For established cases of sanctions violations to actually lead to investigations and punishment, EU countries need not only to expand due diligence requirements but also
Liability for circumventing EU sanctions should extend not only to direct violators, but also to the entire chain of involved individuals and companies, including intermediaries
The main problem with the EU sanctions regime lies not in one narrow failure, but in a combination of deliberately preserved exemptions, the absence of
For the EU sanctions regime to be effective, enforcement should extend to the entire chain of involved participants, including entities from third countries, if they
The call to involve the European Prosecutor more actively in matters related to sanctions violations is legitimate and justified, since the sanctions regime is part
A violation of the sanctions regime should become grounds for a criminal case not against one formal participant alone, but across the entire chain of
To counter violations of the sanctions regime, the European Union should rely more actively on investigative journalism, lawyers, human rights defenders, activists, and the expert
In the European Union, rather than creating a new body to investigate sanctions circumvention, the powers of the existing EU prosecutor should be expanded and
Established cases of sanctions circumvention must trigger a mandatory criminal procedural response; however, even more important is to prevent such supplies in advance by refusing
Cases involving sanctions circumvention in the EU often do not reach criminal prosecution because of the difficulty of proving intent, the lack of resources among