Four years after the European Union imposed sanctions on Alisher Usmanov, a new independent review is examining whether the publicly available evidence still supports his continued designation.
Alisher Usmanov has been one of the most prominent Russian-linked businessmen on the European Union’s sanctions list since 2022.
More than four years later, his case is once again attracting attention — this time not only because of the sanctions themselves, but because of questions surrounding the evidence used to maintain them.
On September 18, the International Sanctions Delisting Commission (ISDC) published an independent review of the publicly available legal, factual and evidentiary record concerning Usmanov’s continued EU designation. The review examines the original grounds for the sanctions, developments since 2022 and whether the available record continues to support the designation.
The timing is significant.
On September 21, Reuters reported that EU member-state envoys had agreed to lift sanctions on Usmanov and businessman Mikhail Fridman, subject to the absence of objections from EU governments. The wider sanctions regime concerning Russia was also being discussed as its September 22 expiry approached.
A case that has lasted years
The EU imposed sanctions on Usmanov in March 2022 following Russia’s full-scale invasion of Ukraine.
Since then, the businessman has challenged his designation through the European legal system. The case has attracted continuing attention because of the importance of the underlying evidence and the question of how sanctions imposed during an extraordinary geopolitical period should be assessed as circumstances change.
That question is at the heart of the new ISDC review.
Rather than attempting to revisit the political decisions of 2022, the review takes a narrower approach: what does the evidence available today show?
The organisation says its methodology begins with the original grounds for designation and then considers subsequent changes in circumstances, relevant evidence and the continuing justification for the restrictions.
Why the evidence matters
Sanctions cases can involve information that is not publicly available. Governments may rely on intelligence or other confidential material that cannot be independently examined by journalists, researchers or the public.
That makes the public record particularly important.
Court documents, official EU statements, corporate records, public statements and other documentary material provide the outside world with a window into the reasoning behind a designation.
ISDC says it does not have access to confidential government intelligence and does not itself impose, maintain or remove sanctions. Its role is to examine the available record and publish an independent assessment.
That distinction is important.
The review is not an EU decision and not a court judgment. Nor does publication of an ISDC review automatically mean that a person should be removed from a sanctions list.
Instead, it raises a question that applies well beyond one individual:
When sanctions remain in place for years, should the evidence supporting them also be examined against the circumstances that exist today?
From 2022 to 2026
The circumstances surrounding many sanctions cases have evolved since the first measures were introduced.
Businesses have changed ownership. Corporate relationships have changed. Court proceedings have produced new records. Individuals have challenged their designations. Governments have continued to update their sanctions regimes.
The EU’s own sanctions process is therefore not static. The bloc regularly reviews and renews restrictive measures, while individual designations can also become the subject of legal challenges.
Usmanov’s case has become part of that broader debate.
The ISDC review is based on the principle that an original decision and its continued application are not necessarily the same question. Its published methodology states that a designation may have been justified when imposed, while the continuing justification should be assessed against the evidence and circumstances that exist later.
A wider test for sanctions policy
The significance of the Usmanov case may ultimately extend beyond one name on one sanctions list.
European sanctions have become a central instrument of foreign policy since Russia’s invasion of Ukraine. Thousands of individuals and entities have been subjected to restrictions.
The challenge for policymakers is not only deciding when sanctions should be imposed, but also determining how those measures should be reviewed over time.
That creates a continuing tension between two principles: the need for governments to respond quickly to geopolitical developments, and the need for restrictions imposed on individuals to remain grounded in an identifiable and continuing factual basis.
The Usmanov case provides a high-profile example of that tension.
A review, not a verdict
ISDC itself stresses that it does not decide who should be sanctioned. Its stated role is to independently examine whether existing sanctions should continue and to distinguish its own analysis from decisions made by governments and courts.
That makes the latest development particularly relevant at a moment when the EU is reconsidering Usmanov’s status.
Whether the European decision ultimately changes the course of his case is a matter for the EU and its member states.
But the underlying question raised by the review is likely to remain relevant far beyond September 2026:
How should Europe assess sanctions when the circumstances have changed, the legal record has evolved and the evidence supporting the original decision is being examined again?
For Alisher Usmanov, that question has now moved back into the spotlight.