On 26 February 2026, ECJ Advocate General, Manuel Campos Sanchez-Bordona, issued an opinion dealing with the blocking of assets of a Russian state-owned/controlled company (which is not subject to EU blocking sanctions) on the basis of such a company being controlled by President Putin (who is subject to EU blocking sanctions).
The context of the opinion is as follows.
The Lithuanian national competent authorities set up a national list of entities which are not listed on Annex I to Regulation 269/2014, but are, nevertheless, deemed by them to be subject to EU blocking sanctions due to being controlled by blocked persons listed on Annex I.
One of the companies listed by the Lithuanian authorities was Inter Rao Lithuania AB. It is a 100% (indirect) subsidiary of Inter Rao UES, a Russian state-controlled/owned energy company. The reason for this listing was alleged control of Inter Rao Lithuania AB by President Putin. The argument for establishing such a control was, in essence, that in an autocratic country, like Russia, its President shall be automatically deemed to control all state-controlled/owned Russian companies operating in the strategic sectors of Russian economy, including the electricity sector.
Advocate General rejected this approach (see paras. 76 and 77 of the opinion). He disagreed that the Russian political regime should automatically translate into “control” over all state-owned companies by the Russian President within the meaning of Regulation 269/2014. The relevant criterion to establish such a “control” shall be the presence of evidence which is “sufficiently specific, precise and consistent” (see, e.g., para 84 of the opinion). This is same criterion which is applied by the EU Courts when hearing annulment applications issued by persons subject to blocking sanctions.
For further information on the concept of control in the EU sanctions, please see our videos here and here.