Amid the ongoing confrontational rhetoric between Russia and the West, there is an increasing number of instances in which individuals targeted by sanctions achieve exemptions—not for political reasons, but as a result of painstaking legal work. While the political agenda remains unchanged, a growing trend in the legal sphere demonstrates that sanctions are not a death sentence, but rather a tool whose effectiveness depends on the strength of its evidentiary foundation.
For instance, in March the European Union revised its sanctions list, simultaneously removing several Russian citizens. Among those delisted were Sports Minister Mikhail Degtyaryov, businessman Vyacheslav Kantor, Gulbahor Ismailova—the sister of Alisher Usmanov—and Vladimir Rashevsky, the former head of EuroChem. In Rashevsky’s case, for example, the lifting of sanctions resulted not only from legal proceedings but also from public pressure that proved his negligible impact on the processes for which he had previously been penalized.
A similar approach was taken by Mikhail Fridman’s legal team, which succeeded in winning a case before the Court of Justice of the European Union. However, despite this legal victory, his formal removal from the sanctions list remains pending—a reminder that the mechanisms of sanctions are subject to both legal and political considerations.
Against this backdrop, the case of Karina Rotenberg—a U.S. citizen and wife of Russian businessman Boris Rotenberg—has attracted special attention. In 2022, she was included on the SDN list as part of an extended pressure targeting families connected with Russian business. However, on April 2, 2025, the U.S. Treasury officially removed her from the list.
This case, devoid of political overtones, underscores the institutional resilience of the American system. Her defense was able to demonstrate that her inclusion on the sanctions list did not meet the domestic legal criteria applied to U.S. citizens. Thorough work by her attorneys, her lack of direct involvement in the sanctionable grounds, and obvious procedural errors in the original decision all contributed to her removal.
As in other examples, it is precisely the availability of effective legal mechanisms, the possibility of appeal, and procedural transparency that make such cases possible. The experiences of Rotenberg, Rashevsky, and others clearly show that despite an overall hardline stance, sanctions policies in the U.S. and EU remain accountable to legal norms. This does not signal a thaw in relations between states; rather, in times of diplomatic tension, the legal system emerges as the sole reliable channel for reassessing sanctions—defining exactly where politics ends and law begins.