Regarding the Judgment of the Court of Justice of the European Union in Case C-147/25 between AB “INTER RAO Lietuva” and the Financial Crime Investigation Service
On 3 September 2026, the Court of Justice of the European Union (hereinafter – the CJEU) delivered a preliminary ruling in Case C-147/25, concerning a dispute between AB “INTER RAO Lietuva” (hereinafter – the Company) and the Financial Crime Investigation Service under the Ministry of the Interior of the Republic of Lithuania (hereinafter – the FCIS). The Supreme Administrative Court of Lithuania (hereinafter – the SACL) had requested the CJEU to provide an interpretation on the application of EU legal acts regarding sanctions. In February 2025, the SACL had stayed administrative case No. eA-24-821/2026, which concerns the Company’s dispute with the FCIS regarding the Company’s inclusion on a list of entities linked to persons subject to EU restrictive measures, as well as the freezing of the Company’s funds.
The CJEU ruled that when a national authority freezes the funds of a company not explicitly named in EU sanctions lists, it must demonstrate that those funds belong to, or are managed or controlled by, a person subject to EU restrictive measures; the mere existence of links to such a person is insufficient. Control of a company by such a person—including informal control—must be substantiated by objective and sufficiently robust evidence; the mere nature of the Russian political regime does not constitute sufficient proof that the President of Russia controls the company. SACL will deliver the final ruling in the case, guided by this interpretation from the CJEU. Pending the SACL’s decision, the decisions taken by the FCIS regarding the Company remain in effect. The Company will provide an update once the SACL has issued its ruling.