EU court sets higher evidence bar for freezing assets of companies linked to sanctioned Russians

LUXEMBOURG, Sepetember 03, 2026 — The European Union’s highest court has ruled that national authorities may freeze the assets of companies not themselves named on EU sanctions lists when their funds or resources are owned or controlled by a sanctioned person, while imposing a significant evidentiary threshold on such action.

The Court of Justice of the European Union issued the ruling in Inter Rao Lietuva, Case C-147/25, concerning a Lithuanian electricity importer whose assets were frozen in 2022 because authorities considered it linked to Russian President Vladimir Putin, who is subject to EU sanctions. Inter Rao Lietuva challenged the measure before Lithuania’s Supreme Administrative Court.

The court said Regulation 269/2014 does not prevent national authorities from maintaining implementation lists identifying companies whose assets must be frozen even if those companies are not individually listed by the EU. Such measures implement existing EU sanctions where the assets belong to, are held by or are controlled by a listed person.

That position largely reflects Advocate General Manuel Campos Sánchez-Bordona’s February opinion, which said national authorities could identify additional entities for asset-freeze purposes when implementing EU restrictive measures. The advocate general also stressed the role of effective judicial scrutiny over national sanctions decisions.

The court, however, drew a firm line on evidence of control.

Lithuanian authorities had argued that Russia’s political system and Putin’s extensive powers supported a finding that he could exercise effective control over companies operating in strategically important sectors such as energy.

The court rejected that proposition as sufficient on its own. Russia’s autocratic and oligarchic political structure does not itself constitute sufficiently solid evidence that Putin controls a particular company, it said. Authorities must instead establish control through direct evidence or a sufficiently specific, precise and consistent body of evidence demonstrating an ability to influence the company’s decisions.

Informal control can still be considered. Courts may examine ownership structures, Russian state shareholdings and other evidence demonstrating genuine influence, but those factors must collectively provide an objective and sufficiently solid basis for the freeze.

The judgment also confirmed that companies do not necessarily have to be heard before an initial asset freeze where advance notice could undermine the measure’s effectiveness. They must, however, have access to effective judicial review afterward.

The ruling provides an important benchmark for EU sanctions enforcement by allowing member states to trace sanctions through corporate ownership and control structures while limiting reliance on broad assumptions about Russian state influence.