The inclusion or re-inclusion of natural or legal persons in the EU sanctions measures may be challenged before the Court of Justice of the European Union under Article 263 of the Treaty on the Functioning of the European Union (TFEU).
The contestation procedure has strict time limits. A successful claimant can claim damages for the loss suffered as a result of the erroneous application of the sanction. All EU de-listing judgments can be found in the ‘Judgments’ section of the Europe Sanctions website.
Grounds for revocation include, for example, lack of evidence for listing or re-listing, failure to comply with established procedures, vague grounds, errors of factual assessment made against the sanctioned party and breaches of the rights of the defence.
In practice, however, as of March 2022, the EU sanctions on Russia and Belarus have led to the inclusion of a large number of Russian businesses on the EU sanctions list, and none have been excluded for the time being, despite attempts to challenge the decision to include them.
On 06 September 2023, the European Court of General Jurisdiction has decided to lift EU sanctions against Alexander Shulgin, the former CEO of online retailer Ozon, who was subject to restrictions on 8 April 2022. The ruling will enter into force once the appeal period has expired. This is the first time a court decision has lifted sanctions on a Russian business in the EU.
The decision of the European Court of General Jurisdiction can be found here (decision in French).
AML.Plus team
English 
Latvian