Four years after his original designation, Sanctions Review examines whether the public record still supports continued EU sanctions
By Headline Business
20 September 2026
Alisher Usmanov, whose fortune is estimated by Forbes at approximately $14 billion, has become the focus of a new independent review examining the evidence behind his European Union sanctions designation.
The timing is significant. EU governments are currently debating the renewal of individual Russia-related sanctions, with the deadline for the latest discussions extended to 22 September 2026. Reuters reported that France and Slovakia have pushed for changes concerning Usmanov’s listing. (Reuters)
At the centre of the debate is a simple question:
Does the evidence supporting Usmanov’s designation in 2026 remain sufficiently reliable, specific and current?
That is the question examined by Sanctions Review, through the International Sanctions Delisting Commission (ISDC) and its review ISDC-2026-001.
FROM 2022 TO 2026: THE EVIDENCE HAS CHANGED
Usmanov was designated by the EU on 28 February 2022.
The EU’s reasoning included allegations concerning his relationship with Vladimir Putin, his alleged support for Russian government policies and his position as a leading businessperson operating in economically significant sectors.
But Sanctions Review argues that these are not one single factual proposition.
Whether Usmanov was a major shareholder in Russian businesses is one question.
Whether he personally acted on behalf of the Russian president in particular transactions is another.
Whether media reports used to support particular allegations remain reliable after subsequent judicial proceedings is yet another.
The review therefore examines the individual propositions separately rather than treating the original sanctions narrative as a single package.
THE COURTS — AND WHAT THEY DID NOT DECIDE
The European courts have already considered Usmanov’s challenges to EU restrictive measures.
In T-1117/23, the General Court dismissed his action on 3 September 2025, finding sufficient grounds for the relevant maintaining measures under the applicable economic-sector criterion. (InfoCuria)
Sanctions Review does not dispute the existence of that judgment.
Instead, it highlights an important distinction: a finding that an independent legal ground was sufficient to maintain a measure does not necessarily establish the truth of every separate factual allegation contained in the broader sanctions narrative.
The subsequent appeal, C-725/25 P, was later discontinued by Usmanov and removed from the Court of Justice’s register in July 2026.
A PUBLIC RECORD THAT HAS EVOLVED
The review points to developments that have occurred since the original designation, including European court proceedings, German judicial decisions, changes in official EU wording, developments concerning assets and corporate interests, and discontinued German investigations.
One particularly important area concerns media allegations about Usmanov’s alleged role as an intermediary for Putin.
German courts subsequently considered proceedings involving some of the reporting underlying such allegations.
Sanctions Review does not suggest that a German press-law judgment determines the legality of EU sanctions.
Its point is narrower: where factual allegations have subsequently been challenged or affected by judicial findings, those developments should form part of the evidence considered in a continuing sanctions assessment.
THE €10 MILLION GERMAN PROCEEDING
The review also considers the subsequent termination of a German investigation concerning alleged foreign-trade-law violations following a €10 million payment.
Reuters reported that Usmanov denied wrongdoing and that his lawyers said the payment was not an admission of guilt. (Reuters)
The review distinguishes this type of procedural outcome from a criminal conviction and treats it as part of the subsequent record rather than as proof that the original EU designation was wrong.
WHY SANCTIONS REVIEW MATTERS
The significance of the new publication lies in its methodology.
Rather than asking simply whether Usmanov’s original designation was justified in 2022, Sanctions Review asks whether the evidentiary record remains sufficient for continuation in 2026.
That is a materially different question.
The review acknowledges that the EU courts have confirmed certain grounds supporting the relevant maintaining measures.
But it also argues that individual allegations should be tested against the evidence currently available, particularly where subsequent court decisions, corrections, withdrawals or changes in official reasoning have altered the public record.
NOT A CALL FOR AUTOMATIC DELISTING
Sanctions Review does not conclude that Usmanov must automatically be removed from the EU sanctions list.
Instead, its conclusion is that the case warrants a fresh, individualized, evidence-by-evidence assessment.
The review also makes clear that it is based on publicly available information and does not have access to confidential intelligence that may be held by EU institutions or Member States.
That limitation is significant: the public record cannot establish whether additional non-public evidence exists.
A CASE AT A CROSSROADS
The Usmanov case now sits at the intersection of three evolving records: the original 2022 sanctions narrative, the subsequent judicial record and the evidence that has emerged since.
For Sanctions Review, the central question is therefore not simply whether the original designation was justified four years ago.
It is whether the evidence supporting continued designation remains sufficiently reliable, specific and applicable today.
With the EU’s renewal discussions approaching their September deadline, the review provides a consolidated examination of that question — bringing together the legal record, subsequent judicial developments and the changing evidentiary picture in one assessment.
For the full analysis, see Sanctions Review, ISDC Case ISDC-2026-001: Does the Current Evidentiary Record Still Support Continued EU Designation?
Read the full Sanctions Review analysis
View ISDC-2026-001 Case Record
Editorial note: This article reports on the Sanctions Review analysis and publicly available judicial and diplomatic material. It does not independently determine whether Alisher Usmanov’s EU designation should be maintained, modified or removed.