The International Sanctions Delisting Commission (ISDC) has conducted an independent review of the publicly available legal, factual and evidentiary record concerning the continued designation of Alisher Usmanov under the European Union’s restrictive measures relating to Russia and Ukraine.
Mr Usmanov was originally designated by the European Union on 28 February 2022. The original statement of reasons referred, among other matters, to his alleged close relationship with Vladimir Putin and alleged support for Russian government policies concerning Ukraine. Subsequent EU decisions have relied in particular on his alleged status as a leading businessperson operating in economic sectors providing a substantial source of revenue to the Russian government.
The ISDC’s review does not assess the political merits of EU sanctions policy. It addresses a narrower question:
Does the present public evidentiary record continue to provide a sufficiently specific, reliable and current basis for maintaining the individual designation?
Our preliminary conclusion is that the answer cannot be established merely by repeating the original designation narrative.
The record has materially changed since February 2022. It now includes multiple judicial decisions concerning allegations that have appeared in media reporting relied upon in or associated with the sanctions narrative; subsequent amendments to the EU’s statement of reasons; developments concerning Mr Usmanov’s corporate interests; proceedings before the EU courts; German judicial decisions concerning specific allegations; and further proceedings concerning assets previously associated with him.
In our assessment, these developments create a material basis for a fresh, individualized reassessment of the designation before any further continuation is treated as justified.
This is not a finding that the designation must necessarily be removed. Nor does it substitute the ISDC’s assessment for the competence of the EU Council. It means that the continuing measure should be assessed against the current evidentiary record, rather than simply against the circumstances and information available in 2022.
The EU listed Mr Usmanov on 28 February 2022.
The original and subsequent EU statements of reasons have included several distinct propositions:
These are separate factual propositions and should not automatically be treated as interchangeable.
A person’s status as a major shareholder in a Russian company is one factual issue.
Whether that person personally acted on behalf of the Russian President in particular transactions is another.
Whether particular media allegations supporting the latter proposition remain reliable is a further question.
A proper continuing review therefore requires each material proposition to be tested separately.
Mr Usmanov challenged the EU measures before the General Court.
In T-237/22, the General Court dismissed his challenge in February 2024. The judgment concerned, among other matters, the interpretation of the criterion relating to support for actions or policies undermining or threatening Ukraine’s territorial integrity and the Council’s assessment of the evidence.
This judgment is an important part of the record and cannot be ignored.
At the same time, it is important to identify precisely what was and was not decided.
The judgment did not establish as a general proposition that every factual allegation appearing in the underlying media material was true. It concerned the legality of the relevant EU restrictive measures under the applicable legal criteria.
A second proceeding, T-1117/23, concerned later maintaining acts from 2023 and 2024.
On 3 September 2025, the General Court dismissed that action. Importantly, the Court found that the Council had sufficient grounds under the amended criterion concerning a leading businessperson operating in Russia and economic sectors providing substantial revenue to the Russian Government. The Court therefore did not need to uphold every separate strand of the Council’s reasoning.
This distinction matters.
A judicial finding that one independent legal basis was sufficient does not necessarily resolve whether every other factual allegation currently appearing in the statement of reasons remains adequately supported.
One of the most significant developments concerns an allegation that appeared in the Council’s earlier reasoning concerning Mr Usmanov allegedly acting as a representative or intermediary for President Putin.
According to the record presented in the subsequent proceedings, an earlier formulation stated that Mr Usmanov had reportedly “fronted” for President Putin and resolved his business problems.
The underlying Forbes publication was subsequently the subject of proceedings before the Hamburg Regional Court.
The Hamburg court prohibited further dissemination of the relevant statements in its judgment of 19 January 2024, Case 324 O 78/23.
The Council subsequently altered the wording in its sanctions statement.
The General Court considered that change when examining the later EU measures.
However, the current EU wording continues to state that Mr Usmanov is:
“reputed to have acted on behalf of the President of the Russian Federation in a number of business deals of political and strategic importance.”
That formulation remains a material part of the current record.
The question for a continuing review is therefore straightforward:
What independent evidence currently substantiates the underlying factual proposition?
A change in wording does not, by itself, constitute new evidence.
The evidentiary record has also developed through further proceedings in Germany.
On 23 January 2026, the Hamburg Regional Court issued judgment 324 O 43/24 concerning statements published by Frankfurter Allgemeine Zeitung.
The court prohibited the publication of several statements concerning Mr Usmanov, including assertions that he had been regarded as Putin’s informal representative for Uzbekistan and that he had used his money in the interests and allegedly on behalf of the Kremlin.
This judgment does not determine the legality of EU sanctions.
A German press-law judgment and an EU sanctions judgment operate under different legal frameworks.
Nevertheless, where a factual allegation has been used or relied upon in the public justification of a sanctions designation, a subsequent judicial finding concerning the factual basis of that allegation is potentially relevant evidence and should be considered in a continuing review.
It should neither automatically exonerate nor automatically incriminate the listed person.
It should be examined.
Another material development concerns the yacht Dilbar and the question of ownership or control.
