EU delists Fridman and Usmanov — UK and OFAC do not. Jersey risk is unchanged.

On 22 September 2026, EU ambassadors agreed to remove Alisher Usmanov (USM Holdings) and Mikhail Fridman (Alfa Group/LetterOne) from the EU individual sanctions list. EU asset freezes and travel ban on the pair lifted.

• In exchange, designations on roughly 3,000 other individuals and entities were rolled over for three years to September 2029. Latvia abstained rather than veto. That is an EU political bargain. It is not a finding that the original grounds have gone, nor does it clear them under UK or US law.

• France (with earlier Slovak support) pushed Usmanov off, citing national security — widely reported as linked to prisoner-release talks involving Azerbaijan. Luxembourg then demanded the same of Fridman, who has brought a claim widely reported to be around $16 billion against Luxembourg over frozen assets. Ireland’s EU presidency called it “a difficult compromise.” Ukraine condemned it.

London and Washington have not followed Brussels.

• Both men remain UK-designated persons under the Russia (Sanctions) (EU Exit) Regulations 2019 — Fridman since 15 March 2022 (RUS0664) and Usmanov since 3 March 2022 — with asset freeze, travel ban and related measures still in force.

• After the EU deal, reports from Prime Minister Andy Burnham’s 23 September meeting with President Zelenskyy say the UK disagreed with the delisting and intends to keep its own sanctions.

• Both also remain on OFAC’s SDN List under RUSSIA-EO14024 (SDN file updated 23 September 2026).

For Jersey firms, the binding lists are still the UK/OFSI list and, where there is a US nexus, the OFAC list — not the EU compromise.

UK: still designated

Jersey implements UK sanctions. Both men remain designated under the Russia (Sanctions) (EU Exit) Regulations 2019.

Mikhail Fridman

• Unique ID RUS0664 / OFSI Group ID 14615

• Designated 15 March 2022

• Asset freeze, travel ban, trust services sanctions, director disqualification, transport sanctions
  UK Sanctions List: https://search-uk-sanctions-list.service.gov.uk/
  Record still showing as a UK listing when checked against source on 23 September 2026: https://sanctions.lursoft.lv/person/-/uk-14615
  The UK updated its statement of reasons in June 2026; it did not delist him: https://globalsanctions.com/2026/06/uk-updates-basis-for-mikhail-fridman-designation/

Alisher Usmanov

• Designated 3 March 2022

• Asset freeze, travel ban, trust services sanctions, director disqualification (9 April 2025)
  Still showing as a UK listing when checked against source on 23 September 2026: https://sanctions.lursoft.lv/person/alisher-usmanov/uk-14210
  A 2026 High Court judgment still treated him as lawfully designated: https://caselaw.nationalarchives.gov.uk/ewhc/admin/2026/1188

What should firms do now?

1. Treat both as still designated for UK/Jersey and US purposes. Tag files: “EU delisted 22 Sep 2026; UK designation remains (RUS0664 Fridman / Usmanov 3 Mar 2022); OFAC SDN remains.”

2. Re-screen against OFSI and OFAC, not only the EU list. Vendor EU feeds must not overwrite UK or US hits. Confirm on the live UK Sanctions List and OFAC search before any change of status.

3. Re-run ownership and control. LetterOne, Alfa, USM, and historic structures are not automatically clear because the individuals are not on the EU list. UK control tests and OFAC’s 50 per cent rule still apply where a designated person retains ownership or control.

4. Do not release assets held for either man or for entities they own or control without a legal basis under the regime that froze them. For Jersey, that means an OFSI licence for UK-prohibited activity — not an EU delisting.

5. Expect more pressure and more national patches (Estonia has already acted; Latvia has indicated national measures). Other designated persons will copy the France/Luxembourg playbook. Document why the name stays on your applicable list even if another jurisdiction has moved.

EU delists Mikhail Fridman and Alisher Usmanov from Russia sanctions list after pressure from France, Luxembourg and Slovakia — three-year rollover for the rest

On 22 September 2026, EU member-state ambassadors agreed to remove two high-profile Russian-linked billionaires — Alisher Usmanov (USM Holdings) and Mikhail Fridman (Alfa Group / LetterOne) — from the EU’s individual sanctions list against Russia.

