Sanctions 2026

EU Law and Practice Contributed by: Edward Borovikov, Laurens Engelen, Xiaoyi Tang and Semen Medvedkov, Dentons

not suffice to substantiate that Mr Chevtsov support - ed the Belarusian regime. Moreover, the Court found that his alleged involvement in Reshenie Bank and, indirectly, in the Dudutki museum complex, and his alleged benefiting from the Belarusian State budget, was also insufficiently substantiated. In Ignatova v Council (Case T 601/24, June 2026), the General Court held that an “immediate family mem - ber” is any person with family ties to a leading busi - nessperson of such a degree that they could be used to disperse that businessperson’s assets to evade sanctions, irrespective of whether the tie is based on blood, adoption or marriage. Thus, the Court held that Anastasia Ignatova, the daughter of the wife of listed businessman Sergei Chemezov, was a sufficiently immediate family member. By contrast, in Abramovich v Council (Case T 313/22), the General Court upheld the listing of Roman Abram - ovich, confirming the existence of a clear and material link with entities supporting the Russian government. The General Court confirmed its finding in Abramovich v Council (Case T 1105/23, October 2025), dismissing Mr Abramovich’s action for annulment of the maintain - ing acts. The Court held that he remained an “influen - tial businessman exercising activities in Russia” and a businessman active in sectors providing substantial revenue to the Russian government, primarily on the basis of his 28.64% shareholding in Evraz – one of Russia’s largest taxpayers. Recently, in Traugott Ickeroth (Case C 67/25, July 2026), the Court of Justice found that the Commis - sion’s Frequently Asked Questions (FAQs) on sanc - tions regulations cannot alter the scope of restrictive measures contained in a regulation or be decisive for the purposes of interpreting such a regulation. Specifically, the Court held that the FAQs had been unduly lenient in narrowing the scope of the concept of “operator” to operators engaged in an activity of an economic nature, whereas Regulation 833/2014 itself imposed no such limitation. Moreover, in Belaruskali and Others v Council (Joined Cases C 816/24 P, C 817/24 P and C 818/24 P, June 2026), the Court of Justice upheld the General Court’s judgments and confirmed the validity of the appel -

lants’ inclusion or maintenance on the EU restrictive measures lists. The Court rejected the argument that the concept of the “Lukashenko regime” was insuf - ficiently clear and precise and therefore contrary to the principle of legal certainty. Additionally, the Court found that the General Court did not err in consider - ing, based on an accumulation of facts, that Bela - ruskali and Mr Golovaty benefited from the Lukashen - ko regime, within the meaning of criterion (b). These decisions underline the courts’ insistence that sanctions listings must rely on verifiable, individual - ised evidence and cannot be maintained based on vague affiliations or outdated assumptions. EU Blocking Statute In the EU, a blocking statute was first adopted by way of Council Regulation (EC) No 2271/96 in response to US sanctions against Iran, Cuba and Libya having extraterritorial effects. This Regulation was updated in August 2018 to shield EU individuals and entities aiming to do business in Iran from legal consequences in the USA resulting from US extraterritorial sanctions. In Case T-8/21, IFIC Holding AG v Commission , the EU General Court confirmed its position regarding the EU Blocking Statute protecting EU companies from complying with US sanctions on Iran. This specific case involved a German company, IFIC, which chal - lenged the Commission’s decision to allow a bank (Clearstream) to withhold their dividend payments due to US sanctions. The General Court ruled in favour of the Commission, finding that: • the Commission does not need to consider the interests of companies on the US sanctions list (such as IFIC); • the Commission does not have to explore less harmful options before granting permission to comply with US sanctions; • companies on the US sanctions list do not have the right to be heard in the authorisation process; and • the authorisation to comply with US sanctions only applies from the date it has been granted, not retroactively.

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