Dmitry Konov, former head of Russia’s largest petrochemical company, failed to convince the General Court that he left the Alrosa diamond board in April 2022, following a ruling that sets demanding evidentiary standards for anyone building a Russia sanctions exit case on similar grounds.
The General Court dismissed the Russia sanctions annulment action brought by Dmitry Konov on 29 April 2026. Konov, the former chairman of SIBUR Holding, Russia’s largest integrated petrochemical group, challenged his continued listing under the EU’s Ukraine-related restrictive measures. The court upheld both the September 2024 and March 2025 renewal decisions, dismissing his EUR 500,000 moral damages claim.
Konov was first listed under the Russia sanctions regime in March 2022, days after attending the 24 February Kremlin meeting at which Putin briefed a select circle of influential Russian businessmen. Since 2023, his listing has rested on the fact that he remained a member of the supervisory board and strategic planning committee of Alrosa, the state-owned diamond company whose profits flow directly to the Russian government.
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The Alrosa Dispute
Konov’s Russia sanctions exit case rested on his resignation from the Alrosa supervisory board on 14 April 2022, weeks after his initial listing, and had played no role there since. To prove this, he produced seven documents backing his case: two Alrosa corporate secretary attestations (January and September 2023); a letter from Russian audit firm FBK (October 2024); a letter from the Moscow Stock Exchange (February 2025); a legal opinion from White & Case Kazakhstan (February 2025); the resignation letter itself, dated 14 April 2022; and a Central Bank of Russia letter (March 2025). The General Court found all seven insufficient.
The two Alrosa corporate secretary attestations had already fallen short in the December 2024 judgment in the predecessor case T-326/22. Both were prepared ex post, at Konov’s request, for litigation purposes, and neither rested on contemporaneous documentation. The same finding applied here.
The resignation letter presented the most striking problem, as Konov submitted it for the first time in his April 2025 reply brief, three years after the alleged resignation, two years after the Alrosa listing ground was introduced, and with no mention of it in any prior exchange with the Council. The letter carries no company stamp and no registration number. Courts treat late production without explanation as a credibility problem, and this time was no exception.
The FBK audit letter stated that Konov had ceased his Alrosa functions on 14 April 2022. It must be noted that FBK is a registered Russian auditor. The problem was not its status itself, but rather that the letter described underlying corporate documents in general terms without identifying or producing them. The court could not verify the assertions, and found that description of evidence is not evidence.
The Moscow Stock Exchange letter reported that, based on information Alrosa had provided to the Exchange, Konov was no longer a board member since April 2022. Again, the documents Alrosa sent to the Exchange were not attached, and the court had no way to verify their content.
The White & Case Kazakhstan legal opinion discussed minutes of Alrosa board meetings showing Konov’s absence from 2022 onwards. The problem arised from the fact that the law firm had been allowed to inspect those minutes but not copy them. Most of the relevant documents were described by counsel, not reproduced as exhibits. The court declined to treat counsel’s account of confidential documents as independent proof.
The Central Bank of Russia letter stated that the bank held no information about Konov’s board membership since 30 June 2022. The court read this narrowly. Absence of information is not confirmation of departure. The two are not the same.
Three Rules for Sanctions Exit
This judgment is the most granular treatment the General Court has produced of what evidence is and is not sufficient to prove that a listed person has genuinely left a role:
- Contemporaneous documentation is essential. Post hoc attestations carry minimal weight, even from senior officers or registered auditors, unless they reproduce the primary records that generated the underlying information.
- Independent verification is required. Letters from institutions relying on documents supplied by the interested party do not count as independent verification. Alrosa providing records to FBK, or to the Moscow Stock Exchange, simply creates another layer of unverified assertion. The intermediary adds no epistemic independence.
- Timing and consistency matter. A resignation letter surfacing in reply briefs, three years after the event and two years after the relevant listing ground appeared, will face scepticism regardless of its face validity. Consistency across the administrative and litigation record is part of the credibility assessment.
These standards have immediate practical relevance beyond Konov’s own case, as the EU Russia sanctions list now covers over 2,200 individuals and entities. Many of the March 2022 listings are now entering their fourth year, and an increasing number of listed individuals will seek delisting by arguing that their circumstances have changed, by having resigned from boards, sold stakes, relocated, or otherwise cut ties with the networks that justified their original listing.
Konov’s case shows that the evidentiary bar for proving changed circumstances is substantially higher than producing a package of attestations, opinions, and third-party letters. The primary documents must be produced, and description of these documents is not valid by itself. The contemporaneous record must also support the claimed timeline, and the litigation strategy must be consistent from the administrative review stage onwards.
Konov’s Parallel Attempts
Konov also raised three further grounds, all dismissed. On procedural rights, the Council had informed him of each renewal intention and given him multiple opportunities to respond. The fact that the Council renewed the measures one week after receiving his March 2025 letter did not violate his right to be heard, as the Council is not required to respond to pre-renewal observations before acting.
On proportionality, the court restated settled case law. The Russia sanctions framework targets influential businesspeople because of their potential leverage over the Russian government. The Council does not need to prove this leverage mechanism works, only that it is plausible. Konov’s arguments did not displace that logic.
On fundamental rights (property, privacy, free enterprise) the court found no violation. All restrictions flow from a legal basis and pursue a legitimate objective within the EU Charter framework. Konov raised no argument that had not already been rejected in T-326/22.
Konov has a parallel action at T-802/25 challenging the September 2025 renewal decisions, with the case at an early stage. Today’s judgment not only gives the Council a comprehensive factual and legal record to rely on, but also makes his sanctions exit case begin its next chapter in a weaker position than it started this one. Short of producing the Alrosa board minutes themselves, his evidentiary position, and employment of new documentation (the resignation letter) whose veracity is doubted by the tribunal, will make any new evidence submitted by Konov subject to a higher scrutiny.
