EU Sanctions List

The European Union operates one of the largest sanctions frameworks in the world, with restrictive measures targeting individuals, entities, and entire economic sectors across multiple country-specific and thematic programs. Since Russia's invasion of Ukraine, the EU has adopted an unprecedented volume of sanctions, and in 2024 moved to harmonise criminal penalties across all 27 member states.

How EU sanctions work

EU sanctions — formally called restrictive measures — are adopted by the Council of the European Union as part of the EU's Common Foreign and Security Policy (CFSP). They take two forms:

• Council Decisions under Article 29 TEU — establish the policy framework for sanctions
• Council Regulations under Article 215 TFEU — make the sanctions legally binding and directly applicable in all member states

Unlike US sanctions (where OFAC both designates and enforces), the EU splits these functions: the Council designates parties and defines restrictions, while member states enforce the sanctions within their own legal systems. This has historically led to uneven enforcement, which the 2024 harmonisation directive aims to address.

The Consolidated Financial Sanctions list

The EU Consolidated Financial Sanctions list identifies all persons, groups, and entities subject to EU financial sanctions. It is maintained by the European Commission and updated as the Council adopts new designations or amends existing ones.

The list covers:

• Targeted asset freezes — all funds and economic resources belonging to, owned, held, or controlled by listed persons must be frozen
• Prohibition on making funds available — no funds or economic resources may be made available, directly or indirectly, to or for the benefit of listed persons
• Sectoral restrictions — prohibitions on specific economic activities with sanctioned jurisdictions (energy, finance, technology, luxury goods, transport)

EU sanctions programs

The EU maintains sanctions against numerous countries and thematic targets. The largest programs include:

• Russia/Ukraine — by far the largest EU sanctions program, with extensive designations of individuals, entities, and broad sectoral restrictions on trade, finance, energy, and technology. The Council regularly adopts new packages of measures; in March 2026, Decision (CFSP) 2026/696 renewed Ukraine-related measures through September 2026, covering 132 individuals and 77 entities[1]
• Iran — nuclear proliferation and human rights-related restrictions
• Syria — restrictions related to the Syrian conflict
• North Korea (DPRK) — nuclear and missile proliferation
• Belarus — related to both domestic repression and support for Russia's invasion of Ukraine
• Thematic regimes — cyber attacks, chemical weapons use, terrorism, and human rights violations

Enforcement: the 2024 harmonisation directive

Historically, enforcement of EU sanctions varied significantly across member states, with some countries rarely prosecuting violations. In April 2024, the EU adopted Directive 2024/1226 to establish uniform minimum criminal penalties across all 27 member states.[2]

The directive establishes criminal offences for:

• Transferring funds to circumvent asset freezes or providing false information to conceal frozen assets
• Providing prohibited or restricted economic and financial services
• Breaching travel bans and arms embargoes
• Failing to freeze assets when required

Maximum penalties under the directive:

• Legal persons: fines of 1–5% of global turnover or €8–40 million, depending on the breach
• Individuals: member states must implement maximum prison sentences; many have set these at 5–12 years

Who must comply

• All EU persons and entities — nationals of EU member states and entities incorporated under the law of a member state
• Anyone within EU territory — regardless of nationality
• Any business done in whole or in part within the EU — including via EU-based subsidiaries or branches
• EU-flagged vessels and aircraft — wherever they are in the world

Rights of designated persons

Unlike some sanctions regimes, the EU provides formal mechanisms for designated persons to challenge their listing:

• Reconsideration requests — designated persons may submit a request to the Council before specified deadlines
• Judicial review — designations can be challenged before the General Court of the European Union, and the Court has annulled designations where the Council failed to provide sufficient evidence
• Fund release requests — designated persons may apply to their member state's competent authority for authorisation to use frozen funds for basic needs or specific payments