Report D-10 examines the removal of individuals and entities from European Union and United Kingdom sanctions lists. It focuses on administrative and judicial delisting mechanisms, evidentiary requirements, procedural deadlines and the practical consequences of successfully challenging a designation.

A central point of the report is that “sanctions removal” may describe several legally distinct outcomes. Annulment of an original designation, non-renewal of restrictions, amendment of the stated reasons, obtaining a licence and correcting mistaken identity are not equivalent. Even a successful court challenge concerning a previous period does not necessarily mean that no current restrictions remain.

In the EU, a designated person may submit observations and supporting evidence to the Council and challenge specific acts before the General Court. These routes need to be coordinated carefully because correspondence with the Council does not itself suspend the deadline for bringing a judicial challenge. In the UK, the ordinary route is structured differently: a designated person may seek review by the competent minister under section 23 of SAMLA, followed by judicial review of the resulting decision under section 38.

The report places particular emphasis on the evidentiary file. Where designation is based on business control, evidence should address actual management rights, economic benefit and practical influence. A formal sale of a company, resignation from a position or alteration of registry information may therefore be insufficient on its own. The documents should establish a coherent chronology showing what changed, when it changed and whether relevant links genuinely ceased.

The cases of Aven, Fridman, Timchenko and Shvidler illustrate the limits of individual judicial victories and the importance of precise legal characterization. A favourable judgment may concern only a particular act or period, while a subsequent designation or a different legal basis requires separate analysis.

ARGA ultimately proposes continuous examination of five elements: the legal basis, the challenged act, the relevant period, the evidentiary connection and the desired legal outcome. Delisting is therefore presented not as a single event but as a sequence in which each transition—from new facts to review, from annulment to current status, and from changed status to restoration of banking or commercial services—must be established separately.