Given the complexity of ensuring that any restrictive measures are subject to comprehensive monitoring and implementation, which are determined by various interweaving factors, this new Study focuses on six key issues that challenge contemporary EU sanctions implementation and enforcement policies:

Firstly, diverging implementation processes and uneven interpretations at Member State level involving 160 national competent authorities (NCA), each operating with unique mandates, intra-government divisions of competencies and legal sanctions frameworks;
Secondly, the lack of harmonisation in judicial sanctions enforcement and unequal penalisation of sanctions violations across Member States, resulting in pervasive incentive structures for malign economic operators to engage in ‘shopping’ – and the question of whether the Commission’s recent proposal to make sanctions violations a recognised crime at the EU-level will mitigate this risk;
Thirdly, and linked to the previous issue, the EU’s underdeveloped legal and practical mechanisms to address serious cases of sanctions evasion and circumvention by EU-based individuals and entities, often with the involvement of public and private actors from third countries, thereby not only undermining the effectiveness of EU sanctions, but also their legitimacy;
Fourthly, the yet-to-be-understood outcomes of recent reform initiatives at EU-level to enhance cooperation and information-sharing between EU institutions and Member States as well as strengthening the role of the Commission/the Vice President/High Representative (VP/HR) in guaranteeing a comprehensive implementation oversight across the EU;
Fifthly, the longer-term consequences of nascent signs in shifting institutional balances within EU sanctions decision-making procedures, both between the Commission/European External Action Service (EEAS)/VP/HR and the Council, in terms of preparing the composition of wide-scale EU sanctions regimes, as well as the EP’s enhanced political involvement in addressing cases of enhanced and improved EU sanctions use.
And sixthly, the impact of implementing autonomous EU sanctions in a sanctions coalition with other like-minded countries, such as has been the case when wide-scale EU sanctions have been targeted at Russia, Belarus, Syria and Iran.

These key issues will together form the analytical focus of this study, designed to provide a series of forward-looking and tangible policy recommendations which aim to improve the effectiveness and impact of EU sanctions. Recommendations will be targeted at the EP’s engagement (both in terms of legislation and scrutiny) as well as that of other EU institutional actors and Member States in this central aspect of contemporary CFSP efforts.

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