From the beginning of the war in Ukraine to the present, 18 people associated with Russia have been excluded from the sanctions lists of the EU, US and UK. 8 people were excluded from EU sanctions lists, 7 from US sanctions lists, 3 from UK lists.
On September 14, the United States lifted sanctions against former vice president of Sberbank Natalya Alymova and member of the supervisory board of Otkritie FC Paul Goldfinch. Prior to this, on September 13, the European Union lifted sanctions from three Russian entrepreneurs: the owner of the ESN group Grigory Berezkin, the ex-head of Ozon Alexander Shulgin and the co-owner of Northgas Farhad Akhmedov. In addition, sanctions were lifted from Oleg Tinkov, Saodat Narzieva (sister of Alisher Usmanov), Olga Aiziman (former wife of Mikhail Fridman), Andrei Golikov and Elena Titova.
Considering that the sanctions lists are regularly replenished with new names, and the courts of the European Union consider and reject the claims of persons who try to challenge inclusion in the sanctions lists, the lifting of sanctions is rather an exception.
An analysis of court decisions of the EU courts shows that the main basis for lifting sanctions, at least according to the official position of the EU courts, is a change in the connection of the sanctioned persons with a particular organization/company that is significant for the Russian economy. For example, dismissal from a government position for one reason or another, or resignation from the post of CEO or resignation from the board of directors. This was done by Dmitry Ovsyannikov, who left the post of head of Sevastopol, and Alexander Shulgin, who resigned from the post of General Director of Ozon.
Another possible reason for the lifting of sanctions against some Russian businessmen, such as Alexander Shulgin, Farkhad Akhmedov and Grigory Berezkin, may be that the dossiers on the basis of which decisions were made about whether to add individuals to the sanctions list were compiled hastily and based on machine translations of Russian-language publications and unreliable news sources.
An important factor is also competent lobbying of one’s interests in the competent sanctions authorities.
Nadmitov, Ivanov and Partners Law Firm advises clients on issues of sanctions law.