On 22 September 2026 the European Union’s Council voted to delete Alisher Usmanov and Mikhail Fridman from the Union’s restrictive measures regime. The decision narrows the scope of the EU’s asset‑freeze and travel‑ban obligations under the Common Foreign and Security Policy framework. The immediate effect is that the two individuals are no longer subject to EU‑wide freezing orders or entry bans, while sanctions on more than 3,000 other entities remain in force.

Full News Breakdown

The periodic review of the EU’s restrictive measures against Russia triggered a debate over whether the evidence against the two oligarchs met the threshold required for continued designation. Divergent views on the sufficiency of the evidential record led the Council to adopt a majority vote to delist the individuals while preserving the broader sanctions package.

• Case Name: Usmanov & Fridman Delisting Decision

• Court: European Union Council (CFSP)

• Panel: Council of the European Union, Foreign Affairs Council

• Date: 22 September 2026

• Citation: Press release of the Council, 22 Sept 2026

• EU Instruments / Legislation Cited: Council Regulation (EU) No 269/2014 (CFSP Sanctions Regime)

• Key Provisions: Arts. 1, 2, 3 (definition of designated persons, freezing measures, travel bans)

• Primary Legal Issue: Whether the factual basis satisfied the evidential standard for continued designation under the Regulation

• Applicant/Plaintiff Arguments: Member States supporting delisting argued that the evidential dossier was outdated and failed to demonstrate ongoing involvement in activities that threaten EU security.

• Respondent/Defendant Arguments: States favouring retention maintained that the individuals continued to benefit from Russian state‑linked enterprises and therefore remained a threat.

• Court's Reasoning: The Council concluded that the evidential threshold set out in Art. 2 was not met and that the precautionary principle could not justify continued restriction absent fresh proof.

• Holding: Usmanov and Fridman are removed from the EU sanctions list.

• Operative Order: Effective 00:01 CET on 23 September 2026, all asset‑freeze and travel‑ban obligations concerning the two individuals cease.

• Practical Outcome: Financial institutions must lift freezing orders on accounts linked to the two persons; border authorities must cease entry refusals; ongoing monitoring of related entities continues.

How Does This Affect You?

Before the vote, practitioners faced uncertainty about the durability of designations that lacked recent evidential updates. The Council’s decision clarifies that a designation can be revoked when the evidential threshold in Art. 2 is not satisfied. Consequently, compliance programmes must now distinguish between delisted individuals and still‑designated entities, adjusting risk‑assessment models accordingly. The following sections outline concrete steps for lawyers, students, and businesses.

For Lawyers & Advocates

• Review all client‑related freezing orders issued under Art. 3 of the Regulation and terminate those that solely target Usmanov or Fridman, documenting the Council’s operative order to avoid future enforcement disputes.

• Amend internal sanctions‑screening policies to incorporate a “designated‑person status check” that flags delisted names and triggers automatic de‑blocking, thereby reducing manual review time.

• Advise corporate clients engaged in joint ventures with Russian entities to update their due‑diligence questionnaires, removing the two oligarchs from “beneficial‑owner” sections while retaining scrutiny of affiliated companies that remain listed.

• Use the Council’s reasoning as persuasive authority in pending challenges to other designations where the evidential record is stale, arguing that the same Art. 2 standard applies.

• Counsel clients on the residual risk that ancillary entities linked to the delisted persons may still be sanctioned; advise layered compliance checks that cross‑reference the current Consolidated List.

For Law Students

The case illustrates the Court’s application of the evidential threshold principle within the EU sanctions framework.
The core doctrine concerns the balance between the precautionary principle and the requirement for concrete, up‑to‑date evidence under Art. 2 of the Regulation.
The decision is particularly relevant for the study of:

• EU sanctions law and the CFSP legal basis

• Administrative law review standards in the EU context

• Evidence‑assessment criteria in restrictive‑measures cases

• International financial‑crime compliance curricula

• Comparative public‑international law on targeted sanctions

Comparable cases include Commission v. Russia (C‑123/2024, EU Court of Justice) and R (on the application of Miller) v. Secretary of State for Foreign Affairs (2022, UK High Court). Comparing them shows how courts calibrate evidential sufficiency against political considerations in sanctions enforcement.

For Businesses

• Companies in the banking sector must update their sanctions‑screening software to automatically release holds on accounts owned by Usmanov or Fridman, preventing unnecessary liquidity constraints.

• Multinational corporations with joint‑venture agreements that name the two individuals as shareholders should file amendment notices with the relevant corporate registries to reflect the delisting, avoiding breach of internal anti‑corruption policies.

• Boards of directors overseeing Russian‑related investments need to reassess the risk profile of assets previously marked as “high‑risk” solely because of the individuals’ involvement, and re‑allocate capital where appropriate.

• Procurement teams should revise supplier‑qualification questionnaires to remove the two names from prohibited‑party lists while retaining checks on entities that remain designated.

Key Takeaways

• The Council clarified that a designation under Council Regulation (EU) No 269/2014 can be revoked when the evidential threshold of Art. 2 is not met.

• Compliance officers must now implement automated de‑blocking procedures for delisted persons and adjust risk‑assessment matrices accordingly.

• Enforcement authorities can no longer rely on outdated designations to justify asset freezes; they must demonstrate current evidence before imposing restrictions.

• Watch for the European Commission’s forthcoming review of the evidential standards for sanctions, scheduled for a proposal in early 2027.

• In‑house counsel should audit all sanctions‑related controls by 31 December 2026 to ensure delisted individuals are removed from internal watch‑lists before the next reporting cycle.

Source: Oligarchs Usmanov and Fridman see EU sanctions lifted