EU Sanctions & Embargoes – A little bit of context

Story of the week

Since the early 1990s, the European Union (EU) has increasingly used financial and economic sanctions as a vital part of its Common Foreign and Security Policy (CFSP). In 2004, the Member States of the EU jointly emphasized their commitment to employing sanctions in defense of human rights, democracy, the rule of law, good governance, and in efforts to combat weapons of mass destruction and terrorism.

Over the last 15 years, the EU’s use of sanctions has grown in number and scope. Currently, 41 EU sanctions regimes are in place, each with varying objectives, types of measures (such as asset freezes, travel bans, arms embargoes, and sectoral restrictions), and geographical or thematic contexts. These sanctions also interact with measures imposed by other international actors, including the United Nations (UN) and autonomous sanctions from countries like the United States, the United Kingdom, and Canada.

The EU’s sanctions in response to Russia’s aggression against Ukraine represent a significant development in EU sanctions policy. These sanctions increasingly involve financial and economic bans, and as such, monitoring and evaluating their implementation has become more complex and resource-intensive for EU institutions and Member States’ authorities.

EU sanctions under the CFSP can be categorized into two main groups:

  • Measures of General Application: These are directed at specific sectors and can have broader economic effects.
  • Measures Targeting Individuals and Entities: These sanctions are specified in an annex to the legislation and typically consist of asset freezes and prohibitions on entry.

This categorization has important implications. Sanctions on individuals and entities can be challenged in the Court of Justice of the EU (CJEU), while broader economic sanctions are not subject to judicial review. The CJEU distinguishes between provisions of a general nature and measures targeting specific individuals or entities named in the act.

Sanctions regimes can be organized geographically (focused on a specific country) or thematically. Thematic or horizontal sanctions regimes have gained popularity, allowing the designation of individuals and entities sharing a common violation of a specific norm. These regimes primarily affect individuals and entities, while country-based sanctions can include both categories.

The EU has established thematic sanctions regimes in recent years to address issues such as chemical weapons use, cyberattacks, and human rights abuses. Russian entities and individuals are often included in these regimes. A sanctions regime targeting grand corruption is also being developed at the Council.

The most commonly used EU sanctions measures include travel bans (prohibitions on entry) and asset freezes. These measures are implemented through blacklists, which contain designated individuals and entities found in the annex of each sanctions regime. Asset freezes prevent the targets from using bank accounts, financial assets, real estate, and vessels in EU Member States. EU-incorporated banks and operators are prohibited from transferring funds to the bank accounts of blacklisted individuals.

Arms embargoes are frequently employed, particularly in situations of violent conflict. Additionally, trade restrictions, financial sanctions, and various trade and financial measures (investment bans, restrictions on joint ventures, and insurance prohibitions) are becoming more common in EU sanctions despite being rare in the early years of the CFSP.

Source: European Parliament, Study: Implementation and monitoring of the EU sanctions regimes, including recommendations to reinforce to EU’s capacities to implement and monitor sanctions, 10 Oct 2023

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