In its judgment of 12 February 2026 in Opera Laboratori Fiorentini SpA (Case C-313/24), the Court of Justice of the European Union clarified how EU restrictive measures against Russia, adopted by the Council of the European Union under Regulation (EU) No 833/2014, as amended, apply in the context of public procurement.
The Court clarified the criteria for determining whether an economic operator falls within the scope of the sanctions, including how ownership, control, and links with sanctioned persons or entities must be assessed. It held that contracting authorities are required to carry out a thorough assessment before awarding a public contract to a company that is not established in Russia but is managed by an administrator who is a Russian national.
The Court stressed that authorities must assess all relevant legal and factual circumstances, including, inter alia, ownership and control structures, personal and professional connections between the persons concerned, the characteristics of the transactions, and any evidence of coordination or prior instructions.
Read the full judgment her:
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