On 22 September 2026, hours before its own deadline, the ambassadors of the EU member states finally reached an agreement and extended Russia’s individual sanctions for three years. Part of the compromise was removing several individuals who had been under sanctions since 2022. None came off through litigation. All were traded away in a room in Brussels, which makes the decision political rather than legal, and that distinction matters more than the names themselves.

The next morning the SDN list in Washington looked exactly as it had the day before, and so did the UK list. That gap between the regimes is what a client who sits on more than one list actually has to deal with.

What Brussels decided

The EU’s individual measures rest on Council Decision 2014/145/CFSP and Regulation (EU) No 269/2014, the regime built around Ukraine’s territorial integrity. It covers thousands of individuals and entities through asset freezes, travel bans and a prohibition on making funds available to them.

Until this month, the regime was rolled over every six months by unanimity, and in September 2026 that routine broke. Ambassadors failed to agree on 11 September, and on 14 September the Council bought time with a seven-day rollover. Had unanimity failed again on 22 September, the entire list would have lapsed on its own.

It did not fail. The Council prolonged the measures for 36 months, to 22 September 2029, the first three-year extension in the life of the regime, and the EU sanctions delisting of Usmanov and Fridman rode through on the same vote.

The names the Council did not print

The Council’s press release contains no names. It states that the listings of three individuals and one entity were not renewed, and that entries for three deceased persons were deleted. The annex changes were made by Council Implementing Regulation (EU) 2026/2160 of 22 September 2026.

The names came from diplomats and from reporting: Alisher Usmanov and Mikhail Fridman. Russian outlets identify the third individual as Andrei Falaleev, former rector of Crimean Federal University. No source has identified the entity so far.

The bargaining is well documented. France pressed for Usmanov, tying the delisting to the release of French nationals held in Azerbaijan. Luxembourg backed Fridman, who is pursuing an arbitration claim against the Grand Duchy of roughly 15 billion over frozen assets. Latvia held out to the last, then abstained constructively and promptly imposed its own national designations on both men.

No court delisted either man. Usmanov lost his challenges in 2024 and 2025, and Fridman won once in 2024 before being relisted on amended grounds. This EU sanctions delisting was negotiated in a closed room, not won in open court.

Washington and London did not follow

Mikhail Fridman remains on the SDN list under the RUSSIA-EO14024 program, designated on 11 August 2023. Alisher Usmanov was designated on 3 March 2022 under the same order and likewise remains. OFAC last updated the list on 18 September 2026, four days before the Brussels decision, and the entries remain untouched.

The United Kingdom has not moved either: both men remain on the UK Sanctions List, Fridman at entry RUS0664 since 15 March 2022, and Usmanov since 3 March 2022.

The broader direction of U.S. sanctions policy is also reflected in the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026 (H.R. 5334), signed on 18 September 2026, four days before Brussels acted. For vessels, section 102(c) lets the US President treat the mere fact that a ship is already sanctioned by the United Kingdom, the EU, the Group of 7, or a Five Eyes member as prima facie evidence. An ally’s listing counts toward a US designation, and the Act writes no rule running the other way. For Usmanov and Fridman, that means their exit from the EU list carries no matching presumption in Washington.

What this means if you are on the SDN list

An EU sanctions delisting delivers real things: assets frozen under the EU regime can be unfrozen, the travel ban falls away, and the other restrictions tied to EU listing no longer apply. For a client whose exposure was mainly European, that is a great deal.

For a client who stays on the SDN list, the relief is far from complete. Property in the United States, or owned or controlled by US persons, remains blocked, transactions involving that person are still off-limits under OFAC rules, and dollar access remains difficult. Secondary sanctions exposure under section 11 of Executive Order 14024 is untouched. A European bank no longer legally required to freeze the account will still screen against the SDN list and will often decline anyway, because its own exposure has not changed.

The route to delisting from the SDN list in the United States remains separate from the European procedure. After 18 September 2026, it has to be read alongside the Graham Act, which sets its own statutory requirements for several sanctions programs and preserves measures already in place. A petition for reconsideration under 31 C.F.R. § 501.807 succeeding on its own does not guarantee that every restriction can be lifted: it still has to be established whether the person falls within the Act’s mandatory provisions, and whether a waiver or termination mechanism is actually available.

The Act provides two separate mechanisms for presidential relief. Under section 115, the US President may grant a waiver, after first sending Congress a certification that doing so serves US national interests, together with a supporting report. Separately, section 117 allows sanctions to be terminated once the Act’s statutory conditions are satisfied; that decision goes through a statutory congressional review period, during which Congress may adopt a joint resolution of disapproval. For Russian nationals, the termination criteria turn mainly on the statutory conditions for a peace settlement of Russia’s war against Ukraine.

The Council’s decision can and should be put in front of OFAC, but as evidence rather than as a legal ground for removal from the US list.

One tactical shift is worth naming. Until this month, a listed person could wait for the next six-month review and hope unanimity would fail. For anyone counting on the next EU sanctions delisting round on the same terms, that window is closed until autumn 2029. The statutory routes remain open, and starting them sooner rather than later is the wiser course.