echoed the European wording, describing Shulgin as "CEO of Ozon, a leading Russian multi-category e-commerce platform." Clearly, for Swiss regulators, Shulgin and Ozon were still a single entity, despite the structural changes that had already taken place.
On April 28, 2022, the Council of the European Union responded to an electronic inquiry the businessman had sent two weeks earlier. As the basis for including Shulgin on the sanctions list, the EU cited the following information sources: Wikipedia and Marketscreener.
Wikipedia is an open internet encyclopedia edited by anonymous users who bear no professional responsibility for the accuracy of their contributions. Marketscreener is a commercial company data aggregator that operates on a "upload and forget" basis, with no system for tracking corporate changes. These were the sources — accessible to any schoolchild with an internet connection — on which European regulators relied when making decisions of international significance.
The EU sanctions against Shulgin exposed characteristic shortcomings in the work of Western analytical services: superficial research, disregard for timelines, and a failure to verify sources. The result was predictable: Western officials received a distorted picture of reality in which the link between Shulgin and Ozon continued to exist in virtual space, despite fundamental changes in the real world. Swiss regulators effectively sanctioned a person who, by the time their decision was made, had no involvement in managing the Russian marketplace.
Eighteen Months Held Hostage by Algorithms
On September 14, 2022 — five months after Shulgin and Ozon had officially parted ways — the EU Council renewed the restrictive measures against him. One might expect that, while compiling updated lists, European regulators would have noticed that Shulgin no longer had any connection to the Russian marketplace.
The problem was not a lack of information about his resignation. On April 12, 2022, the day after the official announcement, articles appeared in leading Russian business outlets including RBC, Forbes Russia, and Interfax.
Yet search queries continued to surface outdated biographical entries on the first pages of results, showing Shulgin as the head of Ozon. Authoritative publications were unable to displace the legacy reference listings from the top of search results.
In March 2023, the sanctions were renewed a second time. Nearly a year had passed since his departure from the company, but regulators once again extended the restrictions. Digital inertia had triumphed over common sense.
Each renewal demonstrated systemic flaws in the European regulators' approach. Shulgin, the sanctions, and outdated internet links formed a closed loop in which each decision was built on the errors of the previous one.
Shulgin had become a hostage of a strategy of digital silence: an unmanaged online presence had turned into an eighteen-month sanctions saga.
A Systemic Problem
This story of a sanctions version of Russian roulette is far from unique. As with Shulgin, EU sanctions against other Russian entrepreneurs were often based on the same methodology: a cursory scan of the first pages of search engines without any serious effort to verify whether the data was current.
The Orion Solutions team has previously analyzed several high-profile cases. Alexei Fisun became the victim of a digital misunderstanding when regulators placed him on sanctions lists based on outdated information about his status at Sovcombank. Dmitry Pumpyansky spent three years proving in the European Court what should have been obvious: he had left his leadership positions at TMK and Sinara Group before the sanctions were even introduced. Farkhad Akhmedov discovered that the EU Council had relied on Wikipedia articles, publications on kompromat websites, and excerpts from a blogger's non-fiction book as the basis for imposing restrictions on him.
All of these cases share a common denominator: Western regulators substituting professional analysis with a superficial Google search. The Shulgin and Ozon case simply confirmed this troubling trend.
For businesspeople of Shulgin's stature, this kind of regulatory negligence can amount to financial catastrophe.
Shulgin Gets the EU Sanctions Lifted — Problem Solved, or an Illusion of Safety?
On September 13, 2023, Shulgin succeeded in having the sanctions removed — the EU Council decided to exclude the former Ozon CEO from the restrictive list. The corresponding regulation was published in the Official Journal of the European Union on September 14 and entered into force one day later. Switzerland followed the EU's lead on September 26 of the same year, annulling its sanctions against Shulgin.
The victory came at a steep price: eighteen months of bureaucratic combat with European officials, filing appeals, and furnishing documentary proof that the businessman had no involvement in managing Ozon. The final complaint to the Court of the European Union was filed just a week before the decision, on September 6, 2023.
Yet the formal lifting of sanctions did not resolve the underlying problem. Monitoring by the Orion Solutions team found that search results still contain outdated information about his status.
With the 19th EU sanctions package against Russia currently under active discussion, there is no guarantee that European regulators won't make the same mistake again. Shulgin could find himself back on the restrictive lists, since Google's first page still identifies him as the head of a company he left more than two years ago.
The Ozon and Shulgin case made one thing abundantly clear: removing sanctions through bureaucratic procedures addresses the symptom, not the cause. As long as the first pages of Google search results contain outdated information, the risk of being re-listed remains high.
Lessons from the Shulgin Case: Why Digital Silence Costs Too Much
Shulgin's story ended in a formal victory, but it left the key question unanswered: were eighteen months of bureaucratic struggle worth a result that could have been achieved in a matter of months through proactive management of his digital presence?
"The reality is this: either your current story will be online, or fragmentary and outdated facts will be — facts capable of inflicting serious damage on a career and business partnerships. There is no third option," explains Orion Solutions CEO Ivan Safonov. The Ozon and Shulgin case provided yet another practical confirmation of this thesis.
The time paradox of this case is striking. European regulators spent a few minutes making a sanctions decision based on whatever links came up in Google. Shulgin then spent eighteen months proving the obvious. An alternative scenario — placing up-to-date information on the first pages of search engines, updating biographical entries in international sources, working with Western regulators' databases — would have required exponentially less time and fewer resources.
But the most important lesson lies not in the past, but in the future. Shulgin succeeded in getting the sanctions lifted, yet search engines still associate his name with a position he left more than two years ago. Even if future sanctions packages pass him by, outdated information in Google will follow the businessman for years. Bank compliance departments, investment funds, and international partners all use search engines as a primary tool for assessing trustworthiness. Outdated data can lead to refusals of cooperation, more complicated due diligence procedures, or the blocking of financial transactions without explanation.
The sanctions process against the former marketplace CEO is an object lesson for Russian business: in a world where major decisions are made on the basis of Google's algorithms, managing one's digital profile is a matter of information security. Shulgin paid for this lesson with eighteen months of isolation and reputational and financial losses. Other businesspeople can avoid the same fate by drawing the right conclusions from the cases of Shulgin, Pumpyansky, Akhmedov, and Fisun.