EU Extends Russia Sanctions 3 Years, Removes Two Oligarchs
On Sept 22, 2023, the EU extended Russia sanctions for 36 months and delisted two oligarchs.
Why it matters: Legal and compliance teams must update sanctions screenings due to longer renewal terms and removal of Usmanov and Fridman. Failure to do so risks sanctions violations amid a shifting regulatory landscape.
- On Sept 22, 2023, EU sanctions on roughly 3,000 Russian-linked entities were extended from six to 36 months.
- Russian oligarchs Alisher Usmanov and Mikhail Fridman were removed from the sanctions list, lifting their asset freezes and travel bans.
- France pushed for Usmanov's removal linked to a prisoner swap with Azerbaijan; Luxembourg backed Fridman’s exit amid a legal dispute.
- Latvia abstained on the vote after initially opposing; Ukrainian President Zelensky condemned the removals as unacceptable.
On September 22, 2023, the European Union agreed to extend its sanctions regime against Russia from six-month renewals to a fixed 36-month period. This extension covers approximately 3,000 Russian-linked individuals and entities connected to Russia’s military aggression in Ukraine.
The sanction extension aims to provide greater stability and predictability for enforcement and compliance efforts among businesses and legal teams.
However, the EU agreed to remove two well-known Russian oligarchs—Alisher Usmanov and Mikhail Fridman—from the sanctions list. Their asset freezes and travel bans were lifted as part of this decision. France advocated for Usmanov’s delisting, tying it to a prisoner release deal involving French nationals in Azerbaijan, while Luxembourg supported Fridman’s removal amid his $16 billion legal arbitration over frozen assets (Luxembourg Times).
Latvia opposed the removals initially but abstained in the final vote, allowing the agreement to proceed. Ukrainian President Volodymyr Zelensky condemned the decision on social media, calling it "unacceptable." EU officials described the consensus as pragmatic to maintain the broader sanctions framework without reopening complex negotiations.
For legal and compliance professionals, the longer sanction cycle means enhanced certainty in regulatory planning. However, the removal of high-profile names like Usmanov and Fridman necessitates prompt updates to sanctions screening processes and risk controls to avoid inadvertent exposure to sanction violations.
By the numbers:
- 3,000 individuals/entities — covered by the EU sanctions list extended to 36 months
- 36 months — new fixed renewal period for Russia sanctions, up from 6 months
- $16 billion — amount of legal claim by Mikhail Fridman over frozen assets
Yes, but: While the longer renewal period aids enforcement consistency, the oligarch removals introduce compliance complexity by altering the sanctioned parties at a critical juncture.
What's next: The EU is expected to review the Russia sanctions package annually despite the fixed 36-month term to adjust measures as geopolitical conditions evolve.