Court of Justice confirms freezing of funds of five Russian businesspersons
Summary
The Court of Justice of the European Union has dismissed appeals from five Russian businesspersons challenging the freezing of their funds. The Court clarified that sanctions target economic sectors providing substantial revenue to the Russian government, and that the influence of businesspersons is assessed in light of their economic importance.
What changed
The Court of Justice of the European Union, in its judgment on joined cases C-696/23 P to C-111/24 P, has upheld the freezing of funds belonging to five Russian businesspersons: Dmitry Pumpyanskiy, Tigran Khudaverdyan, Viktor Rashnikov, Dmitry Mazepin, and German Khan. The Court clarified that the EU's restrictive measures are aimed at economic sectors that provide substantial revenue to the Russian government, rather than solely focusing on the individuals involved. It also established that the 'influence' of these businesspersons should be assessed within the economic context, confirming an objective link between their involvement in lucrative sectors and the EU's objective of increasing pressure on Russia and the costs of its destabilizing actions in Ukraine.
This ruling has significant implications for individuals and entities subject to EU sanctions, reinforcing the legal basis for asset freezes based on economic sector contributions to sanctioned governments. Regulated entities, particularly within the financial services sector, should ensure their compliance programs adequately address the criteria for identifying and freezing assets linked to sanctioned economic sectors and individuals. While the Court confirmed the proportionality and legality of the measures, the judgment underscores the importance of robust due diligence and adherence to sanctions lists. No specific compliance deadline is mentioned, as this is a judicial confirmation of existing measures.
What to do next
- Review internal policies and procedures for compliance with EU sanctions against Russian businesspersons and economic sectors.
- Ensure due diligence processes adequately identify individuals and entities linked to sanctioned economic sectors.
- Consult legal counsel regarding any specific assets or transactions potentially affected by these sanctions.
Source document (simplified)
PRESS RELEASE No 48/26
Luxembourg, 26 March 2026
Judgment of the Court in Joined Cases C-696/23 P | Pumpyanskiy v Council, C-704/23 P | Khudaverdyan v Council, C-711/23 P | Rashnikov v Council, C-35/24 P | Mazepin v Council and C-111/24 P | Khan v Council
War in Ukraine: the Court of Justice confirms the freezing of the funds of five leading businesspersons operating in Russia
Since the start of Russia’s war against Ukraine in February 2022, the Council of the European Union has adopted restrictive
measures against leading businesspersons involved in economic sectors providing a substantial source of revenue to the 1 Russian Government. In that context, Mr Dmitry Alexandrovich Pumpyanskiy, Mr Tigran Khudaverdyan, Mr Viktor Filippovich Rashnikov, Mr Dmitry Arkadievich Mazepin and Mr German Khan, who have been subject to restrictive measures, brought proceedings before the General Court of the European Union. Their actions having been dismissed by the General Court in 2023, they lodged appeals before the Court of Justice. 2 In its judgment delivered today, the Court of Justice dismisses all the appeals. First of all, it clarifies that it is the ‘economic sectors’, rather than the leading businesspersons involved in those sectors, that must provide a substantial source of revenue to the Russian Government.
It also clarifies that the concept of the ‘influence’ of the businesspersons must be understood in the light of the economic
context in which they operate, irrespective of any link that they may have with the Russian Government. It is indeed because they are of significant importance for the Russian economy that those persons are likely to further, indirectly, the financing of destabilising actions against Ukraine, by contributing to maintaining the profitability, or the prosperity, of the economic sectors in which they are involved. Next, the Court recalls that the legality of a criterion serving as the basis for the imposition of restrictive measures can be affected only if that criterion is manifestly inappropriate. Such a criterion cannot be regarded as unlawful provided that it targets categories of persons that have, albeit indirectly and albeit independently of any personal conduct, an objective link with the third country against which the European Union is seeking to impose sanctions. In the present cases, the Court finds that there is an objective link between, on the one hand, important businesspersons involved in sectors that are lucrative for Russia and, on the other, the objective consisting in increasing the pressure exerted on that country and the costs of its actions to destabilise Ukraine. Last, the Court confirms that, in order to determine whether the restrictive measures are proportionate, it is necessary only to verify that they are not manifestly inappropriate for achieving the legitimate objective pursued and that they do not manifestly exceed what is necessary to achieve that objective. Both those requirements are satisfied here. NOTE: An appeal, on a point or points of law only, may be brought before the Court of Justice against a judgment or order of the General Court. In principle, the appeal does not have suspensive effect. If the appeal is admissible and well founded, the Court of Justice sets aside the judgment of the General Court. Where the state of the proceedings so permits,
Communications Directorate Press and Information Unit curia.europa.eu
the Court of Justice may itself give final judgment in the case. Otherwise, it refers the case back to the General Court, which is bound by the decision given by the Court of Justice on the appeal.
Unofficial document for media use, not binding on the Court of Justice. The full text and, as the case may be, an abstract of the judgment is published on the CURIA website on the day of delivery. Press contact: Jacques René Zammit ✆ (+352) 4303 3355. Images of the delivery of the judgment are available on 'Europe by Satellite' ✆ (+32) 2 2964106.
Council Decision 2014/145/CFSP of 17 March 2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, 1 sovereignty and independence of Ukraine, as amended by Council Decision (CFSP) 2022/329 of 25 February 2022. Judgments of 6 September 2023, Pumpyanskiy v Council, T-270/22 (see also Press Release No 132/23) and Khudaverdyan v Council, T-335/22; of 2 13 September 2023, Rashnikov v Council, T-305/22; of 8 November 2023, Mazepin v Council, T-282/22 (see also Press Release No 166/23); and of 29 November 2023, Khan v Council, T-333/22.
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