ALISHER USMANOV

Mr. Alisher Usmanov was included in the European Union sanctions list on 28 February 2022.

The Council of the European Union identified him as a leading businessperson with particularly close ties to the President of the Russian Federation and stated that he had supported and actively endorsed the Russian Government's policies of destabilisation of Ukraine.

The EU designation has subsequently been maintained under amended grounds, including criteria concerning leading businesspersons operating in economic sectors providing a substantial source of revenue to the Government of the Russian Federation.

Since the original designation, the legal and factual record concerning Mr. Usmanov has developed substantially.

Mr. Usmanov has challenged his designation and subsequent maintaining acts before the EU courts. The General Court delivered judgments concerning the evidentiary and legal basis for the measures, and appeals concerning those judgments have been brought before the Court of Justice.

Subsequent EU acts have also relied on grounds and evidence that are not identical to those underlying the original 2022 designation.

ISDC is therefore reviewing the present designation on the basis of the current record rather than treating the circumstances existing at the time of the original designation as necessarily determinative today.

ISDC has opened an independent review of the continued application of EU restrictive measures to Mr. Usmanov.

The review does not proceed from a presumption that the designation should either be maintained or removed. It examines whether the grounds currently relied upon by the Council remain sufficiently supported by the present evidentiary record.

Particular attention is being given to the distinction between the original grounds for designation, the grounds relied upon in subsequent maintaining acts, relevant judicial findings, and material developments occurring after the original designation.

The existence of unsuccessful challenges to particular EU measures does not remove the need to assess whether the factual and evidentiary basis for continued designation remains applicable at the present time. Equally, subsequent changes in circumstances do not in themselves establish that delisting is warranted.

The review remains in progress.