EU Sanctions Regime
How the European Union designs, adopts, and enforces sanctions -- and why EU and US approaches often clash.
How the EU Sanctions System Works
The EU's sanctions regime, known as 'restrictive measures,' requires unanimous agreement among all member states in the Council of the European Union. This consensus requirement gives every member state a veto, which both ensures legitimacy and creates frustration when a single country -- often Hungary under Viktor Orban -- blocks action. Once adopted, sanctions are implemented through EU regulations that are directly binding on all member states, companies, and individuals within the EU.
Before 2022, EU sanctions were a relatively modest tool. The Russia-Ukraine war transformed them into a central instrument of EU foreign policy. Between February 2022 and mid-2024, the EU adopted over 13 packages of sanctions against Russia -- an unprecedented pace that required the EU to build enforcement capacity essentially from scratch. The experience exposed gaps in implementation: member states varied widely in their willingness and ability to enforce sanctions, and the EU lacked a centralized enforcement body.
