EU General Court rejects Timchenkos’ delisting applications

10 December 2025

The EU General Court has rejected Gennady and Elena Timchenko’s applications to annul their relistings on the EU’s Russia sanctions list. Both have previously challenged their designation and relistings, most recently in appeal cases rejected in August 2025.

Gennady Timchenko – Case T-285/24

The EU sanctioned Mr Timchenko in February 2022 under designation criteria (a) (responsible for supporting actions which undermine the territorial integrity of Ukraine etc) and (d) (supporting or benefitting from Russian decisionmakers responsible for the destabilisation of Ukraine) in Regulation 269/2014.  The reasons for his designation in 2022 said he met both criteria because of his shareholding in the Volga Group and Bank Rossiya which provided services for the Russian State. In 2023, the reasons were amended to add that he was a “leading businessperson in Russia”, so he met designation criterion (g) of Regulation 269/2014 as well as criteria (a) and (d). He applied for the court to annul a March 2024 regulation which maintained his name on the EU’s Russia sanctions list for the same reasons as in 2023.

In his previous delisting application, Mr Timchenko had challenged his pre-September 2023 designations, which were based on criteria (a) and (d). In that case, and on appeal, the EU courts rejected his application and said that Mr Timchenko met designation criteria (a) and (d) because he had not distanced himself from or objected to the activities of Bank Rossiya.  In this case challenging his 2024 re-listing, Mr Timchenko made the same arguments in relation to criteria (a) and (d) and added two arguments on criterion (g) – that it is an unlawful criterion and that it should not have been applied to him.

The General Court rejected his application after determining that Mr Timchenko met designation criterion (d), so it did not consider his arguments on criterion (a) or the illegality and application of criterion (g) because, even if the criterion had been illegal or not applied, Mr Timchenko would have remained designated under criterion (d). He met criterion (d) because he indirectly owned around 10% of Bank Rossiya and, since Bank Rossiya is the “personal bank of senior Russian officials”, that showed he provided financial support to Russian decision makers responsible for the destabilisation of Ukraine. A Russian law granting him tax exemptions demonstrated that he received a benefit from Russian decision makers responsible for the destabilisation of Ukraine.

Mr Timchenko’s first delisting application (Case T-252/22) and appeal (Case C-703/23) were rejected. Mr Timchenko’s second delisting application (Case T-297/23) is currently under appeal (Case C-297/33). He has also applied for the court to annul his September 2024 listing (Case T-603/24).

Elena Timchenko – Case T-1107/23

The EU sanctioned Elena Timchenko in April 2022 because she was said to be associated with Mr Timchenko (her husband) through her participation in his public affairs via the Timchenko Foundation, her business activities carried out with her husband, and the property she held jointly with him. She has been relisted each March and September since her designation on the same basis.

Her first delisting application was rejected at first-instance (Case T-361/22) and on appeal (Case C-703/23). The court said Ms Timchenko was not designated because she was Mr Timchenko’s wife but because of “association” arising from her participation in Mr Timchenko’s public affairs.

In this case, she applied for the court to annul the September 2023 and March 2024 acts re-listing her. She challenged the September 2023 re-listing on the ground that the Timchenko Foundation was not related to her husband’s public affairs. And the March 2024 regulation on the grounds that the EU ought to have considered the fact that she had resigned from the Timchenko Foundation in December 2023. The EU General Court rejected her application because:

• The Timchenko Foundation benefitted from other companies owned by Mr Timchenko and was “a communication tool serving the public image of the Timchenkos”. The mutual participation of Mr and Ms Timchenko in the Foundation was evidence of her association with Mr Timchenko [106].

• Although she had resigned from the Timchenko Foundation in December 2023, she had retained “substantial powers” within the Foundation by virtue of the Foundation’s charter in March 2024. Although she provided evidence that the Foundation’s charter had been altered in April 2024 to reduce her powers, the Court could not consider this in assessing the lawfulness of her March 2024 relisting because the change occurred after the passage of the challenged regulation [126].

She has an application pending (Case T-602/24) to annul her September 2024 re-listing.