• Asset freezes and travel bans on the pair will be lifted. In return, the remaining designations covering roughly 3,000 individuals and entities were rolled over for three years (until September 2029) instead of the usual six months.

• Latvia, the last holdout, abstained rather than vetoed. The deal was then confirmed by written procedure.

• This is a political compromise, not a finding that the original designation grounds no longer apply.

• The EU had described Usmanov as a “pro-Kremlin oligarch with particularly close ties to Russian President Vladimir Putin” and Fridman as a “top Russian financier and enabler of Putin’s inner circle.”

• Both were designated in 2022 after Russia’s full-scale invasion of Ukraine. Both have denied the characterisation and have litigated extensively.

• The three-year lock-in is the offset. Periodic six-month renewals had given every member a regular opportunity to veto. That window is now closed until 2029 for the remaining names.

Why did the two names come off

• Usmanov: France (supported earlier by Slovakia) pressed for delisting, citing “national security” considerations. Multiple reports link the demand to discussions on prisoner releases with Azerbaijan. France has said it wishes to respond positively to international partners who approached Paris about Usmanov.

• Fridman: Luxembourg then insisted that if Usmanov was removed, Fridman should be too. Fridman has brought a very large claim (widely reported as around $16 billion / €14–15 billion) against Luxembourg over frozen assets. Luxembourg’s position was that continued EU listing would weaken its legal defence.

What was said

• Ireland, holding the rotating EU Council presidency, called it “a difficult compromise.”

• Ukraine condemned the move as unacceptable and urged member states to impose national measures instead.

• Critics, including Bill Browder, warned that it sets a precedent: member states can now extract individual delistings by threatening to collapse the whole list. Several governments accepted the deal only because the alternative was the expiration of the entire individual-sanctions package.

Compliance implications (especially for Jersey and Crown Dependency firms)

1. EU list ≠ UK / OFSI list. Jersey implements UK sanctions. An EU delisting does not automatically remove a person from the UK consolidated list or from OFSI’s Russia designations. Screening systems must continue to treat Fridman and Usmanov as designated persons under UK law unless and until OFSI/FCDO separately delist them. Do not assume “EU off = we can unfreeze.”

2. Update screening files immediately. Add a note that the individuals have been removed from the EU list with effect from the September 2026 decision, while remaining designated under other regimes. Record the source and date.

3. Ownership and control. Historical structures, trusts, LetterOne / Alfa / USM-related entities, and associates previously treated as controlled or owned by the pair still require a fresh control test. Delisting of the individual does not automatically clear related entities that were designated in their own right or that remain under the control of other designated persons.

4. Litigation and asset claims. Fridman’s claim against Luxembourg is a reminder that frozen-asset disputes can drive political delisting pressure. Firms holding or administering assets linked to either man should expect renewed legal activity and should not release anything without a clear legal basis under the applicable regime (UK first).

5. Precedent risk. Other designated persons and their advisers will study this episode. Expect more lobbying, more “national security” or “litigation exposure” arguments, and more pressure on smaller member states. Screening and EDD files should document why a name remains on your applicable list even if another jurisdiction has moved.

Actions

• Firms using automated screening should confirm that their data vendors have ingested the EU change and that UK/OFSI feeds have not been incorrectly overwritten.

• Always verify the live EU Official Journal / Council decision text and your firm’s applicable UK/OFSI, UN and US lists before changing any freeze, travel or relationship decision. EU political bargains do not rewrite other jurisdictions’ designations.

• Always check the live OFAC SDN file and the live UK/OFSI list before changing any freeze, payment or onboarding decision. Brussels does not write Washington’s list.

