While the United States and European Union continue to maintain strong rhetoric on Russia, recent developments suggest that the once-solid architecture of sanctions is showing signs of procedural and legal strain. Increasingly, individuals with Russian connections are finding pathways—both legal and political—towards being removed from sanctions lists, challenging the long-term durability of restrictive measures introduced since 2022.
In March, the EU announced the delisting of several Russian nationals, including Sports Minister Mikhail Degtyarev, prominent businessman Vyacheslav Kantor, Gulbahor Ismailova (sister to sanctioned businessman Alisher Usmanov), and former EuroChem CEO Vladimir Rashevsky. The changes formed part of the bloc’s routine review of its sanctions regime. Yet, according to European media, the decisions were driven not merely by procedural scheduling, but by shifting dynamics within the EU itself—particularly lobbying efforts and the growing influence of dissenting member states such as Hungary.
Legal challenges to sanctions are also on the rise. Russian banking tycoon Mikhail Fridman, for example, has taken legal action against his inclusion in EU sanctions. Though aspects of his case have been upheld, the sanctions against him remain intact—highlighting the fact that judicial victories do not always translate into immediate relief from economic restrictions.
The case of Vladimir Rashevsky stands out for its combination of courtroom success and public advocacy. In 2024, the former EuroChem executive successfully argued in the EU General Court that the rationale for his listing had been exaggerated and that his rights had been infringed. His removal followed a protracted legal battle supported by a coordinated public relations strategy. Observers point to this case as an example of how sustained legal and reputational efforts can erode the foundation of politically motivated sanctions.
The trend is not confined to Europe. In the United States, Karina Rotenberg, the wife of Russian businessman Boris Rotenberg, was quietly removed from the Treasury Department’s Specially Designated Nationals (SDN) list on 2 April 2025. A naturalised American citizen since 2007, Rotenberg had found herself targeted in 2022 as part of a broader campaign against relatives of sanctioned Russian elites.
Rotenberg defence, led by a US legal team, argued that her designation by the Office of Foreign Assets Control (OFAC) was legally baseless. The team successfully demonstrated that she had no involvement in any sanctionable conduct, and that her inclusion stemmed solely from her marital connection to a sanctioned figure.
Legal analysts view the case as a milestone, reinforcing a core tenet of the American legal system: sanctions imposed on US citizens require a demonstrable evidentiary basis. Rotenberg’s removal, they argue, exemplifies the role of due process even in highly politicised policy areas.
Meanwhile, other developments—such as the temporary suspension of sanctions on Kirill Dmitriev, head of the Russian Direct Investment Fund, to facilitate backchannel diplomacy—underscore that sanctions, while politically potent, are not legally immutable.
Publicly, both Washington and Brussels maintain firm stances. Yet behind the scenes, cracks are beginning to emerge in the machinery of economic pressure. As more individuals seek legal redress, Western institutions will be increasingly challenged to reconcile geopolitical objectives with the principles of legal scrutiny and procedural fairness.
