Sanctions 2025

EU Law and Practice Contributed by: Edward Borovikov, Laurens Engelen, Aurore Ancion and Semen Medvedkov, Dentons

CJEU Rulings on Sanctions and Due Process The CJEU is continuously strengthening its position that individuals and entities listed under sanctions must have their rights protected. In practical terms, EU sanctions must adhere to the principles of due process, meaning that individuals and entities tar - geted by sanctions have the right to be informed of the reasons for their listing and have access to effec - tive legal remedies. As an example, in Case T-301/22 Fridman and Aven v Council, two Russian business - men successfully challenged their inclusion on the EU sanctions list. The CJEU found that the Council of the EU had not demonstrated a sufficient connec - tion between the applicants and the destabilisation of Ukraine, underscoring the necessity for a thorough and substantiated evidentiary basis for sanctions list - ings. More recently, in Pumpyanskiy v Council (Case T 221/24, April 2025), the General Court annulled the sanctions listing of Dmitry Pumpyanskiy (in addition to those in respect of his wife (Case T 1108/23) and son (Case T‑221/24)), stressing that the Council failed to reassess the listing in light of the applicant’s resig - nation from roles that originally justified the designa - tion. This judgment reaffirms the Council’s obligation to base listings on up-to-date, individualised assess - ments. In Kozitsyn v Council (Joined Cases T 607/22 and T 731/22), the General Court annulled the September 2022 sanctions listing against Andrey Kozitsyn, high - lighting the Council’s failure to adequately reassess his situation after his resignation from UMMC. However, the court upheld sanctions listing against Mr Kozitsyn from March 2023 onwards, recognising his continued influence in sectors that generate significant revenue for the Russian government. This mirrors the Ezubov case of September 2024 (T-741/22), where the court found insufficient evidence under the amended criterion of being a “leading busi - nessperson” to support the September 2023 sanc - tions listing. In that case, the General Court partially annulled restrictive measures against Pavel Ezubov, emphasising the need for sanctions listings to be based on current and individualised assessments. However, the court upheld the September 2022 and

in transactions with sanctioned entities must comply with reporting requirements. To Whom Reports Must Be Made Reports must generally be made to the national com - petent authorities of each EU member state, which are typically the financial regulatory bodies or ministries of finance. Such national competent authorities will usually themselves report this information within the European Commission. Reporting Circumstances Entities must report the freezing of funds or economic resources belonging to sanctioned individuals or enti - ties. Legal professionals must ensure their services to sanctioned parties are compliant with sanctions regimes and may need to report their activities, espe - cially if they suspect a breach of sanctions. In specific sanctions regimes, such as the one targeting Russia, reporting must be done regarding the management of reserves and assets of the Central Bank of Russia and the Russian National Wealth Fund. Credit institutions must also report deposits exceeding EUR100,000 being transferred out of the EU by Russian nationals or entities owned by Russian nationals or entities. Legal Framework The EU regulations that outline specific reporting obli - gations are spread across diverse sanctions or may arise from member states’ national regulatory or pru - dential rules. Council Regulation (EU) No 833/2014 setting out sectoral sanctions vis-à-vis Russia con - tains specific reporting requirements. Such require - ments are also envisaged under the sanctions regime on Belarus, Haiti and Iran. 3. Recent and Future Legal Developments 3.1 Significant Court Decisions or Legal Developments Since the proliferation of EU sanction regimes, par - ticularly those targeting Russia and Belarus, the juris - prudence of the Court of Justice of the European Union (CJEU) in sanctions matters has become more complex.

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