The Man: Roman Viktorovich Trotsenko

Confirmed - Sanctions Registries

Roman Viktorovich Trotsenko, born 1970 in Moscow, Russian Tax ID 771500884353, is the founder and beneficial owner of AEON Corporation -- a conglomerate with holdings across shipping, mining, real estate, and infrastructure. He serves as adviser to Igor Sechin, president of Rosneft and widely regarded as the second most powerful man in Russia after Vladimir Putin.

The Sanctions Map: Eight Jurisdictions

Confirmed - Government Sanctions Lists

JurisdictionStatusBasis
United States (OFAC)SanctionedAssociation with Russian government/Sechin
United KingdomSanctionedAssociation with Russian government
European UnionSanctionedSupporting/benefiting from Russian government
CanadaSanctionedRussian oligarch designation
SwitzerlandSanctionedAligned with EU sanctions
BelgiumSanctionedAligned with EU sanctions
UkraineSanctionedSupporting Russian aggression
United NationsSanctionedInternational consensus designation

The Family: All Sanctioned

Confirmed - Sanctions Registries

Family MemberRelationshipSanctions Status
Roman Viktorovich TrotsenkoPrincipalSanctioned (US, UK, EU, CA, CH, BE, UA, UN)
Gleb TrotsenkoSonSanctioned
Nikita TrotsenkoSonSanctioned
Sofja TrotsenkoWife/DaughterSanctioned
Svetlana YershovaAEON VP since 2012NOT sanctioned

The Transfer: Seven Days Before Sanctions

Confirmed - Corporate Registry Critical Finding

On October 27, 2023, all shares of Zangezur Copper-Molybdenum Combine (ZCMC) -- Armenia's single most valuable industrial asset -- were transferred to Svetlana Yershova. Seven days later, new sanctions designations were announced.

She is not a stranger. She is a long-term corporate insider receiving the crown jewel of a sanctioned oligarch's mining portfolio one week before the hammer falls.

ZCMC: What Was Transferred

Confirmed - Financial Records

Full financial details in Investigation #18.

The Digital Trail: AEON Mining Suspended

Confirmed - DNS Records

AEON Mining operated the domain aeonmining.com. That domain is now in clientHold status -- suspended by the registrar. The website is gone. The mine is not.

Vodohod: The Security Breach

Confirmed - Breach Data

Account: nk@vodohod.ru
Password: 123456

The same password from Investigation #1.

GeoProMining: Website in Croatia

Confirmed - DNS Records Pattern Analysis

GeoProMining maintains a website resolving to infrastructure in Croatia -- not Russia, not Armenia. EU member state hosting for a sanctioned oligarch's mining operation.

The Evasion Architecture

Pattern Analysis

LayerEntity/PersonFunctionSanctions Status
Beneficial OwnerRoman TrotsenkoUltimate controller of AEON/GeoProMiningSanctioned (8 jurisdictions)
FamilyGleb, Nikita, Sofja TrotsenkoBlocked from holding assetsAll sanctioned
Nominee HolderSvetlana YershovaReceived ZCMC shares Oct 27, 2023NOT sanctioned
Operating EntityGeoProMiningOperates ZCMC mine in ArmeniaWebsite in Croatia
Corporate ParentAEON CorporationTrotsenko conglomerateMining domain suspended
Financial ConduitZCMC$300M+ annual revenueOperating in Armenia

Armenia's Role

The Armenian government either knew and allowed the transfer (complicity), did not know (regulatory failure), or knew and reported it (no public evidence). None reflect well on governance.

When a sanctioned oligarch's mining shares are transferred to his corporate VP seven days before new designations, and every government pretends not to notice, sanctions are not a policy. They are theater.

Methodology

Based on international sanctions registries (OFAC, UK, EU, Canadian, Swiss, Belgian, Ukrainian, UN), Armenian corporate registry filings, DNS records, publicly available breach databases, and open-source intelligence. No systems were accessed, penetrated, or tested.

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