As the Russian war with Ukraine drags on, Russians are seeking ways to dodge Western sanctions that block their bank accounts, limit their travel and generally make their lives harder. And it seems one way to achieve this is by exploiting the formalities of the Western legal system: London courts show no mercy to family members of Russian oligarchs who have tried to dispute their listing, but turn a blind eye to ostensibly unconnected “consiglieri.”
Before the Russia-Ukraine war began in February 2022, Western sanctions primarily targeted countries such as Iran and Afghanistan, focusing on nuclear programmes, terrorism and human rights. The sanctions against Russia marked a massive shift, targeting a major European state with extensive economic ties and aiming to cripple its war effort in Ukraine. As a result, the sanctions campaign has not only reshaped global trade and political alliances but also affected many individuals with close or indirect ties to the Kremlin, prompting them to seek ways to get these restrictions lifted.
Among those targeted are close relatives of individuals who built their fortunes after the fall of the Soviet Union and maintain close ties to the Kremlin, often referred to as oligarchs. Since 2022, Alexandra Melnichenko, wife of Russian billionaire Andrey Melnichenko; Marina Mordashova, wife of Russian billionaire Alexei Mordashov; and Anzhelika Khan, wife of Russian-Ukrainian oligarch German Khan, have all come under Western sanctions.
Anzhelika Khan, a UK passport holder, challenged her listing in the UK Court of Appeal, which has yet to make a decision. In November 2024, the court heard her appeal against the Foreign, Commonwealth and Development Office (FCDO), the UK body that oversees sanctions. She had previously appealed a lower court’s decision to dismiss her case under Section 38 of the Sanctions and Anti-Money Laundering Act 2018, after spending months fighting to lift the personal sanctions imposed on her due to her “association” with her husband, German Khan.
Anzhelika Khan was sanctioned on 21 April 2022, a month after her husband. The EU and UK sanctions, which include asset freezes and travel bans, have had a significant impact on Khan, who has lived in the UK since 2013 and became a British citizen in 2019.
The UK Foreign Office justified the asset freeze and travel sanctions by citing her relationship as the wife of German Khan, who “is obtaining a benefit from and/or supporting the Government of Russia through his positions on the Supervisory Board of the Alfa Group Consortium and the Board of Directors of ABH Holdings S.A., owner of Russia’s largest privately owned bank ‘Alfa-Bank (Russia).” It also claimed that German Khan has been “involved in destabilising Ukraine or undermining or threatening the territorial integrity, sovereignty or independence of Ukraine.”
While Anzhelika Khan is reportedly mainly focused on raising her four children, she also manages several high-value properties the couple acquired over the years, including multiple apartments in London’s affluent Belgravia area and a £62 million house on Eaton Square purchased in 2008. Evidence presented to the London court revealed that German Khan gave his wife “substantial gifts,” including shares in four properties.
On 20 February 2024, Anzhelika Khan lost her legal battle in the High Court of England and Wales against UK sanctions imposed due to the Ukraine conflict. She argued she had no involvement in Russian politics or influence over the government, claiming the sanctions were unlawful. However, her claim was dismissed in a written ruling.
Evidence suggests that London continues to be a haven for Russia’s kleptocratic elite. Oligarchs and former officials close to the Russian president are adjusting to new circumstances but are reluctant to relinquish the privilege of owning assets in the UK. While the connection between husband and wife is often clear, making it easier to prove in court, in some cases, even when it’s evident that someone represents the interests of a sanctioned individual, proving this can be nearly impossible. This makes them legally untouchable under sanctions law, bringing the next case into focus.
Russian entrepreneur Olga Zinovieva moved to London in February 2022, coinciding with the start of Russia’s full-scale invasion of Ukraine. Like Anzhelika Khan, she holds a British passport.
In early 2023, Zinovieva sued Citibank in a London court, claiming the bank had unlawfully withheld $500,000 she transferred from a sanctioned Russian bank. The court sided with Zinovieva, finding that the funds were frozen without valid grounds as Zinovieva was not on the sanctions list, according to the HM Courts and Tribunals database.
Unlike Anzhelika Khan, Zinovieva is neither married to nor closely related to any Russian nationals subject to UK sanctions. However, she once topped the list of “10 Women to Whom Russian Billionaires Entrust Their Money,” compiled by the Russian edition of Forbes magazine in 2015, and held executive roles in companies that were sanctioned after the invasion of Ukraine, including at the time the sanctions were imposed.
Zinovieva was formerly a senior executive at Interros, the holding company owned by Vladimir Potanin, a Kremlin-linked oligarch and one of Russia’s wealthiest men. She served as First Deputy General Director, Deputy Chairman of the Management Board and a member of the Board of Directors, and gained the reputation of Potanin’s right-hand woman. Potanin, added to the UK sanctions list in the summer of 2022 as the controlling owner of Rosbank, was hit with further sanctions in February 2024 when the UK’s Office of Financial Sanctions Implementation (OFSI) extended measures to cover his holdings.
After relocating to the UK, Zinovieva registered Parsons Advisory Services Ltd in March 2022, a company specialising in “management consultancy activities.” But despite leaving Russia and starting her new business in the UK, she was reappointed to the board of directors of Interros, which suggests that she retained Potanin’s trust.
Anzhelika Khan’s case presents a significant challenge to the UK government’s sanctions strategy, which targets family members and associates holding substantial assets on behalf of oligarchs and other key sanctions targets. It is particularly notable as the first major appeal in the Court of Appeal involving an individual designated solely under the association provisions of the UK’s Russia sanctions regime related to the war in Ukraine. Meanwhile, Zinovieva’s case proceeded quietly, without similar attention.
