EU DROPS ALISHER USMANOV FROM SANCTIONS LIST AFTER FOUR YEARS OF LEGAL BATTLES

The EU has removed Alisher Usmanov from its sanctions list. An independent review published days earlier examined whether the evidentiary record still supported his designation.

For more than four years, Alisher Usmanov’s name has been one of the most prominent on the European Union’s Russia-related sanctions list.

That changed on 22 September.

The Council of the European Union formally deleted Alisher Burkhanovich Usmanov from the relevant EU sanctions list, alongside businessman Mikhail Fridman.

The decision closes the current EU sanctions designation against Usmanov.

But it does not erase the complicated legal history behind the case.

That history includes multiple EU Court proceedings, challenges over the evidence relied upon by the Council, different legal grounds for maintaining the designation and, ultimately, a political and legal decision by the EU to remove his name.

Just four days before the delisting, the International Sanctions Delisting Commission (ISDC) published its independent review of the Usmanov case.

The review had been completed on 15 September 2026 and published on 18 September.

The timing is notable. But the two developments should not be confused: the ISDC does not impose, maintain or remove sanctions, and its review does not claim to have caused the EU’s decision.

FROM DESIGNATION TO DELISTING

Usmanov was designated by the EU in February 2022, shortly after Russia’s full-scale invasion of Ukraine.

The Council’s original statement of reasons referred to his business interests, his position within major Russian companies, alleged relationships with senior Russian political figures and the Council’s assessment of his connections with the Russian authorities.

The Council characterised Usmanov as a prominent businessman with particularly close ties to Vladimir Putin and relied on a number of allegations concerning his business and political relationships.

Those were the Council’s reasons for designation.

They should not, however, be confused with findings made by a court.

That distinction became increasingly important as the case moved through the European judicial system.

THE FIRST COURT BATTLE

The first major judicial challenge was Case T-237/22, Usmanov v Council.

The General Court delivered its judgment on 7 February 2024.

The case concerned, among other matters, the legal criterion relating to persons supporting actions or policies undermining or threatening the territorial integrity, sovereignty and independence of Ukraine.

The Court examined the Council’s reasoning and the evidence relied upon in support of the designation, as well as arguments concerning procedural rights and fundamental rights.

The General Court did not annul the designation in that case.

The action was dismissed in the relevant respects.

Usmanov subsequently appealed to the Court of Justice in Case C-274/24 P.

That appeal remains a separate part of the judicial history of the case.

The significance is important: the first General Court judgment cannot accurately be described either as a declaration that the sanctions were unlawful or as a final ruling on every subsequent EU measure concerning Usmanov.

THE LEGAL BASIS LATER CHANGED

The Usmanov case subsequently involved a different sanctions criterion.

In Case T-1117/23, the General Court examined measures maintaining Usmanov’s designation under the criterion concerning a businessperson involved in economic sectors providing a substantial source of revenue to the Government of the Russian Federation.

The General Court delivered its judgment on 3 September 2025.

It dismissed Usmanov’s action.

The case addressed a different legal basis from the original proceedings and considered issues including the Council’s reasoning, alleged errors of assessment, proportionality and fundamental rights.

That distinction matters.

EU sanctions cases can evolve over time. A later Council decision may rely on a different legal criterion, a different period or a different evidentiary record.

A judgment concerning one designation therefore cannot automatically be treated as a judgment concerning every later designation.

THE APPEAL THAT WAS WITHDRAWN

Usmanov appealed the T-1117/23 judgment to the Court of Justice in C-725/25 P.

But the Court of Justice did not ultimately rule on the merits of that appeal.

On 17 June 2026, Usmanov informed the Court that he was discontinuing the proceedings.

On 8 July 2026, the President of the Court ordered that C-725/25 P be removed from the register and ordered Usmanov to pay the costs.

The case therefore ended procedurally without a substantive Court of Justice judgment on the merits of the appeal.

The separate appeal in C-274/24 P, concerning the earlier T-237/22 judgment, is a distinct proceeding.

THEN CAME 22 SEPTEMBER

Against this complicated judicial background, the EU took a separate institutional decision.

On 22 September 2026, the Council adopted Decision (CFSP) 2026/2161.

