Sanctions 2025

FRANCE Law and Practice Contributed by: William Julié, Amélie Beauchemin, Camille Gosson and Elena Moreno, WJ Avocats

• On 25 February 2022, the day after President Putin announced a military operation against Ukraine, the Council of the EU issued Council Decision (CFSP) 2022/329 amending Decision 2014/145/ CFSP concerning restrictive measures in respect of actions undermining or threatening the territo - rial integrity, sovereignty and independence of Ukraine, providing for travel bans and freezing of assets of targeted persons, and Council Decision (CFSP) 2022/331 listing 98 individuals who alleg - edly supported the Russian government’s decision to invade Ukraine, opening the door to what would be an unprecedentedly large sanctions regime targeting thousands of natural and legal persons under a dozen different – and largely encompass - ing – listing criteria. • The first order from the President of the Gen - eral Court of the CJEU suspended the sanctions decided against Mr Nikita Mazepin, on 1 March 2023, which is significant as it was the first time the Court has granted an interim measure request in a sanctions case. • Directive (EU) 2024/1226, adopted in April 2024, criminalised violation and circumvention of sanc - tions at the EU level, showing the importance of restrictive measures for the EU; this is significant as it usually leaves criminal law and procedural matters for the member states to decide. • At the national level, as explained in the foregoing, relevant recent case law includes the Lafarge trial, the Baltic Leader case and the Arcom decision concerning Eutelsat. In a decision dated 23 May 2025, the Paris Adminis - trative Court of Appeal rejected an appeal challenging a judgment of the Paris Administrative Court, which had upheld a decision by the French Treasury denying The 17th package of sanctions was adopted on 20 May 2025, strengthening enforcement and anti-cir - cumvention measures. On 12 June 2025, the European Commission pro - posed its 18th package of “hard-biting sanctions”, according to Commission President von der Leyen, a request to unfreeze assets. 3.2 Future Developments

targeting Moscow’s energy and banking sectors as well as its military industry. In addition to new listings, this sanctions package, adopted on 18 July 2925, includes banning transac - tions with Russia’s Nord Stream gas pipelines, as well as banks that engage in sanctions circumvention. It also restricts the export of dual-use goods and tech - nologies that are used for producing drones, missiles, and other weapon systems. Additional sanctions packages are expected to be released in the upcoming months – as they have been regularly for the past three years. On the judicial side, challenges of listings have started to reach the stage of examination of appeals by the CJEU, which will likely produce important case law more precisely defining the framework of sanctions against Russia and Belarus. 4. Delisting Challenges 4.1 Process The delisting process varies depending on the source of the sanction: • when the sanction has been decided at the nation - al level by the French Ministry of Economy and Finance, the sanctioned person can apply directly to the Ministry to reconsider its decision, and in case of refusal, apply to the French administrative court with a recours pour excès de pouvoir • when sanctioned by the Council of the EU, the affected person can challenge their listing both before the Council itself, by a simple letter, and/ or before the General Court of the CJEU, with an application for annulment of the listing; and • when listed on UN sanctions lists, the affected person would have to make an application to the Focal Point for Delisting, except for sanctions imposed on ISIL/Al-Qaeda, for which the Ombud - sperson is the competent authority. 4.2 Remedies Concerning French sanctions, the procedures of recours gracieux and recours pour excès de pouvoir

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