Sources (full URLs) re

• OFAC  
  https://sanctionssearch.ofac.treas.gov/Details.aspx?id=44291
  https://sanctionssearch.ofac.treas.gov/Details.aspx?id=42083
  https://ofac.treasury.gov/recent-actions/20230811
  https://ofac.treasury.gov/faqs/1131
  https://sanctionssearch.ofac.treas.gov/

Re EU news

• Reuters – EU renews Russia sanctions, drops Usmanov and Fridman
  https://www.reuters.com/world/eu-renews-russia-sanctions-drops-russian-billionaires-usmanov-fridman-2026-09-22/

• Reuters – EU faces backlash after lifting sanctions on Russian billionaires
  https://www.reuters.com/world/europe/eu-faces-backlash-after-lifting-sanctions-on-russian-billionaires-2026-09-23/

• BBC – Ukraine anger as EU removes Russian oligarchs from sanctions list
  https://www.bbc.co.uk/news/articles/c6dj4k98107do

• The Guardian – EU removes two oligarchs from Russia sanctions list as deadline looms
  https://www.theguardian.com/world/2026/sep/22/eu-removes-oligarchs-from-russia-sanctions-list-as-deadline-looms

• POLITICO – EU removes two Russian billionaires from sanctions list
  https://www.politico.eu/article/eu-removes-two-russian-billionaires-from-sanctions-list/

• Euronews – EU renews Russia sanctions but removes Usmanov at France’s request
  https://www.euronews.com/2026/09/22/eu-renews-russia-sanctions-but-removes-usmanov-at-frances-request

• Meduza – EU agrees to lift sanctions on Russian billionaires Alisher Usmanov and Mikhail Fridman
  https://meduza.io/en/feature/2026/09/22/eu-agrees-to-lift-sanctions-on-russian-billionaires-alisher-usmanov-and-mikhail-fridman

• bne IntelliNews – EU drops Usmanov and Fridman from Russia sanctions list after last-minute deal
  https://www.intellinews.com/eu-drops-usmanov-and-fridman-from-russia-sanctions-list-after-last-minute-deal-469474/

• Luxembourg Times – Luxembourg pushes EU to lift sanctions on Russia-linked billionaire Fridman
  https://www.luxtimes.lu/luxembourg/luxembourg-pushes-eu-to-lift-sanctions-on-russia-linked-billionaire-fridman/161771340.html

• Luxembourg Times – EU Russia sanctions renewed for 3 years as Fridman, Usmanov dropped
  https://www.luxtimes.lu/europeanunion/eu-renews-russia-sanctions-drops-russian-billionaires-fridman-and-usmanov/161902147.html

• Luxembourg Times – EU lifts sanctions on Russian billionaires Usmanov and Fridman: backlash grows
  https://www.luxtimes.lu/world/eu-faces-backlash-after-lifting-sanctions-on-russian-billionaires/162046580.html

• Le Monde (English) – EU removes two oligarchs reputedly close to Putin from sanctions list
  https://www.lemonde.fr/en/international/article/2026/09/22/usmanov-and-fridman-two-oligarchs-close-to-putin-are-exempted-from-eu-sanctions_6757821_4.html

• RFE/RL – EU Reportedly Set To Remove Sanctions On Russian Oligarchs Fridman And Usmanov
  https://www.rferl.org/a/eu-remove-sanctions-russian-oligarchs-usmanov-fridman/33860522.html

• The Insider – EU extends Russia sanctions for three years, lifts restrictions on billionaires Alisher Usmanov and Mikhail Fridman
  https://theins.press/en/news/297445

• dpa international – EU to lift sanctions against Russian oligarchs Usmanov and Fridman
  https://dpa-international.com/politics/urn:newsml:dpa.com:20090101:260921-930-722529/

• The Straits Times – EU agrees to lift sanctions on Russian oligarchs in ‘shameful’ compromise deal
  https://www.straitstimes.com/world/europe/eu-renews-russia-sanctions-drops-russian-billionaires-usmanov-and-fridman

• ABC News – EU to lift sanctions on Russian oligarchs Alisher Usmanov and Mikhail Fridman, prompting anger in Kyiv
  https://www.abc.net.au/news/2026-09-23/brk-eu-sanctions-lifted-on-oligarchs/107183784