The decision expressly deleted the entry:

from the relevant annex to the EU’s Russia-related restrictive-measures regime.

Mikhail Fridman’s entry was deleted in the same decision.

The immediate legal consequence is clear:

This is a formal legal act of the Council, not simply a media report.

FOUR DAYS EARLIER, ISDC HAD PUBLISHED ITS REVIEW

The timing adds an unusual dimension to the story.

On 15 September 2026, the International Sanctions Delisting Commission completed its independent review of the Usmanov case.

The assessment was published on 18 September under the title:

The review examined the publicly available legal, factual and evidentiary record surrounding the designation and its subsequent development.

The ISDC approach is deliberately different from political commentary.

Its published Review Standards state that a sanctions review should begin with the question:

rather than with a predetermined objective of obtaining delisting.

The organisation also states that its role is not to impose, maintain or remove sanctions.

Its function is to conduct an independent assessment of the available record.

WHAT WAS THE ISDC LOOKING AT?

The Usmanov review focused on several questions.

These questions are important because sanctions designations are not frozen in time.

Evidence can change.

Corporate circumstances can change.

Legal interpretations can develop.

Court proceedings can clarify the meaning of a designation criterion.

And the competent authority can ultimately decide that a designation should no longer continue.

ASSOCIATION IS NOT THE SAME AS A LEGAL CRITERION

The Usmanov case also raises a broader question about how individual sanctions evidence should be assessed.

Corporate ownership is evidence.

A business relationship is evidence.

A political relationship may be evidence.

Activity in a particular economic sector may be evidence.

But none of these facts automatically establishes every possible legal criterion for designation.

The relevant question is whether the evidence, considered in its proper context, establishes the specific legal ground on which a designation is based.

That distinction is particularly important when a designation continues over several years and the legal basis for later measures differs from the original grounds.

The Usmanov litigation demonstrates why the entire record needs to be examined rather than reduced to a single allegation, court decision or political statement.

WHAT THE DELISTING DOES — AND DOES NOT — MEAN

The Council’s decision of 22 September changes Usmanov’s current EU sanctions status.

It does not, by itself, constitute a judicial declaration that every allegation made in the original 2022 designation was false.

Nor does it mean that the General Court found the original designation unlawful in T-237/22.

The judicial record does not support either simplified conclusion.

What can be stated with certainty is more limited — and more important:

The previous court proceedings remain part of the historical legal record.

The Council’s original reasons remain part of that record.

The subsequent judgments remain part of that record.

And the September 2026 delisting is now the latest official development.

WHY THIS CASE MATTERS

The Usmanov case illustrates a difficult feature of modern sanctions policy.

A designation can begin as a political decision.

It can then become the subject of judicial review.

The evidence can be challenged.

The applicable legal criteria can evolve.

New designation decisions can be adopted.

And, eventually, the competent authority can remove the individual from the list.

That means the question of why someone was designated is not necessarily the same as the question of why they remain designated years later.

For individual sanctions regimes, that distinction can be critical.

THE ISDC POSITION

The ISDC does not claim that its review caused the European Union’s decision.

There is no basis to establish such causation, and the two processes should remain separate.

The significance of the ISDC review is instead that it provides an independent assessment of the record immediately before the EU’s decision.

The Commission’s stated institutional principle is:

That principle is particularly relevant in a case such as Usmanov’s, where the evidentiary and judicial record has developed substantially since the original designation.

A FOUR-YEAR CASE REACHES A NEW STAGE

The headline is simple:

The legal history is not.

It runs from the original February 2022 designation through T-237/22, the subsequent C-274/24 P appeal, the later T-1117/23 proceedings, the withdrawal of C-725/25 P, and finally the Council’s formal decision of 22 September 2026.

The ISDC review adds another layer to that record.

It was completed on 15 September and published on 18 September — before the Council formally removed Usmanov from the list.

The sequence does not establish that one caused the other.

But it does provide a clear chronology:

The current EU designation has ended.

The historical record remains.

And for the first time since the original designation, the full trajectory of the case can be examined not simply as a sanctions story, but as a case study in evidence, judicial review, changing circumstances and delisting.

CURRENT STATUS