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ARTICLE · 22 SEPTEMBER 2026

How EU Sanctions Can Affect An Unlisted Company

AGPLAW | A.G. Paphitis & Co. LLC
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Two recent European Court judgments clarify when EU sanctions can freeze an unlisted company's funds through ownership or control by a listed person. The Inter Rao Lietuva and Abramovich cases establish different evidentiary standards and challenge routes, requiring businesses to understand the specific legal basis for any payment restriction.

European UnionInternational Law
Angelos Paphitis
Angelos Paphitis
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A company does not have to appear on an EU sanctions list for its funds to be frozen. Ownership or control by a listed person can also bring it within the restrictions. For a business facing a blocked payment, the first question is therefore straightforward: what is the legal reason for the restriction?

A useful sanctions review should identify the person, assets and transaction involved, then the exact rule relied on.

Two September judgments help explain why that question matters. Inter Rao Lietuva concerns evidence that a listed person controls a company. Abramovich concerns the Council’s decision to keep an individual on the sanctions list. They address different situations, with different arguments and different routes to challenge.

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