EU sanctions are strong on paper, but enforcement remains the weakest link — Catarina Vieira

The European Union has adopted strong sanctions against Russia, but their impact is weakened by uneven implementation across Member States, fragmented enforcement and the lack of systematic consequences for violations. Sanctions enforcement must become a priority policy area, while liability for circumvention should extend across the full chain of actors involved, including intermediaries and third-country entities where they knew or should have known they were facilitating a violation.

This was stated in a comment to Guildhall by Catarina Vieira, a Dutch Member of the European Parliament from GroenLinks-PvdA and the Greens/EFA group.

— Do you agree with the assessment that the main weakness in the EU’s sanctions enforcement lies in the gap between established violations and real punishment?

— Broadly speaking, yes. Enforcement is the weakest link. The EU has adopted strong sanctions, but implementation across Member States remains uneven, and too many violations still do not lead to consequences. This reduces the impact of sanctions and weakens their deterrent effect.

The problem of EU sanctions is also more structural. Sanctions are agreed at the EU level and often require unanimity among Member States, which can dilute ambition and slow down decision-making at times when we need to act promptly.

— In your view, what should be changed to ensure that every established case of sanctions violation leads to criminal proceedings and real punishment for those responsible?

— Sanctions enforcement needs to be treated as a priority policy area by all Member States, not as a secondary legal task.

Member States need to dedicate more resources to better information sharing, proactive coordination and closing loopholes in order to prevent sanctions circumvention. When violations are identified, they should systematically lead to investigation and, where necessary, prosecution.

— Should such liability extend across the full chain of individuals and companies involved, including banks, traders, insurers, logistics operators, intermediaries and entities from third countries that knew or should have known the nature of the operation?

— Yes, with careful application. Sanctions circumvention typically relies on networks of actors and intermediaries, not on isolated individuals.

To make enforcement effective, extending responsibility and liability across the full chain is necessary, especially where actors knew or should have known that they were facilitating a violation.

— Could expanding the powers of the European Public Prosecutor’s Office in investigating sanctions violations form part of the solution?

— Yes, it could be part of the solution. Enforcement is currently fragmented across Member States. A stronger role for the European Public Prosecutor’s Office could improve coordination and consistency in cross-border cases.

Sanctions violations often span multiple jurisdictions, which makes them difficult for national prosecutors to handle alone. Expanding the mandate of the European Public Prosecutor’s Office could bring more consistency and help ensure that complex sanctions violations are investigated and prosecuted more effectively.

Exclusively for Guildhall. 

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