The evolving position of the Trump administration on security guarantees for Europe is reshaping not only the future of NATO and EU defence capabilities. It is also leaving Europe without the US sanctions shield, which has long targeted entities threatening Western democracies.
At the same time, the EU risks once again becoming bogged down in discussions over how to respond to this problem.
For years, the US designated hundreds of companies and individuals worldwide that enabled Russia, Iran, and North Korea to procure restricted technologies, move illicit funds, and trade in sanctioned commodities such as oil.
However, in 2025, the United States paused the imposition of new sanctions and, in some cases, began easing existing restrictions, including measures related to Belarusian potash exports and banking system.
As a result, the EU and its partners must rethink how sanctions policy is designed and implemented. The current system – requiring consensus on each listed entity – is too slow and fragmented to counter fast-moving sanctions evasion networks. What is needed instead is scale, speed, and strategic reaction. While these debates are not new, the current geopolitical environment makes reform urgent.
The impact of Member States
Member States play a critical role in sanctions policy now and might react more operative to the new circumstances. For example, in 2025 Latvia announced its intention to include a ban on the export of natural rubber to Russia in an EU sanctions package, drawing on analysis by the Economic Security Council of Ukraine. As a result, the 20th sanctions package included restrictions on natural rubber exports to Russia – just one of several recent examples.
Nevertheless, sanctions implementation is typically distributed across ministries of foreign affairs, export control authorities, customs, law enforcement, financial intelligence units, and intelligence services. While these institutions possess valuable insights, sanctions are rarely their primary focus.
The EU can support the development of the capabilities of these bodies and their focus on combatting sanctions evasion or benefit from a “lead nation” model, whereby one or more Member States invest in robust, well-staffed sanctions bodies capable of collecting, analysing, and operationalising data at both national and EU levels. This would enhance the overall resilience and coherence of the European sanctions regime.
The EU centralised approach to sanctions
The EU also needs to modernize the centralised approach to the sanctions policy. A first step could be to streamline decision-making at the EU level. Political agreement on sanctions should remain subject to unanimity among Member States.
However, the technical process of adding entities, vessels, or goods to sanctions lists could be delegated to a more flexible mechanism, operating within the framework of an already agreed political mandate. If Member States agree to sanction the Russian military-industrial complex, it is inefficient to require consensus on every individual enterprise within it.
A second issue is strengthening the EU’s analytical and operational capacity. At present, identifying and acting on sanctions evasion can take years. By contrast, the US has demonstrated a far more agile and data-driven approach, making it a credible deterrent to illicit networks.
The EU should establish a centralised data and analysis hub with access to cross-border intelligence on sanctions evasion. Such a body could rapidly compile evidence and support timely listings, in coordination with Member States and key partners including Ukraine and the United Kingdom. Encouragingly, some Member States already support this idea.
The decision to establish a centralised EU sanctions enforcement institution is a strategic step for the Union as a whole. However, the EU’s bureaucratic procedures may take years to overcome. In addition, the problem of consensus could still hinder lengthy discussions.
At a time of rising security risks, Europe can no longer rely on external sanctions enforcement to safeguard its interests. A short-term response to this challenge could involve supporting Member States in becoming more effective and proactive in sanctions designation and enforcement. However, at the EU level, the establishment of a centralised enforcement body with a comprehensive, “helicopter-view” perspective represents a strategic objective for the Union.
