On 15 October, the EU imposed Designated Party controls on six individuals and one entity in Russia under the EU’s Chemical Weapons sanctions regime for their alleged involvement in the poisoning of Alexei Navalny with a nerve agent in August 2020.  The EU separately designated one Russian individual under the Libya sanctions regime, for alleged breaches of the UN arms embargo against Libya.  These individuals and entities are now subject to a travel ban and asset freeze, including prohibitions on dealings by EU persons.

The individuals designated under the Chemical Weapons regime are senior government and security officials in Russia, who the EU considers to be responsible for Mr Navalny’s poisoning.  They have been designated together with Russia’s State Scientific Research Institute for Organic Chemistry and Technology, which the EU names as the facility that developed the novichok nerve agent that was used in the poisoning.  The Chemical Weapons regime was previously used to impose sanctions on Russian individuals and entities following the poisoning of Sergei and Yulia Skripal in the UK in March 2018, and on various Syrian nationals alleged to be involved in Syria’s chemical weapons programme.

In addition, the EU has designated Russian businessman Yevgeniy Prigozhin under the Libya sanctions regime, for allegedly providing support for breaches of the UN arms embargo on Libya by Wagner Group, a private military company.  Wagner Group itself has not been designated. All of the designations are directly applicable in all EU Member States and in the UK.  The EU’s press releases announcing the designations are available here (in respect of the Chemical Weapons regime) and here (in respect of the Libya regime).


Andrew joined Baker McKenzie's London office as a trainee in 2015 and qualified in 2017. His practice concentrates on compliance with EU/UK trade regulations, as well as anti-bribery and antitrust. Andrew previously was previously seconded to Baker McKenzie's European Competition Law Practice in Brussels.