EU Can Freeze Assets Controlled by Sanctioned Individuals

May 14, 2026 Benn-Ibler Rechtsanwälte

In a recent ruling, the Court of Justice of the European Union (CJEU) held that the assets of a company not included on the sanctions list may be frozen if that company is controlled by a listed individual.

At the end of 2020, a Belarusian national was added to the list of individuals subject to EU sanctions against Belarus. Consequently, two banks froze the assets of a Lithuanian company not included on the list on the grounds that 50% of its capital was held by the sanctioned national. An action brought by the company seeking the release of the assets was dismissed. Questions regarding the possibility of freezing the funds of a legal person or organisation not included on the list were referred to the CJEU for a preliminary ruling.

Freeze also for assets and resources of unlisted individuals

The CJEU decided that this rule also covers the assets and economic resources of companies that are not on the sanctions list, if those assets are owned, held, or controlled by someone—or an organisation or entity—who is included on the list.

The Court determined that possessing a 50% shareholding in a company’s capital confers control over both the company itself and its financial assets and economic resources.

Procedures available for listed and non-listed individuals alike

Additionally, the Court determined that Member States are required to implement a process by which legal persons, organisations, and entities whose assets or economic resources have been frozen due to alleged possession or control by a listed individual may contest the freezing action and, where justified, secure its removal.

ECJ C-84/24 (12 March 2026)