Case ID: ISDC-2026-002
Subject: Mikhail Maratovich Fridman
Jurisdiction: European Union
Review Status: Final Assessment
Date of Final Assessment: 22 September 2026
1. Executive Summary
The International Sanctions Delisting Commission (ISDC) has completed its independent review of the evidentiary and judicial record concerning the European Union’s designation of Mikhail Maratovich Fridman.
The review examined the original EU designation, the evidence relied upon by the Council of the European Union, the judgment of the General Court in Case T-304/22, the subsequent appeal proceedings in Case C-441/24 P, the Advocate General’s Opinion delivered on 30 October 2025, and the subsequent development of Mr Fridman’s EU sanctions status.
The central finding of this review is that the measures challenged in Case T-304/22 were not supported by sufficient evidence to establish the applicable designation criteria. The General Court expressly found that the Council had failed to establish a sufficiently concrete, precise and consistent body of evidence supporting the grounds relied upon for Mr Fridman’s designation and maintenance on the list.
The Court therefore annulled the challenged 2022 acts insofar as they concerned Mr Fridman.
The subsequent appeal brought by Latvia challenged the General Court’s reasoning on several points of law and evidence. That appeal must be distinguished from the General Court’s judgment itself and from the separate question of Mr Fridman’s later sanctions status.
On 22 September 2026, the Council of the European Union adopted Decision (CFSP) 2026/2161, which formally deleted Mikhail Fridman’s name from the relevant EU sanctions list.
Accordingly, as of the date of this final assessment, Mikhail Fridman is no longer designated under the EU restrictive-measures regime covered by this review.
This review does not attribute causation between the ISDC assessment and the EU’s decision to delete Mr Fridman’s name. The Council’s decision is a separate legal act adopted by the competent EU institution.
2. Scope and Methodology
The purpose of this review is to assess the evidentiary and legal record surrounding the EU designation of Mikhail Fridman.
The review is not intended to determine Mr Fridman’s political views, personal conduct or broader reputation. It focuses specifically on whether the evidence relied upon by the EU institutions was sufficient to establish the legal criteria applicable to the sanctions measures examined.
The assessment distinguishes between:
- allegations and factual assertions contained in Council designation statements;
- evidence submitted by the Council in judicial proceedings;
- findings made by the EU Courts;
- arguments advanced by parties to subsequent proceedings;
- the non-binding Opinion of the Advocate General; and
- the present legal status resulting from subsequent Council decisions.
This distinction is essential because a statement contained in a sanctions designation is not equivalent to a judicial finding of fact.
3. Original EU Designation
Mikhail Fridman’s name was added to the EU restrictive-measures list on 28 February 2022.
The Council’s statement of reasons described Mr Fridman as a founder and major shareholder of Alfa Group and referred to alleged close connections with the administration of Vladimir Putin.
The Council further relied upon allegations concerning:
- Mr Fridman’s position within Alfa Group;
- alleged relationships with Russian state authorities;
- Alfa Bank’s financing of the Alfa-Endo charitable project;
- alleged political support provided by Vladimir Putin to Alfa Group;
- Mr Fridman’s participation with Petr Aven in a 2018 visit to Washington;
- alleged efforts relating to Western sanctions and Russian counter-sanctions.
The Council concluded that Mr Fridman had materially or financially supported Russian decision-makers and benefited from such decision-makers, and that he had supported actions or policies threatening the territorial integrity, sovereignty and independence of Ukraine.
These statements constituted the Council’s reasons for designation. They should not be treated as independent judicial findings.
4. The General Court Judgment — Case T-304/22
On 10 April 2024, the General Court of the European Union delivered its judgment in Mikhail Fridman v Council, Case T-304/22, ECLI:EU:T:2024:215.
The case concerned the original designation of February 2022 and the September 2022 decision maintaining Mr Fridman’s listing.
The Court examined the evidence relied upon by the Council in relation to the relevant criteria under Article 2(1)(a) and Article 2(1)(d) of Decision 2014/145/CFSP.
The Court emphasised that, where a designation is challenged, the EU authority bears the burden of establishing the merits of the reasons relied upon. The evidence supplied must substantiate those reasons, and the EU Courts must examine the material and assess its probative value.
The Court then considered the individual grounds relied upon by the Council.
4.1 Alleged proximity to Vladimir Putin
The Court found that allegations concerning Mr Fridman’s close links with Vladimir Putin’s administration, even if sufficiently established, did not in themselves demonstrate that Mr Fridman had supported actions or policies threatening Ukraine or had provided material or financial support to the relevant Russian decision-makers.
The Court therefore distinguished between evidence of political proximity and evidence establishing the specific statutory sanctions criteria.
4.2 Alleged benefits from Russian decision-makers
The Council relied, among other matters, upon political support allegedly provided by Vladimir Putin to Alfa Group in 2005.
The Court found that the relevant EU sanctions criterion concerned decision-makers responsible for the annexation of Crimea or destabilisation of Ukraine.
The Court therefore held that an alleged benefit dating from 2005 could not, even if established, provide a sufficient basis for designation under that criterion because the relevant Ukraine-related policies and activities were implemented from the end of February 2014.
