Russia’s invasion of Ukraine in February 2022 led the EU to expand its sanctions list under Council Regulation (EU) No 269/2014, freezing the funds and economic resources of every individual added to it.
Several of those individuals had, in advance of being listed, placed valuable assets into trusts. The question this opened, and on which the courts had until recently said little, was whether the freeze reaches assets held in a trust where the trust deed formally excludes the sanctioned individual from any right to use or benefit from those assets. On 21 May 2026, the Court of Justice of the EU answered the question across three judgments delivered on the same day. In Case C-483/23 (T Trust), the First Chamber addressed the position of the settlor; in the joined references in Case C-428/24 (FZAR) and Case C-476/24 (SX), it addressed the position of the beneficiary. Together, the three rulings articulate a single working test: the freeze reaches trust-held assets wherever the sanctioned person retains, in law or in fact, the power to use those assets, to benefit from them, to dispose of them or to influence the trustee in relation to them.
