EU Chemical Weapons Sanctions – the EU Council Blacklists Six Russian Individuals and One Entity Linked to the Poisoning of Alexei Navalny

15 October 2020

On 14 October 2020, the EU Council imposed sanctions (“restrictive measures”) in - the form of a travel ban and an asset freeze - against six Russian officials and one organisation (the State Scientific Research Institute for Organic Chemistry and Technology), that the EU deems responsible for the suspected poisoning of Russian opposition leader Alexei Navalny with the toxic nerve agent “Novichok”.

The above-mentioned sanctions were imposed under the EU’s chemical weapons sanctions framework, which was originally introduced in 2018, and has been previously used by the EU to sanction certain Russian officials in response to the alleged use by the Russian secret services of the “Novichok” nerve agent against Russian double agent Sergei Skripal  and his daughter Yulia Skripal. This framework has also been used to sanction certain Syrian officials and entities, accused of the use of chemical weapons.

By the Council Decision (CFSP) 2020/1482 of 14 October 2020, the EU has added the names of the six Russian officials and of the entity, targeted by the latest sanctions for the alleged poisoning of Alexei Navalny to the consolidated list of the chemical Russian targets (included in the annex to the Council Decision (CFSP) 2018/1544.

In addition, on the same day, the Council adopted a related Implementing Regulation 2020/1480 of 14 October 2020, which added the sanctioned individuals and entity to the list of targets in the amended Annex I of the Council Implementing Regulation 2018/1542, making the asset freezes against them directly applicable in all EU-Member States.

As a result of these new sanctions, EU citizens and companies will be prohibited to make any funds or economic resources available to the designated Russian officials and organisation, and to any company, entity or body owned by them for more than 50% or controlled by them de jure or de facto. All the assets of these sanctions targets, held by EU citizens or companies, have to be frozen.

In addition, the sanctioned individuals will be prohibited to enter into or transit through the territory of any EU Member State (and of the UK, which continues to apply the EU sanctions regulations until 31 December 2020).

The new sanctions are effective as of 15 October 2020, following the publication of the relevant Council Decision and Implementing Regulation in the EU Official Journal.

Link to the EU Official Journal:

Council Decision (CFSP) 2020/1482 of 14 October 2020 amending Decision (CFSP) 2018/1544 concerning restrictive measures against the proliferation and use of chemical weapons

Council Implementing Regulation (EU) 2020/1480 of 14 October 2020 implementing Regulation (EU) 2018/1542 concerning restrictive measures against the proliferation and use of chemical weapons


ACQUIS EU Law & Policy Comment:

The immediate business repercussions for European and international companies of this latest round of EU chemical weapons sanctions is expected to be rather limited, as these measures predominantly affect Russian government officials and organisations, rather than business corporations and individuals that are involved in intensive trade and business relations with the EU.

However, these designations send a strong political signal about the EU’s willingness and the readiness to further expand sanctions against Russia (and against other third countries), using different combinations of measures available in the EU sanctions toolbox.

In addition to the far-reaching financial and sectoral sanctions against Russia, imposed since 2014 in relaxation to the situation in Ukraine, the EU has also used the new cyber-sanctions and chemical weapons sanctions regimes against Russian officials and entities. In the coming months the EU is planning to further expand its sanctions toolbox by adopting a tailor-made Human-Rights sanctions framework (the so-called “EU Magnitsky Act”).

It could also be expected that the validity of Council Decision and of the Implementing Regulation, imposing these latest chemical weapons sanctions, will be challenged before the EU General Court. Russian authorities have publicly denied any involvement of Russian officials in the alleged poisoning of Navalny. Given the high standard of proof and legal reasoning, required by the EU Courts from the Council’s sanctions decisions, and the expected serious negative financial and reputational repercussions for the Russian officials and organisation affected by these sanctions, it is likely that the lawyers of the new sanctions targets will try to test the legal robustness of these sanctions measures in court.


Valerijus Ostrovskis


ACQUIS EU Law and Policy