The Council has secured its individual Russia sanctions listings until 2029. It has not explained why two of the best-known names came off, and that silence is now the regime’s weakest point.

On 22 September the Council of the European Union prolonged the individual listings over Ukraine’s territorial integrity for thirty-six months, fixing a new expiry date of 22 September 2029. More than 3,000 individuals and entities remain under asset freezes and travel bans. The regime had usually lived from one six-month rollover to the next, the most recent in March, so this EU Russia sanctions renewal marks a real change of rhythm. Yet the same release contains a sentence that deserves closer reading. The Council decided “not to renew the listings of three individuals and one entity.” It gave no names and no grounds. Two of those individuals, by every public account, are Alisher Usmanov and Mikhail Fridman.

The Case for the Bargain

The defence of the deal deserves a fair hearing, and it is stronger than the anger in Kyiv suggests. Twice a year since 2022, the EU Russia sanctions renewal has handed every capital a veto over the entire regime. Budapest treated that veto as a standing instrument of pressure for years. A sanctions architecture that must be rescued every six months invites brinkmanship by design. Securing three years of certainty removes the recurring cliff edge at which a single government could threaten a lapse.

A legal argument points the same way. Both men have contested their designations in Luxembourg. In April 2024 the General Court annulled the acts listing Fridman between February 2022 and March 2023, finding that none of the Council’s original reasons was sufficiently substantiated; he remained listed only because later decisions were already in force. Usmanov’s own challenge was dismissed by the same court. A list that loses cases erodes its own authority, and pruning weak files can be presented as housekeeping rather than retreat. Kaja Kallas, the High Representative, cast the outcome as a question of stability, and the Irish Council presidency, which brokered the talks, called the result a difficult compromise that “enhances the durability and predictability of the EU sanctions framework.” Even Estonia, which declined to support the delistings, welcomed the longer extension. Its foreign minister, Margus Tsahkna, said it “reduces the risk of future sanctions renewals becoming hostage to political bargaining.” Judged by that yardstick, the Council obtained what it wanted.

The private sector has a stake as well. Banks, custodians, and national authorities administer the freezes, and each six-month cycle obliged them to prepare for a possible lapse. That risk materialised this month, when the 15 September deadline passed and the listings survived on a seven-day extension. A longer EU Russia sanctions renewal spares the institutions that actually hold the assets from repeating that exercise every spring and autumn.

What the Record Shows, and What It Does Not

The public record of how the two names came off during the EU Russia sanctions renewal is thin, and what exists sits largely outside the Council. Latvia’s prime minister, Andris Kulbergs, said his government had faced a choice between changing the status of two individuals and risking the loss of the entire regime. Latvia abstained so that the decision could pass, as did Estonia, and both governments have since adopted national sanctions on the two men. Lithuania’s prime minister, Mindaugas Sinkevičius, has instructed his authorities to follow. In Kyiv, Foreign Minister Andrii Sybiha called the outcome shameful, while the Kremlin said sanctions on every Russian businessman should go.

Press reports citing unnamed diplomats have gone further, linking the French request concerning Usmanov to French nationals detained in Azerbaijan, and Luxembourg’s position on Fridman to his pending claim against the Grand Duchy. Reports since the decision say Azerbaijan’s president pardoned a detained French national the following day. Paris has drawn no public connection, Baku denies any interference, and none of these accounts appears in any Council document. This editorial does not rest its case on them.

It does not need to. Whatever the motives, the Council has published none. The formula in last week’s release is also not new. The September 2025 review dropped one individual and the March 2026 review dropped two. Neither announcement named the people concerned or explained their removal.

Neither delisting is necessarily wrong. Fridman has won in court before, and the Council may hold evidence that his file no longer meets the criteria in Decision 2014/145/CFSP and Regulation 269/2014. The difficulty is that the EU Russia sanctions renewal now offers no way for anyone outside the room to distinguish a removal grounded in evidence from one grounded in circumstance.

A Precedent the Courts Will Read

That gap carries a legal cost. The defence of every designation rests on one proposition: that names enter and leave the list according to published criteria, supported by evidence and reviewed in good faith. The General Court tests that proposition file by file. Counsel for listed persons who remain on the list will now point to a man whose listing that court upheld and who has nonetheless left it, and ask what distinguishes their client. The Council would then need to explain the distinction and show that its criteria are being applied consistently. It may well be able to, through fresh evidence, changed circumstances, or a revised legal assessment; without published reasons, it will be doing so after the fact and in a courtroom, rather than on the record at the moment of decision.

Aligned third countries face a parallel problem. The Council regularly records which partners have aligned themselves with its listings, and those governments now confront the same removals without the benefit of any reasons. They can follow Brussels without explanation or diverge from it, and divergence is exactly the fragmentation a common list exists to prevent.

The three-year horizon contains the damage for one regime only. The economic measures against Russia still run on six-month renewals, and other frameworks keep their own calendars. Every capital has now seen that a deadline concentrates bargaining power, and that a delisting can form part of the settlement. The change of government in Hungary removed the most familiar obstacle; last week showed that holdouts can emerge elsewhere. Any future EU Russia sanctions renewal on those other tracks will open with that knowledge on the table.

What the Council Should Now Put in Writing

The Union cannot reverse last week’s delistings. It can stop them from hardening into procedure, and three steps would help.

First, separate delisting from the EU Russia sanctions renewal itself. A request to remove a name should be tabled on its own, measured against the listing criteria, and accompanied by a written statement of reasons that the Council is prepared to defend in Luxembourg. A removal that cannot pass that test should not be agreed in the final hours before an expiry date.

Second, publish the names and the grounds at the moment of decision. The 22 September release refers to three individuals and one entity without identifying any of them. Disclosure would cost the Council little, and it would oblige every government that seeks a removal to defend it in public.

Third, be candid about the harder reform. Article 31(3) TEU allows the European Council, acting unanimously, to let the Council decide by qualified majority in specified foreign policy cases. Applying that clause to the routine extension of existing listings would end the standoff at each expiry. The obstacle is obvious: activation requires the consent of the very governments whose veto it would dilute, and the clause has never been used. Short of that, the Council can adopt a working rule of its own, requiring that any removal not ordered by a court be accompanied by a reasoned note to all delegations and a public summary. That needs no treaty change, only the political will that last week should have supplied.

The List as a Statement of Fact

Sanctions lists work through credibility as much as through frozen accounts. Every entry records the Council’s determination that a person or entity meets one of the criteria for listing, which range from supporting actions against Ukraine’s territorial integrity to benefiting from Russian decision-makers. When the European Council conclusions of 18 June 2026 promise continued pressure on Moscow, the list is the proof that the promise carries weight.

The latest EU Russia sanctions renewal shields that proof from the calendar. The silence around the two removals leaves it exposed to a different risk: the suspicion that findings of fact can change without explanation. The national measures adopted in Riga and Tallinn, and under preparation in Vilnius, will soften the practical effect. Published reasons would do more to protect the principle.

Brussels bought three years of stability last week. It should now decide, in writing, that no name leaves the list again without an account of why.