In a recent EU Case, the Court dismissed Mr. Dmitry Beloglazov’s challenge to his designation for facilitating the circumvention of EU sanctions targeting Russia (Case T-492/24). On 15 July 2026, the Court provided clearer guidance through the mentioned case on the scope of the Councils’ power to list persons for facilitating circumvention and what the definition can encapsulate.
A general background on the case is as follows: Rasperia Trading Limited (hereinafter referred to as “Rasperia”) held roughly 28.5 million shares in the European listed company, STRABAG SE. Those shares were frozen on the basis that Rasperia was controlled by Mr. Oleg Vladimirovich Deripaska, a person subject to EU restrictive measures. Mr. Deripaska coordinated a fraudulent scheme with Mr. Beloglazov in order to sell the frozen shares of STRABAG SE by creating a subsidiary, JSC Iliadis, which acquired Mr. Deripaska’s state in Rasperia, and subsequently, the frozen shares of STRABAG SE. As a consequence, the Council designated Mr. Beloglazov for facilitating circumvention of the sanctions attached to the frozen shares.
Mr. Beloglazov argued that his conduct took place outside of the EU and should therefore not fall within the Council’s reach in regard to sanctions. The Court rejected that argument and used this case to further expand on what circumvention can and will cover. The Court mentioned that operating outside of the EU is not in itself a shield against designation for facilitating circumvention. It clarified that this did not mean that it had extraterritorial power, and that the listing power must be viewed within the broader architecture of EU sanctions and as a tool available to the Council that complements, rather than substitutes for the enforcement powers that remain with Member States.
More specifically, the Court confirmed that, as a concept, facilitating circumvention’s definition is broad and encompasses any act and/or omission that enables a circumvention operation, or that merely facilitates the conditions for its implementation. What the Council state matters as they essentially affirm that being or operating outside of the EU is not in itself a shield, and that a designation for facilitating circumvention means that there must be an underlying circumvention that presents an EU nexus. The Council therefore reaffirms, in simpler terms, that there must be some link with EU jurisdiction in order for the same to apply.
To conclude therefore, the Court’s judgments highlights essentially the intention behind keeping the term of circumvention quite broad and that it remains a substance-over-form concept. It covers any activity, whatever its formal legality under other bodies of law, that has the purpose or effect of undermining the sanctions regime, and an objective intent to circumvent is sufficient even where circumvention was not actually achieved.
The judgment serves as a reminder that structuring transactions to route around EU asset freezes carries two distinct layers of exposure. The transaction itself may simply fail to achieve its commercial purpose, being unenforceable under EU law regardless of where it is executed. However, the individuals and entities who design or facilitate the structure face a separate and independent risk of designation, one that reaches conduct carried out entirely outside of the EU, provided that the underlying assets or restrictive measures retain an EU nexus.
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