Washington, D.C. (September 27, 2023) – On September 15, 2023, three Russian businessmen were removed from the European Union (EU) sanctions list following the end of an EU sanctions renewal period.
The three individuals, Grigory Berezkin, Farkhad Akhmedov, and Alexander Shulgin, were previously subject to sanctions under Annex I of the "Council Regulation (EU) No 269/2014 of 17 March 2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine," which froze listed individuals' assets and restricted travel within the EU. These sanctions require member state unanimity and are renewed every six months.
Shulgin's removal from the sanctions list follows a successful appeal to the Court of Justice to the European Union (CJEU). Shulgin had previously been described in the April 8, 2022 EU Journal as a leading businessperson, particularly in the Russian e-commerce sector as an executive for Ozon, and was listed for "providing a substantial source of revenue to the Government of the Russian Federation," and attending a meeting with President Valdimir Putin. The judgment, which has yet to be officially published, determined that Shulgin's listing was based on insufficient grounds, noting that his attendance in a meeting with Putin did not, alone, indicate support for Russian actions in Ukraine and that Shulgin had stepped down from his executive position in Ozon. Other CJEU rulings of the same date dismissed appeals by sanctioned Russian individuals, and a number of sanction appeals remain pending.
The EU did not provide an official comment on the delisting of the other two Russian businessmen. Berezkin, chairman of the Board of Directors of Russian private equity group ESN, was described in the EU Official Journal's April 8, 2022 listing as "a leading Russian businessperson ... considered to be the 'henchman' of President Vladimir Putin." Akhmedov has been involved in the Russian energy and gas sector, the Annex I listing described him as "a leading businessperson involved in economic sectors providing a substantial source of revenue to the Government of the Russian Federation."
Individuals and businesses may be subject to a variety of sanctions regimes, which creates a heightened risk when entering into new transactions.
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