EU Court Upholds Beloglazov Designation, Clarifies "Facilitating Sanctions Circumvention"
The EU General Court has dismissed Dimitry Beloglazov's application to annul his designation under Article 3(1)(h)(i) of Regulation (EU) 269/2014, which targets persons facilitating the circumvention of EU Russia sanctions. The judgment in Beloglazov v Council (T-492/24) is notable for its detailed commentary on the concepts of "circumvention" and "facilitating a circumvention" under EU sanctions law.
The court accepted the EU's position that Mr Beloglazov had facilitated circumvention through a scheme in Russia to acquire Oleg Deripaska's shareholding in International LLC Rasperia. That company held 28.5 million frozen shares in the Austrian construction group Strabag, and the transaction served to remove Deripaska from the ownership chain — making it easier to sell the shares and get around the EU asset freeze.
Mr Beloglazov challenged the legality of the designation criterion itself, arguing that "facilitating infringements of the prohibition on circumvention" breached the principles of legal certainty and proportionality. The court disagreed, holding that the criterion covers making easier an operation whose object or effect is to circumvent sanctions, whether by assisting it or lending support to its realisation.
His remaining arguments also failed. Mr Beloglazov contended that the transaction was conditional on obtaining a sanctions licence and therefore could not amount to circumvention, that there was no EU nexus, and that he had successfully applied to annul the sale of the Rasperia shares at the time of the listing. The court found it sufficient that he had an objective intention to bypass the EU asset freeze, adding that after complex schemes come to an end, a reasonable period may need to pass before the Commission can conclude that sanctions are no longer justified.
The ruling strengthens the EU's hand in targeting intermediaries in asset-transfer schemes and signals that structuring a deal around a licence application will not shield participants from designation.
The court accepted the EU's position that Mr Beloglazov had facilitated circumvention through a scheme in Russia to acquire Oleg Deripaska's shareholding in International LLC Rasperia. That company held 28.5 million frozen shares in the Austrian construction group Strabag, and the transaction served to remove Deripaska from the ownership chain — making it easier to sell the shares and get around the EU asset freeze.
Mr Beloglazov challenged the legality of the designation criterion itself, arguing that "facilitating infringements of the prohibition on circumvention" breached the principles of legal certainty and proportionality. The court disagreed, holding that the criterion covers making easier an operation whose object or effect is to circumvent sanctions, whether by assisting it or lending support to its realisation.
His remaining arguments also failed. Mr Beloglazov contended that the transaction was conditional on obtaining a sanctions licence and therefore could not amount to circumvention, that there was no EU nexus, and that he had successfully applied to annul the sale of the Rasperia shares at the time of the listing. The court found it sufficient that he had an objective intention to bypass the EU asset freeze, adding that after complex schemes come to an end, a reasonable period may need to pass before the Commission can conclude that sanctions are no longer justified.
The ruling strengthens the EU's hand in targeting intermediaries in asset-transfer schemes and signals that structuring a deal around a licence application will not shield participants from designation.