In June 2026, the Administrative Court of Frankfurt am Main ruled against the German regulator’s refusal to confirm that the yacht should not be treated as a frozen asset controlled or owned by a sanctioned person. The proceedings arose after Lürssen challenged the regulator’s position concerning the vessel.
This is significant because allegations concerning ownership and control of assets have formed part of the broader public narrative surrounding Mr Usmanov and sanctions enforcement.
Again, the appropriate conclusion is not that one judgment determines the entire sanctions case.
The appropriate conclusion is that the evidentiary record concerning specific ownership/control propositions has materially developed since 2022.
That development should form part of any current assessment.
There is also an important distinction between sanctions designation and criminal liability.
German authorities discontinued a money-laundering investigation in 2024.
In 2025/2026, German prosecutors also discontinued a separate investigation concerning alleged violations of foreign-trade law after an agreement under which Mr Usmanov paid €10 million. The payment was not characterized as a criminal conviction or fine; the investigation was discontinued under the applicable German procedure.
These developments do not prove that the original sanctions designation was erroneous.
They do, however, form part of the subsequent factual record and should be distinguished carefully from allegations that have never resulted in criminal findings.
A submission made to the European authorities in August 2026, as described publicly by Mr Usmanov’s legal representatives, claims that the record now contains:
These figures originate from the legal team’s compilation and should therefore be treated as claims made by an interested party unless independently verified document-by-document.
Nevertheless, the underlying judicial decisions that have been independently reported are themselves relevant.
The existence of numerous corrections does not mean that all reporting about Mr Usmanov was incorrect.
Equally, the existence of some reliable reporting does not make subsequently corrected or prohibited allegations reliable.
The appropriate methodology is therefore claim-by-claim verification.
An independent review must also identify evidence that continues to support the Council’s position.
The EU courts confirmed that Mr Usmanov was a major shareholder in USM Holding and that his interests were connected to substantial Russian economic activities. The 2025 General Court judgment specifically found that the Council had sufficient grounds under the economic-sector criterion for the relevant maintaining measures.
The current EU statement of reasons continues to rely on his interests in metals and mining and other Russian economic sectors.
Therefore, the present record cannot accurately be characterized as a situation in which all grounds have been judicially rejected.
That would be incorrect.
The question is narrower:
Whether the current record continues to support each of the grounds relied upon for the continuing individual designation, and whether the surviving grounds remain sufficient under the applicable legal criteria.
The circumstances surrounding the current renewal are materially different from those existing in February 2022.
The EU designation has now been in place for more than four years.
The evidentiary record has developed.
Several allegations have subsequently been challenged in national courts.
Some publications have been corrected, removed or prohibited from further dissemination.
The EU itself has modified portions of the wording used in the statement of reasons.
There have been subsequent judicial proceedings concerning the EU measures.
There have also been changes concerning corporate assets and ownership structures.
At the same time, the EU courts have confirmed that at least some independent grounds were sufficient to support the relevant maintaining measures at the time those cases were decided.
Consequently, the proper question in September 2026 is not:
“Was the original 2022 designation justified?”
It is:
“Does the evidence supporting the designation remain sufficiently reliable, specific and applicable today?”
That is the question that a periodic sanctions review is intended to answer.
⸻
Based on the publicly available record reviewed to date, ISDC considers that there is a material and substantive basis for a fresh individualized assessment of Mr Usmanov’s designation.
In particular, the record does not justify treating the original 2022 evidentiary narrative as immutable.
Where individual factual allegations have subsequently been the subject of judicial findings, corrections, withdrawals or changes in the Council’s own wording, those developments should be incorporated into the continuing assessment.
Where an independent legal basis remains supported by current evidence, that basis should be identified separately.
Where a factual proposition can no longer be adequately substantiated, it should not be treated as established merely because it appeared in the original designation.
Accordingly, ISDC does not regard automatic continuation of the designation without a fresh examination of the current evidentiary record as an adequate substitute for individualized review.
The competent EU authorities must determine, on the basis of the complete record available to them, whether the applicable legal criteria for continued restrictive measures remain satisfied.
⸻
This review is based on publicly accessible materials.
The ISDC does not have access to confidential intelligence or classified material that may be held by EU Member States or institutions.
Accordingly, this review cannot establish whether non-public evidence exists that independently supports allegations that cannot presently be verified from the public record.
Nor does ISDC treat the outcome of any single court case as determinative of the entire sanctions question.
The assessment is based on the cumulative record available as of 19 September 2026.
⸻
Conclusion
The passage of time does not automatically invalidate a sanctions designation.
But neither does the passage of time automatically validate its continuation.
The public record concerning Alisher Usmanov has materially changed since February 2022.
The current record contains both evidence supporting aspects of the original designation and substantial subsequent material requiring those allegations to be reassessed.
For that reason, the ISDC’s present assessment is that the case warrants a fresh, evidence-by-evidence review of the continuing designation before any further continuation is treated as self-evidently justified.
The question is no longer simply whether the 2022 designation was reasonable on the information then available. The relevant question is whether the evidence remains sufficient today.