CJEU Clarifies The Evidential Threshold For Establishing Control Under EU Restrictive Measures

On 3 September 2026, the Court of Justice of the European Union (“CJEU” or the “Court”) delivered its judgment in Case C-147/25, Inter Rao Lietuva, concerning the evidential basis required to establish that an undertaking is controlled by a person subject to EU restrictive measures. 

Inter Rao Lietuva AB operated in Lithuania as an independent importer and supplier of electricity. In 2022, its funds were frozen after the company was included by the competent Lithuanian authority on a national list of persons considered to have links with persons subject to EU restrictive measures, in this instance the President of Russia. 

The national authority relied, inter alia, on the company’s ownership structure. Inter Rao Lietuva was indirectly owned by Inter Rao, a company incorporated under Russian law whose principal shareholders included undertakings indirectly owned by the Russian Federation.