Pumpyanskaya v Council: EU sanctions annulled over error in "leading businessperson" classification

The General Court has annulled EU restrictive measures imposed on Galina Evgenyevna Pumpyanskaya in Case T-235/25, delivered on 15 October 2025, finding that the Council made an error of assessment when maintaining her name on sanctions lists. The decision provides important clarification on the application of derivative listing criteria under the EU's Ukraine-related sanctions regime.

Pumpyanskaya's name was initially added to the sanctions lists in March 2022 following Russia's invasion of Ukraine. The Council maintained her listing through successive renewal decisions, most recently by Council Decision (CFSP) 2025/528 and Council Implementing Regulation (EU) 2025/527 of 14 March 2025, which extended the measures until 15 September 2025.

The grounds for listing identified Pumpyanskaya as an "immediate family member benefitting from" her husband, Dmitry Alexandrovich Pumpyanskiy, who was classified as a "leading businessperson operating in Russia". Her husband held various senior positions, including President of the Sverdlovsk regional Union of Industrialists and Entrepreneurs and former roles with the Chamber of Commerce and Industry of the Russian Federation. He was also connected to TMK and Group Sinara, companies said to support and benefit from cooperation with Russian state authorities.

The applicant's arguments

Pumpyanskaya challenged the contested acts on multiple grounds, arguing that she was no longer an "immediate family member" of her spouse due to their separation and her residence in Dubai. She claimed financial independence following the sale of shares in Group Sinara and asserted that she derived no benefit from her husband. Additionally, she contested the classification of her husband as a "leading businessperson" under Article 2(1)(g) of Decision 2014/145, as amended by Decision 2023/1094.

The Court's reasoning

The General Court's analysis proved remarkably succinct. Rather than examining the evidence regarding Pumpyanskaya's actual relationship status, financial independence, or whether she genuinely benefited from her spouse, the Court identified a fundamental flaw in the Council's reasoning.

The decisive factor was the judgement of 10 September 2025 in Pumpyanskiy v Council (T-541/24), which found that the Council had erred in classifying Dmitry Pumpyanskiy as a "leading businessperson operating in Russia". This prior finding effectively undermined the entire basis for maintaining Pumpyanskaya's listing.

The Court held that without a valid underlying classification of her husband, the Council's decision to list Pumpyanskaya as someone benefitting from a "leading businessperson" necessarily constituted an error of assessment. The derivative nature of her listing meant that any defect in the primary classification automatically invalidated the secondary one.

Implications for derivative listings

The judgement demonstrates the vulnerability of derivative listings based on family relationships. When sanctions rest solely on association with a listed individual, the legal foundation collapses if the primary listing is successfully challenged. The Council's attempt to maintain provisional effect of the decision pending appeal was rendered moot by subsequent relisting through Decision (CFSP) 2025/1895.

This case underscores the importance of independent grounds for listing family members where possible, rather than relying exclusively on derivative criteria. The Court's refusal to examine the merits of the personal arguments regarding separation and financial independence suggests that such factors become irrelevant once the underlying classification fails.

The Council was ordered to bear its own costs and pay those incurred by the applicant, reflecting the fundamental nature of the error identified.