I don't believe that is the case, because IIRC Russia's id is banned via hardcode.
This FM23 mod, for example, had to transfer everything from Russia to the Soviet Union in order to put them back into UEFA Continentals: https://steamcommunity.com/sharedfiles/filedetails/?id=2886950813
Though it's not impossible that someone in the SI Russia wanted to double-ban Russia, or something.
I don't believe it's the UCL changes either, because I don't think this problem existed in FM21 with the start of the ECL?