UK High Court rejects Sarvar Ismailov’s de-listing case including challenge to ‘family member’ association criterion

19 May 2026

The High Court has dismissed Sarvar Ismailov’s challenge to the UK’s decision not to de-list him under the Russia (Sanctions) (EU Exit) Regulation 2019 – Ismailov v FCDO [2026] EWHC 1188 Admin. All UK sanctions judgments are on the UK-judgments section of the site.

Mr Ismailov is the nephew of UK-sanctioned Alisher Usmanov. In 2022, the UK broadened its designation criteria under the Russia Regulations to include “specified immediate family members” in the definition of “associated with” (reg 6(2)(d) of the Russia Regulations). The UK designated Mr Ismailov in 2022 on the grounds that he was associated with Mr Usmanov.

Mr Ismailov challenged the decision to maintain his designation by the UK Foreign Office (see our UK pages for delisting procedures). He argued that the ‘family criterion’ in the Russia Regulations was unlawful and that he should be delisted. The High Court (Mr Justice Saini) rejected Mr Ismailov’s application and held:

• Including family members within the association criterion is lawful because it operates foreseeably and the Regulations prescribe the specific circumstances in which a person may be designated based on the family association criterion, and their scope and effect is clear. Saini J referred to the Court of Appeal’s judgment in Khan on the association criterion.

• The UK was entitled to include family members within the association criterion and the UK is not bound to mirror the EU’s sanctions on Russia.

• The designation decision did not have to be made by the Secretary of State personally and a Foreign Office official could instead make the decision.

• The designation was not disproportionate, following the Supreme Court’s approach in Shvidler.

• Mr Ismailov’s designation was not irrational because the Foreign Office reviewed a wide range of evidence and the Foreign Office has a wide margin of appreciation in sanctions decisions (see Shvidler).

• The decision to designate was not arbitrary and it did not breach the UK Equality Act.