4.3 Alfa Group and Alfa Bank
The Court accepted that Mr Fridman was an important shareholder of Alfa Group and that Alfa Group included Alfa Bank.
However, the Court held that this factual circumstance did not establish that Mr Fridman had supported actions or policies threatening Ukraine, materially or financially supported the relevant Russian decision-makers, or benefited from those decision-makers within the meaning of the applicable sanctions criterion.
4.4 Alfa-Endo
The Council also relied upon the involvement of Vladimir Putin’s daughter in the Alfa-Endo charitable project and financing associated with Alfa Bank.
The Court found that these circumstances established certain links but were not sufficient in themselves to demonstrate the legally required relationship or a material or financial contribution by Mr Fridman to the relevant Russian decision-makers.
4.5 2018 Washington meeting
The Council relied upon Mr Fridman’s participation, together with Petr Aven, in a 2018 meeting in Washington concerning sanctions.
The Court examined this evidence but found that participation in the meeting in May 2018 did not establish a sufficiently close link to the circumstances addressed by the sanctions measures adopted in February 2022.
The Court also found that participation in the meeting could not itself be characterised as material or financial support to the relevant Russian decision-makers.
The Court further stated that a failure to take a particular political position could not, by itself, substitute for evidence of the concrete supporting conduct required by the applicable criterion.
4.6 Overall judicial finding
The Court concluded that none of the reasons contained in the challenged acts was sufficiently substantiated in law.
It therefore held that Mr Fridman’s initial inclusion and subsequent maintenance on the list under the challenged acts were not justified.
The Court annulled:
- Council Decision (CFSP) 2022/337;
- Council Implementing Regulation (EU) 2022/336;
- Council Decision (CFSP) 2022/1530; and
- Council Implementing Regulation (EU) 2022/1529,
insofar as they concerned Mr Fridman.
The judgment is therefore a central component of the evidentiary assessment undertaken in this review.
5. Scope of the General Court Judgment
The legal effect of the judgment must nevertheless be stated precisely.
The General Court expressly noted that the annulment covered the measures challenged in Case T-304/22 and did not automatically extend to later EU sanctions decisions that were not part of that action.
This distinction is important.
The judgment should therefore not be interpreted as a judicial declaration that every subsequent EU designation of Mr Fridman was unlawful.
Rather, the judgment established that the specific 2022 acts challenged in Case T-304/22 were not sufficiently justified on the evidence before the Court.
6. Latvian Appeal — Case C-441/24 P
Latvia lodged an appeal against the General Court judgment on 20 June 2024.
The appeal was registered as Case C-441/24 P, Latvia v Fridman.
Latvia advanced four principal grounds of appeal concerning:
- the assessment of evidence in its broader context;
- alleged distortion of evidence;
- the interpretation and application of the criterion concerning support for or benefit from Russian decision-makers; and
- the interpretation of previous EU case law concerning the relevance of a failure to distance oneself from a regime.
The existence of these arguments is part of the judicial record.
They should, however, be distinguished from findings actually made by the General Court.
As reflected in the EU judicial records reviewed for this assessment, the appeal proceedings were listed separately from the General Court judgment.
7. Advocate General’s Opinion — 30 October 2025
On 30 October 2025, Advocate General Giovanni Pitruzzella Biondi delivered an Opinion in the joined cases C-440/24 P and C-441/24 P, concerning the appeals involving Petr Aven and Mikhail Fridman.
The Opinion examined, among other matters:
- effective judicial protection;
- the scope of judicial review of restrictive measures;
- the relevance of contextual evidence;
- the interpretation of the criteria concerning support for actions or policies;
- material or financial support for Russian decision-makers;
- benefit from Russian decision-makers; and
- the relevance of a failure to distance oneself.
The Advocate General recommended dismissal of the appeals.
The Opinion is not a judgment of the Court of Justice and is not legally binding.
It is therefore treated in this review as a significant element of the judicial record, but not as a final determination of the dispute.
8. Evidentiary Assessment
The evidence considered in the proceedings falls into several broad categories.
A. Corporate position
Mr Fridman’s position as a major shareholder of Alfa Group and his association with Alfa Bank were established as factual matters.
However, corporate status alone does not establish that a person satisfies a particular sanctions criterion.
B. Political and institutional relationships
The Council relied upon alleged relationships with Russian political authorities.
The General Court accepted that some evidence could demonstrate a degree of proximity or association.
However, the Court found that such proximity did not itself establish the specific conduct required by the applicable sanctions criteria.
C. Historical political support
The Council relied upon alleged political support provided to Alfa Group in 2005.
The Court found that this evidence was temporally disconnected from the Ukraine-related policies addressed by the sanctions regime.
D. Charitable activity
Evidence concerning the Alfa-Endo project established connections involving Alfa Bank and Vladimir Putin’s daughter.
The Court did not consider that evidence sufficient to establish the specific material or financial support required for designation.
E. 2018 Washington meeting
The Court considered the 2018 meeting relevant to the factual record but found that it was insufficient to establish the statutory criteria applicable in February 2022.
