EU Sanctions Framework
RESTRICTIVE MEASURES
The EU's principal foreign policy enforcement tool. Over 40 active sanctions regimes targeting countries, entities, and individuals to uphold international law, counter terrorism, address human rights violations, and respond to threats to international peace and security. Since February 2022, the Russia sanctions programme has become the most comprehensive in EU history -- 19 packages adopted through October 2025, 2,200+ designations, and over EUR 210 billion in frozen assets.
EU sanctions -- formally called "restrictive measures" -- are the European Union's primary tool for responding to threats to international peace, security, and human rights. They work by restricting financial transactions, freezing assets, banning travel, and limiting trade with designated countries, entities, and individuals. Every company that operates in the EU, uses EU financial infrastructure, or is owned by EU persons must comply.
The framework is built on two legal instruments adopted in tandem: a Council Decision under the Common Foreign and Security Policy (CFSP), which sets the political direction, and a Council Regulation, which is directly applicable across all 27 Member States and creates binding legal obligations. Compliance is required immediately upon publication in the Official Journal -- there is no grace period.
Since Russia's full-scale invasion of Ukraine in February 2022, the EU has adopted 19 sanctions packages at unprecedented speed, freezing over EUR 210 billion in Russian sovereign assets and designating more than 2,200 individuals and entities. The regime covers asset freezes, SWIFT disconnections, oil and gas import bans, price caps, export controls on dual-use technology, and restrictions on professional services.
In April 2024, the EU adopted Directive 2024/1226, which for the first time harmonises sanctions violations as criminal offences across all Member States. Companies that fail to screen counterparties, freeze designated assets, or report suspicious activity now face criminal prosecution -- not just administrative fines. The transposition deadline was 20 May 2025.
The EU maintains over 40 active restrictive measures regimes. Below are the most significant programmes by scope and enforcement activity.
EU sanctions employ five main categories of restrictive measures, often combined within a single regime. Select a category for details.
Nineteen sanctions packages adopted since February 2022, constituting the most rapid and comprehensive sanctions escalation in EU history.
Initial response: targeted individuals, Donetsk/Luhansk restrictions, sovereign debt ban
President Putin and FM Lavrov designated. SWIFT ban on select banks. Central Bank asset freeze
Airspace closure to Russian aircraft. RT and Sputnik broadcast ban. EUR 500M military aid
Steel import ban. Luxury goods export ban. New investment restrictions in energy sector
Coal import ban (phased). Port access ban for Russian-flagged vessels. New bank designations
Crude oil import ban (phased with pipeline exemption). Sberbank SWIFT disconnection. Additional bank designations
Gold import ban. Enhanced export controls. Maintenance of listed vessels and aircraft prohibited
Oil price cap framework. Additional trade restrictions. New individual designations. Services ban (IT, legal, architecture)
Media ban expansion. New bank designations. Defence sector export ban strengthened
One-year anniversary package. Trade restrictions on electronics, vehicles, and machinery. New circumvention measures
Anti-circumvention measures via third countries. Diamond import ban. Transit restrictions through Russia
Diamond import ban operational. New designations. Price cap enforcement strengthened
Two-year package. 200+ new designations. LNG transshipment restrictions. Anti-circumvention reinforced
Russian LNG import restrictions. Entity-based approach to circumvention. Intellectual property ban
Shadow fleet targeting. New energy sector measures. 84 vessels designated for price cap circumvention
Third anniversary. Comprehensive shadow fleet measures. Additional energy restrictions. Over 2,200 designations total
Additional designations. Strengthened anti-circumvention measures. Expanded export controls on dual-use goods and advanced technology
Further economic and individual restrictive measures. Enhanced enforcement of energy price cap. New sectoral restrictions
Coordinated with US and UK sanctions. Expanded designations targeting evasion networks and financial facilitators. Additional trade restrictions
All EU persons and entities must comply with sanctions. These sectors face the highest compliance burden and enforcement scrutiny.
A compliant screening programme must cover the entire lifecycle of a business relationship.
Obtain and integrate the EU Consolidated Financial Sanctions List, national lists, and (where applicable) UN, US OFAC, and UK sanctions lists. Ensure automated updates.
Screen all new customers, counterparties, and beneficial owners against consolidated lists before establishing any business relationship.
Screen every transaction for sanctioned parties, restricted goods, and prohibited destinations. Implement real-time screening for payments and trade finance.
Re-screen existing relationships whenever sanctions lists are updated. Monitor for changes in beneficial ownership, corporate structure, and risk indicators.
Investigate and resolve potential matches through a documented escalation procedure. False positives must be recorded; true hits trigger immediate freezing and reporting.
Report confirmed hits, frozen assets, and suspicious circumvention attempts to the national competent authority. Maintain complete audit trails.
Companies operating transatlantically must navigate two distinct sanctions frameworks with different legal bases, enforcement approaches, and extraterritorial reach.
Directive 2024/1226 represents a paradigm shift -- sanctions violations are now criminal offences across all 27 Member States.
Member States must ensure that legal persons (companies) can be held liable for offences committed for their benefit by persons in a leading position or due to lack of supervision. Penalties for legal persons must include criminal or non-criminal fines.