EU Sanctions – Restrictive Measures under the Common Foreign and Security Policy (CFSP)

EU sanctions (also called «restrictive measures») are foreign policy instruments of the European Union adopted under the Common Foreign and Security Policy (CFSP). They target states, organisations, or individuals and may include account freezes, travel bans, arms embargoes, sectoral sanctions, and trade prohibitions.

• Legal basis: Article 215 TFEU and Council CFSP decisions.
• Direct applicability: EU sanctions regulations apply directly in all 27 member states.
• Consolidated list: EU Financial Sanctions Data Repository (FSDR) contains all sanctioned persons and organisations.
• Coordination: Close coordination with UN sanctions and often with US OFAC measures.

The EU began adopting its own restrictive measures following the entry into force of the Maastricht Treaty (1993), which established the Common Foreign and Security Policy. Early EU sanctions targeted the former Yugoslavia (1990s) and Zimbabwe (2002). The Treaty of Lisbon (2009) strengthened the legal basis for EU sanctions (Art. 215 TFEU). EU sanctions policy was significantly expanded after 2014 (Russia/Crimea) and after the Belarus crisis of 2020/21. The response to the Russian invasion of Ukraine from February 2022 resulted in unprecedented EU sanctions packages (16 packages by early 2026), including extensive sectoral sanctions, an oil price cap, and tariffs. In December 2022, the EU appointed David O’Sullivan as international special envoy for the implementation of EU sanctions (Sanctions Envoy) to strengthen the fight against sanctions circumvention, particularly through third countries. The EU now has one of the most active sanctions regimes worldwide.

EU sanctions apply directly in all 27 member states. They affect:

• All companies and persons established in the EU
• Transactions in euro
• Exports from the EU and imports into the EU
• EU citizens worldwide

Active sanctions regimes (selection): Russia, Belarus, Iran, North Korea, Syria, Myanmar, Venezuela, Afghanistan, Yemen, Western Balkans, anti-terror sanctions (ISIL/Al-Qaeda), cyberattacks, chemical weapons use, EU Global Human Rights Sanctions Regime (EU Magnitsky Act).

• Screening of all customers, transactions, and business partners against the consolidated EU sanctions list (FSDR).
• Immediate freezing of funds and economic resources of sanctioned persons.
• Reporting obligation upon matches to national authorities (e.g., Bundesbank, BaFin in Germany or Trésor in France).
• Circumvention prohibition (contained in each EU sanctions regulation, e.g. Art. 12 Regulation 833/2014).
• Violations: national prosecution; Directive (EU) 2024/1226 of 24 April 2024 (Sanctions Enforcement Directive) defines EU-wide criminal offences and minimum penalties; transposition deadline: May 2025.
• Authorisation procedures for humanitarian exceptions or specific licences.

Bidirectional duplicate cleaned up.

3 corrections:
- Date and designation of 1st sanctions package incorrect
- SECO listed as example national EU reporting authority is incorrect
- Date of EU cyber sanctions regime incorrect (2 October 2020)
2 updates:
- last_amended date outdated (2024-06-01)
- Number of Russia sanctions packages outdated (14 instead of 16+)
5 clarifications.
2 notes.