How Putin’s inner circle engineered a legally bulletproof system to keep earning billions from EU trade – while the bloc debates whether it can stop them.
When The Insider published its exposé in December 2024 on oligarchs close to Putin continuing to earn billions from European trade, the response was swift: the EU acknowledged the problem, pledged to close the loopholes, and added names to the sanctions lists. Four months later, the picture is more complex – and more troubling.
Some loopholes have narrowed. But others have deepened. The EU tightened a few evasion mechanisms – yet also approved, knowingly, the unfreezing of frozen assets to compensate an Austrian bank that lost a case in a Russian court. And a new investigation published in March 2026 reveals that alumina produced at an Irish plant owned by a sanctioned oligarch is ending up on the production line for Russian cruise missiles.
What was a ‘loophole’ in 2022 has become, by 2026, a structured strategy — engineered by lawyers, shell companies, and buy-back contracts designed from the outset to withstand legal scrutiny.
The Rule That Explains Everything: The 50% Threshold
To understand how sanctioned oligarchs continue collecting profits from European trade, you need to understand one foundational rule: sanctions against an individual do not automatically extend to a company in which they hold less than 50% of shares.
The EU updated this definition in July 2024: the threshold is now exactly 50%, and includes aggregation – meaning two sanctioned shareholders at 30% and 25% respectively trigger a block. But as long as direct ownership stays below 50%, the company continues to trade freely.
The oligarchs understood this rule before the EU formally published it. Many reduced their stakes to precisely the level that allows free operation – not through genuine divestment, but while retaining control via buy-back contracts, nominee shareholders, and loyal board members.
| Evasion Method | How It Works | Who Uses It |
| Stake reduction to 49% | Sells to a trustee with a buy-back option | Usmanov, Melnichenko |
| Transfer to family member | Spouse, child, parent — none sanctioned | Litvinenko/PhosAgro, Skoch family |
| Swiss or UAE shell intermediary | Exports routed through neutral company | Rusal/Switzerland, Metalloinvest/Dubai |
| Unsanctioned EU subsidiary | European plant directly owned — not on the list | Deripaska/Aughinish, Kubikenborg |
The Profiles: What Has Changed Since December 2024
1. Oleg Deripaska – From Irish Alumina to Russian Rockets
Deripaska is the defining case of 2026. While he personally is sanctioned by the EU, UK, US, and Australia, Rusal – in which he holds around a quarter of shares – continues to operate without restriction.
March 2026: A joint investigation by iStories, OCCRP, and The Irish Times traced the full supply chain. The Aughinish Alumina refinery in County Limerick, Ireland – Europe’s largest alumina refinery – ships raw material to Rusal’s smelters in Krasnoyarsk. The alumina is processed into aluminum. A trading company called ASK then sells that aluminum to more than 40 EU-sanctioned companies owned by Rostec – manufacturers of surface-to-air missiles, rocket systems, and long-range bombers. According to leaked data, ASK earned approximately $337 million from sales to Russian defence contractors between February 2022 and April 2025.
Alumina is not on the EU’s list of sanctioned goods. Its sale to Russia is not prohibited – even when it ends up, step by step, on the production line of a missile that strikes a Ukrainian city.
In Sweden: prosecutors opened a criminal investigation against senior managers at the Kubikenborg Aluminium plant – owned by Rusal – on suspicion of breaching EU sanctions. The plant generated approximately $72 million for Rusal since 2022, part of which may have funded weapons production.
And from Brussels: a draft of the EU’s 19th sanctions package in October 2025 included a plan to release approximately €2 billion in frozen Strabag shares linked to Deripaska, to compensate Raiffeisen Bank International for a Russian court ruling against it. In other words: the EU was considering handing back to Deripaska an economic benefit obtained via the very court system of the regime sanctions were designed to confront.
2. Alisher Usmanov – The Network That Keeps Running
Usmanov reduced his stake in USM Holdings to 49% before sanctions hit. In 2025, the US and UK tightened pressure – OFAC designated 25 individuals and 29 entities that helped him manage his asset network, including the Liechtenstein-based Sequoia Treuhand Trust.
But Metalloinvest – Russia’s largest iron ore company – continues to export to the EU. The Lebedinsky Mining and Processing Plant sold approximately $150 million to Italy, Spain, and Poland in H1 2024, and continued through 2025. Usmanov’s business partner in Metalloinvest, State Duma deputy Andrei Skoch, is sanctioned – but the business is registered in the names of his father Vladimir and daughter Varvara, neither of whom faces EU restrictions.
