EU Sanctions Delisting Lawyer – Removal from the EU Sanctions List (Council/EU)
Legal Excellence
Being listed under EU sanctions has immediate and severe consequences: asset freezes, reputational damage and restrictions on business activities. Individuals, companies and shipowners placed on EU sanctions lists can seek removal (“delisting”) through administrative or judicial channels. As specialised lawyers, we advise and represent clients in delisting proceedings before the Council of the European Union and the General Court of the European Union, ensuring precise compliance with time limits and procedural rules.
Delisting Routes – Administrative vs. Judicial
Administrative Route — Council Reconsideration
Listed persons and entities may request reconsideration by the Council. Updated facts and evidence (e.g. business records, AIS data, contractual documents, financial information) can be submitted.
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The Council must state reasons and review the evidence.
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EU autonomous listings are reviewed at least every 12 months; delisting may occur as part of that periodic review.
→ We prepare comprehensive submissions to the Council, addressing both factual and legal grounds for removal.
Judicial Route — Action for Annulment (General Court)
Affected persons and entities may bring an action for annulment under Article 263 TFEU before the General Court.
Time limits: two months + 10 days (distance). If published in the Official Journal of the EU (OJEU), the two-month period starts after a 14-day standstill from publication. If individually notified, the period runs from notification.
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No automatic suspensive effect: sanctions remain in force pending judgment. Interim measures (Art. 278 TFEU) are possible only in exceptional cases.
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The Court checks compliance with deadlines ex officio; late filings are inadmissible.
→ We draft and file annulment actions, interim measures and appeals, tailored to the evidentiary and procedural standards of the General Court.
Advice on financial transactions
Release of money, securities and other funds
Delisting from the sanctions list
Derogation requests and zero notifications
Criminal defence in cases of violations
Representation in fine proceedings
Litigation before national courts and the GC/CJEU
Legal opinions and statements on complex matters
Governance with sanctions and AML regulations
Drafting of contracts and T&C clauses
Companies and Vessels under EU Sanctions
EU sanctions target not only individuals but also companies and corporate entities (banks, energy firms, logistics operators, IT providers) as well as vessels and shipping operators under Regulations 269/2014 and 833/2014. Being listed can block access to capital markets, freeze assets, restrict insurance and financing, or disrupt operations and port access.
We represent both companies and shipowners in challenging such listings, preparing delisting requests and pursuing annulment actions before the General Court. We also advise on exemptions for essential payments, maintenance of operations or safety-critical activities.
Case Law & Precedents
The General Court has already annulled several listings, for example in the Fridman (T-301/22) and Aven (T-300/22) cases. The Court held that the Council’s reasoning and evidence were insufficient. These rulings illustrate that judicial review is real and effective – but also highlight the importance of detailed submissions and adherence to deadlines.
Why Kronsteyn
We combine in-depth expertise in EU sanctions law with proven experience before EU institutions and courts.
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Preparation of delisting requests and Council submissions
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Annulment actions before the General Court (Art. 263 TFEU)
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Applications for interim measures (Art. 278 TFEU)
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Exemption requests (e.g. Art. 4 Reg. 269/2014)
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Special focus on company and vessel listings under Reg. 833/2014
Precise, solution-oriented advice that translates complex legal issues into commercially workable strategies.
Contact
For corporates, financial institutions, HNWIs and shipowners—advice and representation in Council reconsideration and actions for annulment before the General Court.
Contact EU Sanctions Delisting Lawyer Hendrik Müller-Lankow to discuss your case and the appropriate strategy.
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