Delisting from an EU sanctions list

Delisting takes a person off the annexes of an EU sanctions regime, either by Council decision after review or following a General Court judgment that annuls the listing. The first route runs through the Council: the listed person sends its observations and a request for reconsideration, and the Council reviews the lists at each renewal, every six months for the Russia regime, in March and September. The second runs through the General Court: an action for annulment under Article 263 TFEU (Treaty on the Functioning of the European Union), within two months of publication or notification, plus the extension on account of distance. The Court checks that the reason for listing rests on a sufficiently solid factual basis. On March 8, 2023, in Case T-212/22, it annulled the listing of Violetta Prigozhina, mother of the Wagner founder: the family tie was not enough, and she had not owned Concord Management and Consulting since 2017. On March 20, 2024, in Case T-743/22, it annulled the acts keeping Nikita Mazepin on the lists until March 15, 2024, since the association criterion requires a link that goes beyond family. On April 10, 2024, it annulled the listings of Petr Aven and Mikhail Fridman for the period from February 2022 to March 2023 (T-301/22 and T-304/22). Both stayed frozen under the renewal acts, adopted on updated grounds. The judgment covers only the acts challenged. The Council can relist on other grounds, and the annulment of a regulation takes effect only once the appeal period has run. For an insurer, a delisting is read from its date of publication in the Official Journal, never from a press release: an indemnity paid into a frozen account is released only then. And Article 10 of Regulation 269/2014 shields whoever froze in good faith from any claim by the insured, unless the freeze is shown to result from negligence.