I. Introduction

Judicial review of European Union sanctions has become a recurring feature of EU litigation since the expansion of restrictive measures following Russia’s invasion of Ukraine in 2022. Numerous individuals, companies, and financial institutions have sought annulment of EU listings before the General Court of the European Union, challenging both the factual basis and the legal justification of their designation.

The Case T-898/25, Alfa-Bank v Council represents another challenge to the EU’s sanctions regime targeting Russian economic actors. The Russian Alfa-Bank brought it before the General Court on 30 December 2025, seeking the annulment of measures adopted by the Council of the European Union that subject the applicant bank to restrictive measures under the EU’s sanctions framework.

Although the proceedings are still pending, the action raises fundamental questions regarding the scope of judicial review in EU sanctions cases and the protection of fundamental rights of targeted entities.


II. The Facts

The applicant, Alfa-Bank, brought proceedings before the General Court seeking the annulment of two EU acts adopted by the Council of the European Union as part of the EU’s sanctions regime concerning Russia.

More specifically, the action seeks the annulment of:

  • Council Regulation (EU) 2025/2033
  • Council Decision (CFSP) 2025/2032

These “contested acts” amend the EU’s sectoral sanctions regime targeting Russia, originally established through:

  • Regulation (EU) No 833/2014
  • Annex VIII to Council Decision 2014/512/CFSP

According to the Official Journal notice, Alfa-Bank asks the General Court to annul the “contested acts” in so far as they concern the applicant.

The notice contains two pleas in law:

  1. The first plea focuses on illegality and inapplicability under Article 277 TFEU of Art. 5h(1) of Regulation (EU) No 833/2014 and Art. 1e of Decision 2014/512/CFSP, stating reasons such as, inter alia, circumventing and breaching of procedural safeguards by Regulation (EU) No 269/2014, failure to state reasons and the breach of the principles of legal certainty and effective judicial protection.
  2. The second plea alleges an error of assessment by the Council in applying the sanctions regime to the applicant.


III. The Legal Issues

The proceedings raise several legal issues that are characteristic of EU sanctions litigation.

1. Jurisdiction and Procedural Framework

The action is brought before the General Court under Article 263(4) TFEU, which allows natural or legal persons to institute proceedings for annulment against EU acts addressed to them or acts of direct and individual concern.

Because one of the contested measures is a decision adopted under the Common Foreign and Security Policy (CFSP), the Court’s jurisdiction must also be understood in light of Article 275(2) TFEU, which specifically provides for judicial review of CFSP decisions imposing restrictive measures on natural or legal persons.

Accordingly, the EU Courts have jurisdiction to review the legality of both the regulation and the CFSP decision challenged by Alfa-Bank.

2. The Lawfulness of the Council’s Assessment

A central issue in sanctions litigation concerns whether the Council has correctly applied the listing criteria and relied on a sufficiently solid factual basis when adopting restrictive measures.

The General Court will therefore examine whether the Council committed an error of assessment in determining that the applicant should fall within the scope of the amended sanctions framework.

This review forms part of the Court’s established case law requiring the Council to justify restrictive measures with evidence capable of substantiating the reasons relied upon.

3. Fundamental Rights and General Principles of EU Law

Sanctions litigation frequently involves arguments based on general principles of EU law, including:

  • the principle of legal certainty, and
  • the right to effective judicial protection.

The applicant’s pleas suggest that the contested measures allegedly infringe these principles. If established, such violations could lead the Court to annul the measures in so far as they apply to the applicant.


IV. Conclusion

The action in Alfa-Bank v Council represents another example of the increasing role played by EU courts in reviewing restrictive measures adopted in the context of the Union’s foreign policy.

By challenging amendments to the EU’s Russia sectoral sanctions regime, the case raises important questions concerning the Council’s assessment when applying sanctions, such as the evidentiary standards required for restrictive measures, and the procedural safeguards available to targeted entities.

As sanctions continue to constitute a central instrument of EU external action, sanctions litigation will remain crucial in defining the boundaries between the EU’s foreign policy objectives and the protection of fundamental rights within the EU legal order.

We will monitor the proceedings and report on any new developments.