Russian critics of President Vladimir Putin have spent the past year pressing the US and its allies to impose sanctions on thousands of Kremlin officials and business tycoons. Now they want a clear way for those who come out against the war to get off the blacklists.

Exiled businessman Mikhail Khodorkovsky, who spent years in a Russian prison after a conflict with President Vladimir Putin, wrote to the UK Foreign Office this week appealing for sanctions to be lifted from Oleg Tinkov, a self-made billionaire who publicly condemned Putin’s invasion and renounced his Russian citizenship.

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“I believe the decision to impose sanctions on him was wrong,” Khodorkovsky said in an interview, citing Tinkov’s repeated criticism of Putin’s government. “Lifting sanctions should be very clearly linked to public disengagement from this regime and its aggressive war.”

As the war drags on, many tycoons are challenging the legal basis for including them on Western sanctions lists. None have yet succeeded.

Tinkov formally applied this week to the UK Foreign Office to be removed from the sanctions list.

“I support the UK government’s decision to sanction people who back Putin or facilitate the war,” Tinkov said in a statement. “It’s sad they mistakenly thought I was one of those people. Lifting sanctions on me would be fair and send a signal that Western sanctions are not aimed at all Russians but only people who prop up Putin and his invasion.”

Asked about the request, the Foreign Office said it doesn’t comment on individual sanctions designations. “Every sanctioned individual or entity has the right to challenge their designation and there is a clear legal route to do so,” it said in a statement.

Khodorkovsky isn’t the only Russian opposition activist calling for sanctions to be tied to public criticism of the war.

Leonid Volkov, the chairman of Alexey Navalny’s Anti-Corruption Foundation, has been lobbying European, British and US officials to expand sanctions to include everyone on the organization’s list of 6,000 Russian officials and enablers of the Kremlin.

But to make sanctions more effective at destabilizing Putin, Volkov said Western officials need to lay out clear criteria for how individuals can get removed from the list, including by denouncing the war and paying damages to Ukraine.

“The ultimate goal is to stop the war, not to punish people,” Volkov said in an interview. “Only with an exit strategy will sanctions be effective. Otherwise, people have nowhere to run but back to Moscow, where they get more dependent on Putin. They have to be presented with a clear option – do this and this and sanctions will be lifted.”

Volkov said he has told UK officials they should lift sanctions on Tinkov as an incentive for other Russian tycoons to break with Putin. Tinkov has said the Kremlin threatened to nationalize the online bank he founded after he criticized the war, forcing him to sell his stake last year in what he called a “fire sale.”

In October, Volkov wrote to the EU asking to remove businessmen who condemn the war and “are not connected to the crimes committed by Putin’s regime. The sanctions sometimes “target businesspeople acting in good faith, often simply because they hold Russian passports, while the real criminals, who enriched themselves through their close connections to Putin’s regime, have once again escaped scot-free,” Volkov said.

A spokesperson for the European Commission said bloc would see an end to the war and an unconditional withdrawal of Russian troops as among the main preconditions for easing sanctions.

Opposition activists have also called for sanctions relief for others who’ve been more restrained in criticizing the war than Tinkov.

Volkov cited billionaire Mikhail Fridman and his partners in the Alfa Group, which controls the country’s largest retailer and private bank – Petr Aven, German Khan and Alexei Kuzmichev – as examples of tycoons deserving of sanctions relief. Fridman publicly condemned the war as a “tragedy,” saying “war can never be the answer,” in a Feb. 28, 2022 statement, but he stopped short of directly criticizing Putin.

“We do not believe that they were somehow connected to Putin’s regime or that they should be held responsible for his crimes,” Volkov wrote of the Alfa shareholders.

The UK and the EU have both cited Alfa’s alleged Kremlin ties when they imposed sanctions. The EU called Aven “one of Vladimir Putin’s closest oligarchs.” It called Fridman an “enabler of Putin’s inner circle” and said the other Alfa shareholders maintained close relationships or ties with the Kremlin. The UK said Fridman, Aven and Khan are closely associated with Putin and that they, along with Kuzmichev, have benefited from the Russian government.

The men have denied those claims and are challenging the sanctions.

The US has refrained from targeting the Alfa shareholders or Tinkov but it has imposed sanctions on Alfa-Bank. Fridman has remained in London despite the restrictions, while Aven and Kuzmichev have not returned to Russia since the invasion. EU sanctions are up for renewal this month.

Other Kremlin critics made similar appeals on Fridman’s behalf. Nobel Peace Prize winner Dmitry Muratov, the editor-in-chief of Novaya Gazeta, an independent newspaper shuttered by the Kremlin, called for the EU to reconsider sanctions on the tycoon given his investments in Ukraine and his friendship with the late Russian opposition leader Boris Nemtsov, who was gunned down near the Kremlin in 2015.

“It’s hard to imagine a ‘person close to Putin’ who would befriend a furious opponent of the Kremlin,” Muratov wrote, stressing he has no financial or professional connections to Fridman. Ilya Yashin, an opposition politician now jailed in Russia, wrote a similar appeal for the tycoon last month.

Lawyers for Fridman have sent the letters from activists to the EU ahead of its decision this month on renewing sanctions.

Navalny, one of Putin’s most prominent critics, survived a poisoning in August 2020 that he and Western governments blamed on the Kremlin. He was jailed after returning to Russia in 2021 and is serving a 9-year prison sentence after being convicted of fraud and contempt of court. While he’s in jail, aides at his foundation have continued investigating Russian officials and tycoons for corruption.

Volkov said the foundation had no financial ties to the Alfa Group. He called Aven’s attendance at a Kremlin meeting between the president and tycoons on the day of the invasion a “mistake but shouldn’t be used as a sign of a “connection to Putin.”

Khodorkovsky said tycoons seeking sanctions relief must not only condemn the war but also denounce Putin and declare support for Ukraine’s territorial integrity. Fridman has met only the first of those conditions, he said.

“I believe Fridman and Aven are scared of falling into the gap between the two chairs on which they have been sitting for many years,” he said. “Russia will block the way for them and the West will not open it.”

Read more: EU imposes new sanctions on 121 individuals, entities over Russia’s war in Ukraine