3. Guryev-Litvinenko and PhosAgro – When the Wife Is the Shield
PhosAgro, Russia’s largest phosphate fertilizer producer, continues to export to the EU. The reason: Vladimir Litvinenko – who ghost-wrote Putin’s doctoral dissertation and holds over 19% of the company – is not sanctioned. His wife Tatyana, to whom he transferred more than 20% of shares in 2022, is also not sanctioned.
The EU sanctioned Andrei Guryev Jr. (the CEO), who stepped down. But the Guryev family still controls roughly half of PhosAgro through trusts and Cypriot holding structures. Litvinenko himself – whose fortune doubled to $3 billion since 2022 – continues to provide political cover.
Finland, through which some exports flow, asked Finnish Customs how an oligarch’s exports continued to transit. The customs authority’s response: ‘If we cannot demonstrate that the product, person, or company is subject to sanctions, we will not intervene.’
4. Timchenko and SIBUR – Court Win in Vienna, Exports Continue
Gennady Timchenko – widely referred to as ‘Putin’s wallet’ – holds 23.49% in Novatek and 17% in SIBUR. The majority owner, Leonid Mikhelson, is not EU-sanctioned. So SIBUR exports freely.
The EU General Court dismissed appeals by Timchenko and his wife challenging their listings – affirming the sanctions were lawful. But the ruling changed nothing in practice: SIBUR continued shipping propane-butane to Poland, Latvia, the Netherlands, Slovakia, Romania, and Hungary. In H1 2024 alone: $119 million.
5. Abramovich and Nornickel – ‘Neutral,’ But Still Exporting
Roman Abramovich — shielded from US sanctions at Zelensky’s request in 2022 due to his peace mediator role — holds 28.64% in Evraz and a stake in Nornickel. Both continue to export to Europe.
Nornickel, the world’s largest producer of nickel and palladium, is run by Vladimir Potanin — not EU-sanctioned. Public debate continued in Finland in 2025 over the Norilsk Nickel Harjavalta plant, which channels tens of millions of euros back to the Kremlin indirectly.
The Numbers: €2 Billion in Metals Alone in 2025
Despite all sanctions packages, the EU purchased approximately €2 billion in metals from Russia in 2025 – primarily semi-finished steel products. Irish alumina exports to Russia grew 55% in 2024 versus 2023.
| Company | What Is Exported to/via Europe | Est. Value 2024–2025 |
| Rusal (Deripaska, ~25%) | Alumina from Ireland to Russia; aluminum to Germany, Czech Republic, France | $376M (Ireland→Russia, 2024) |
| Metalloinvest (Usmanov, 49%) | Iron ore to Italy, Spain, Poland | $150M+ (H1 2024) |
| PhosAgro (Guryev-Litvinenko) | Phosphate fertilizers to Netherlands, Germany, France, Romania | Undisclosed |
| EuroChem (Melnichenko) | Fertilizers to Belgium, Lithuania, Italy, Spain | Undisclosed |
| SIBUR (Timchenko/Mikhelson) | Propane-butane to 8 EU states | $119M (H1 2024) |
| Evraz (Abramovich, 28.6%) | Steel to France and Czech Republic | Undisclosed |
What Remains Unresolved: Three Loopholes Still Open
First – ‘control’ versus ‘ownership’: The EU recognizes ‘control’ as a basis for blocking — but proving control is far harder than proving ownership. Oligarchs use complex commercial arrangements written specifically to avoid meeting the legal definition.
Second – neutral intermediary liability: When alumina passes through a Swiss neutral company, the EU must prove a direct link — which is often blocked commercially or legally.
Third – the race between expanding sanctions and asset transfers: Each time someone is added to the list, there can be hours or days during which assets can be moved. OCCRP investigations suggest transfers were planned in advance, before formal designation.
As long as there is no mandatory full beneficial-ownership disclosure, and as long as Russian courts can compel Western banks to transfer assets – the game continues.
Sources
iStories / OCCRP / The Irish Times, March 2026: Aughinish–Rusal–Rostec supply chain investigation.
The Insider, December 2024: Original minority-shareholder exposé.
RBC Ukraine, October 2025: EU metals purchases from Russia.
OFAC, 2025: Usmanov network designations (25 individuals, 29 entities).
Swedish Prosecution Authority, March 2026: Kubikenborg criminal investigation.
Finnish Customs Authority statement on PhosAgro transit.
EU General Court ruling on Timchenko appeals, 2025.