EU General Court Annuls Council Sanctions Listing for the First Time on Grounds of Non-Compliance with a Prior Court Judgment

On 11 February 2026, the General Court of the European Union delivered a landmark judgment in Case T-693/25 (Tokareva v Council). For the first time in European sanctions practice, the Court explicitly held that the Council of the EU had violated Article 266 of the Treaty on the Functioning of the European Union by re-listing Maya Tokareva on the sanctions list without remedying the procedural deficiencies previously identified by the Court. The Court ruled that such actions contravene EU law and constitute a failure to comply with the binding obligation to give effect to judicial decisions.

Background

Maya Tokareva was included in the EU sanctions list pursuant to Council Regulation (EU) No. 269/2014, which provides for restrictive measures, including asset freezes, against persons associated with the Russian Federation’s violation of Ukraine’s territorial integrity. The basis for the applicant’s listing was her family ties: Maya Tokareva is the daughter of Nikolai Tokarev, President of Transneft and a close associate of Vladimir Putin.

The applicant challenged the sanctions before the General Court of the European Union. In her prior proceedings, the Court had already found that the Council failed to provide sufficient justification for Tokareva’s inclusion on the sanctions list and annulled the relevant Council acts accordingly.

Nevertheless, the Council re-listed her and extended the restrictive measures without remedying the deficiencies previously identified by the Court.

By its judgment of 11 February 2026, the Court annulled, insofar as they concern Maya Tokareva, Council Decision (Common Foreign and Security Policy) 2025/1895 and Council Implementing Regulation (EU) 2025/1894.

The Court’s Reasoning

The Court found that the Council of the EU had failed to take the measures necessary to give proper effect to the earlier judicial decisions. Specifically, in order to re-list the applicant on the sanctions lists, the Council was required either to rely on new facts or to identify new circumstances capable of establishing that the listing was justified.

Significance of the Precedent

This judgment is of particular significance: for the first time in EU sanctions practice, the Court expressly held that an institution’s failure to comply with a judicial decision constitutes a violation of Article 266 of the Treaty on the Functioning of the European Union.

While EU courts have previously annulled sanctions listings on numerous occasions, in the present case the Court separately established that the Council’s inaction in implementing judicial decisions constitutes a breach of EU law in its own right, and that the obligation to comply with court judgments is a fundamental element of the EU legal order and a prerequisite for effective judicial protection.

Sources

• Judgment of the General Court of the EU of 11 February 2026 in Case T-693/25 (Tokareva v Council)
• Judgment of the General Court of the EU of 11 September 2024 in Case T-744/22 (Tokareva v Council)
• Council Regulation (EU) No. 269/2014
• Article 266 of the Treaty on the Functioning of the European Union