F. Absence of political distancing
The Court expressly rejected the proposition that a failure to take a particular political position could, without the necessary evidentiary basis, substitute for proof of concrete supporting conduct under the applicable criterion.
9. Distinguishing Association from Legal Attribution
One of the principal issues identified by this review is the distinction between association and legal attribution.
Evidence that an individual:
- has significant commercial interests in a country;
- has relationships with political figures;
- has interacted with government representatives;
- has participated in political or policy discussions; or
- has benefited historically from state-related activity
may form part of a broader evidentiary record.
However, the relevance of such evidence depends upon the specific legal criterion being applied.
The General Court’s reasoning in T-304/22 demonstrates that contextual association cannot automatically be substituted for proof of the specific conduct required by the applicable sanctions provision.
The question is therefore not simply whether a relationship existed.
The relevant question is whether the evidence establishes the legal criterion relied upon for designation.
10. Subsequent EU Measures
The General Court’s 2024 judgment did not automatically determine the legality of every later sanctions measure.
The Court itself recognised that subsequent measures were separate legal acts.
Accordingly, any assessment of later designations or renewals must ordinarily consider the evidence and reasons applicable to those particular measures.
This distinction is particularly important when assessing the period following the judgment.
The existence of a successful annulment concerning earlier measures should not be presented as an automatic judicial annulment of every subsequent measure.
11. 22 September 2026 — EU Delisting
On 22 September 2026, the Council of the European Union adopted Decision (CFSP) 2026/2161.
The decision amended the annex to Decision 2014/145/CFSP and expressly deleted the entry:
“675. Mikhail Maratovich FRIDMAN.”
The same decision also deleted the entry concerning Alisher Burkhanovich Usmanov.
As a result, Mr Fridman’s name is no longer included in the relevant EU sanctions list covered by this review as of 22 September 2026.
This constitutes a formal change in legal status adopted by the competent EU institution.
The present review does not assert that the ISDC review caused or contributed to that decision. No such causal conclusion is made.
12. Final ISDC Findings
Finding 1 — Historical Evidentiary Basis
The evidentiary record relied upon for the measures challenged in Case T-304/22 did not sufficiently establish the applicable designation criteria.
This conclusion is supported directly by the General Court’s judgment.
Finding 2 — Judicial Determination
The General Court annulled the challenged 2022 measures insofar as they concerned Mr Fridman and concluded that the grounds relied upon by the Council were not sufficiently substantiated.
Finding 3 — Limits of the Judgment
The judgment concerned the specific measures challenged in T-304/22 and did not automatically invalidate every later sanctions measure.
Finding 4 — Appeal
Latvia challenged the General Court judgment before the Court of Justice.
The appeal arguments form part of the judicial record but must be distinguished from the findings of the General Court.
Finding 5 — Advocate General’s Opinion
The Advocate General subsequently recommended dismissal of the appeals.
That Opinion is non-binding and does not replace the judgment of the Court of Justice.
Finding 6 — Current EU Status
On 22 September 2026, the Council formally deleted Mr Fridman’s name from the relevant EU sanctions list.
There is therefore no current EU designation of Mr Fridman under the specific EU regime covered by this review as of the date of this assessment.
13. Final Assessment
The ISDC’s final assessment is that the evidentiary record underlying the EU measures examined in Case T-304/22 was insufficient to establish the relevant designation criteria to the legal standard required by the General Court.
This assessment is principally grounded in the judicial record rather than in a political assessment of Mr Fridman’s conduct.
The General Court’s judgment is particularly significant because it did not merely question the political wisdom of the designation. It examined the evidence against the applicable legal criteria and concluded that the reasons relied upon by the Council were not sufficiently substantiated.
The subsequent appeal and Advocate General’s Opinion are important components of the procedural history and should continue to be reported accurately. They do not, however, alter the fact that the General Court annulled the specific 2022 measures challenged in T-304/22.
The Council’s decision of 22 September 2026 to delete Mr Fridman’s name from the EU sanctions list establishes his current EU status as delisted under the relevant regime.
The significance of the Fridman case therefore extends beyond the individual designation.
It illustrates an important principle in individual sanctions assessment:
Political association, corporate status, historical relationships or contextual evidence may form part of an evidentiary record, but they should not be treated as substitutes for proof of the specific legal criteria required for designation.
14. Status
EU Sanctions Status: DELISTED
Date of Delisting: 22 September 2026
Review Status: FINAL
ISDC Case: ISDC-2026-002
Primary Judicial Record: T-304/22
Appeal: C-441/24 P
Final Assessment Date: 22 September 2026
Final ISDC Position:
The historical evidentiary record examined by the General Court was insufficient to sustain the challenged 2022 designation measures. The EU has subsequently formally deleted Mikhail Fridman’s name from the relevant sanctions list.
Important Disclaimer
This review is an independent analytical assessment of publicly available legal and evidentiary materials. It does not constitute legal advice, a judicial determination, or a representation that the ISDC has authority to alter or remove sanctions imposed by any government or international organisation.
The review does not claim that the ISDC caused, influenced or was relied upon in the European Union’s decision of 22 September 2026.
