The situation
The Council of the European Union on 22 September extended restrictive measures targeting individuals and entities deemed responsible for undermining Ukraine’s territorial integrity for 36 months, replacing the previous six-month renewal cycle. The regime, which covers more than 3,000 persons and entities, retains travel restrictions, asset freezes and a prohibition on making funds or economic resources available to those listed.
Council Implementing Regulation (EU) 2026/2160 entered into force on publication and deleted Alisher Usmanov and Mikhail Fridman from Annex I, alongside other reviewed entries. The removals are legally effective across EU member states, but they do not alter the continuation of the broader listings framework until September 2029.
Why it matters
The three-year extension gives the EU a longer-duration legal basis for maintaining individual financial and travel restrictions linked to Russia’s war against Ukraine, reducing the need for repeated short-cycle renewals. It preserves an important economic-pressure instrument while leaving the wider sanctions architecture intact.
The delistings show that individual designations remain subject to review and legal-political scrutiny. Estonia has said it intends to impose national sanctions on Usmanov and Fridman, indicating that national measures may partly offset the EU-level removals in at least one member state.
What changed
On 22 September, the EU replaced the regime’s prior six-month renewal rhythm with a 36-month extension through 22 September 2029 and made the removals of Usmanov and Fridman legally effective.
The assessment
Current judgement
The delistings are a material exception within a substantially strengthened and longer-lasting EU individual-sanctions framework.
Impacts
Economic Pressure
The extension preserves EU travel, asset-freeze and funding restrictions for the remaining listed persons and entities through September 2029, sustaining pressure on Russia-linked targets despite the removal of several entries.
Diplomacy
The removals underscore the political and legal sensitivity of individual sanctions decisions, while Estonia’s stated plan for national sanctions points to potential divergence in post-delisting treatment among member states.
Political Stability
A three-year renewal reduces the frequency of EU-wide votes on this listings regime, but the exemptions and removals remain a potential source of disagreement over sanctions policy.
Full edition assessment · Economic Pressure
The EU has extended its individual Russia-related sanctions regime through September 2029, preserving travel restrictions, asset freezes and funding prohibitions for more than 3,000 listed persons and entities. The longer renewal period strengthens policy durability and reduces the frequency of EU-wide renewal decisions.
The simultaneous removal of Alisher Usmanov and Mikhail Fridman shows that individual listings remain subject to review. This is a targeted sanctions development, not evidence of a broad new tightening in global economic pressure.
Moderate confidence · Improving · Easing
Sanctions compliance horizon becomes more predictable
The three-year extension maintains the EU legal basis for restrictions on the remaining designated persons and entities, reducing near-term uncertainty over the regime's continuation.
EU-regulated financial institutions, counterparties and service providers retain a durable compliance obligation for the listed population.
Signal to watchFurther Council decisions modifying Annex I or formal national measures following EU delistings would determine whether individual exposure changes materially.
Delistings create uneven jurisdictional exposure
The EU-level removal of two individuals ends restrictions attached to those listings, while Estonia has stated that it intends to pursue national sanctions against them.
Businesses and asset holders may face different legal exposure across jurisdictions despite the EU-level delistings.
Signal to watchEstonia's publication of binding national restrictive measures would clarify the scope of any continuing country-specific restrictions.
What to watch
- Does Estonia formally adopt national restrictive measures against Usmanov and Fridman, and what restrictions do they impose?
- Do further EU legal acts or Council decisions alter the scope of Annex I before the next formal review of the regime?
Evidence and uncertainty
Moderate confidence. Moderate confidence. 11 retained references from 6 reporting origins (Reuters, Ministry of Foreign Affairs of Estonia, Council of the European Union, European Union, European External Action Service, European Union Official Journal). Claim-level independent corroboration has not been established. Confidence concerns the evidence for the reported development, not the probability of an outlook.
Useful context
Annex I
The legal annex listing persons and entities subject to restrictive measures under the relevant EU regulation.
Deletion from Annex I ends the EU-level restrictions attached to that listing.
Council Implementing Regulation (EU) 2026/2160
The EU regulation adopted on 22 September 2026 to amend the sanctions list under Regulation (EU) No 269/2014.
It made the reviewed deletions, including those of Usmanov and Fridman, directly applicable across EU member states.
Geographic context
- 01Moscow, Russia (city)
- 02Kyiv, Ukraine (city)
- 03Brussels, Belgium (city)