MIKHAIL FRIDMAN

Mr. Mikhail Fridman was included in the European Union sanctions list on 28 February 2022.

The Council of the European Union described him as a top Russian financier and enabler of President Vladimir Putin's inner circle. The original statement of reasons referred, among other matters, to his business interests, his alleged relationship with the Russian administration, and allegations that he had actively supported materially or financially and benefited from Russian decision-makers responsible for the annexation of Crimea and the destabilisation of Ukraine.

The designation was subsequently maintained through further EU restrictive-measures acts.

The legal record has materially developed since Mr. Fridman's original designation.

On 10 April 2024, the General Court of the European Union annulled the restrictive measures concerning Mr. Fridman for the period from 28 February 2022 to 15 March 2023.

The General Court concluded that the evidence relied upon by the Council did not sufficiently substantiate the grounds examined in those proceedings.

The Republic of Latvia subsequently appealed that judgment in Case C-441/24 P.

Mr. Fridman also challenged later restrictive-measures acts in Case T-605/24. That case was removed from the register by order of 20 May 2026.

These developments do not automatically determine the validity of subsequent EU measures. They do, however, form a material part of the record when assessing whether the grounds for the continued designation remain applicable today.

ISDC considers the judgment in Case T-304/22 to be a material element of the review record because the General Court annulled the restrictive measures concerning Mr. Fridman for a defined historical period after examining the evidentiary basis relied upon by the Council.

The judgment should not, however, be interpreted as automatically determining the legal or evidentiary position of subsequent restrictive measures.

The ISDC review therefore distinguishes between the measures examined in T-304/22 and the grounds and evidence relied upon in later maintaining acts.

The review is examining the original grounds for designation, the findings of the General Court, the pending appellate record, subsequent EU measures and relevant changes in circumstances in order to determine whether the present basis for continued designation remains sufficiently supported.

The review remains in progress and no final conclusion has yet been reached.