INTRODUCTION
Four years have passed since the beginning of Russia’s full-scale invasion of Ukraine. This period has been marked both by the European Union’s historic wave of sanctions against Russia and by Russia’s institutionalization of mechanisms to circumvent those sanctions through indirect channels.
In the first weeks and months of the war, there were expectations that sanctions would weaken the Russian economy in the short term and thereby reduce its capacity to wage war. However, these expectations did not materialize. The complexity of decision-making mechanisms and procedures, political fractures within the EU, energy dependency, re-exports via third countries, the use of a shadow fleet, and parallel channels all reduced the effectiveness of the sanctions regime.
In this analysis, the KHAR Center maps the chronology of EU sanctions against Russia, the trends in sanction bypassing, and how the EU has redesigned its mechanisms in response—using data and factual evidence.
KEY QUESTIONS OF THE ANALYSIS
Why did the EU’s tough sanctions fail to produce the expected immediate effect? What factors played the primary role in Russia’s adaptation to the sanctions regime? In what direction is the new sanctions architecture changing the situation?
I. SANCTIONS CHRONOLOGY
2014–2021 — The Period of Symbolic Sanctions
The European Union’s first sanctions began in March 2014—during the annexation of Crimea. On March 5, the European Union adopted a decision to freeze the assets of individuals linked to the misappropriation of Ukrainian state funds. This resolution was not directly aimed at Russia; it targeted former President Viktor Yanukovych and his entourage. Nevertheless, it was adopted against the backdrop of developments in Ukraine and Russia’s escalating actions (Eur-Lex Europa, 2014).
On March 17, the European Union imposed travel bans and asset freezes within EU territory on individuals and entities involved in actions threatening Ukraine’s territorial integrity and sovereignty. This decision was the EU’s first concrete reaction to the occupation of Crimea (Eur-Lex Europa 2026).
Between June and July of the same year, the EU adopted two separate sanctions packages related to Crimea and Sevastopol. These packages included restrictions on imports of goods originating from Crimea and Sevastopol into the EU, as well as limitations on infrastructure investments (Consilium Europa, 2014).
Following Russia’s occupation activities in Donbas and the downing of the Malaysian passenger aircraft, the EU adopted another sanctions resolution. This resolution restricted certain Russian banks and companies from accessing EU capital markets, limited trade in arms and defense industry products, curtailed exports that carried a risk of military use, and imposed restrictions on trade in energy-related technologies (Eur-Lex Europa 2026).
In December 2014, the EU further tightened the sanctions regime by prohibiting investments in Crimea and Sevastopol (Eur-Lex Europa 2026).
Between 2015 and 2021, these sanctions were renewed or extended in the form of updates to the lists of sanctioned individuals and the expansion of the scope of restrictive measures. However, these sanctions had no practical impact in halting Russia’s occupation activities. While the initial months of the annexation of Crimea and the occupation of Donbas witnessed a display of unity within Europe, this situation gradually changed in the following months and years.
Although the Baltic states, Poland, the Scandinavian countries, Romania, and the United Kingdom supported maintaining the sanctions regime in a strict manner, Bulgaria, the Republic of Cyprus, Greece, Italy, Slovenia, Portugal, Spain, Hungary, and Austria—particularly during ceasefire periods—began leaning toward restoring relations with the Kremlin (Natorski, Pomorska, 2016).
At the same time, Russia actively exploited divisions within the EU to weaken the impact of sanctions and to influence the overall decision-making mechanism. Moscow skillfully took advantage of the fact that sanctions were adopted under the Common Foreign and Security Policy (CFSP) procedure, which requires periodic renewal and grants member states veto power. The Kremlin’s allies within the EU used the CFSP procedure to create complications during the votes held every six months. Hungary was a primary source of these obstacles (Portela, Pospiezsna, Skrzypczynska, and Walentek 2021).
Russia also mitigated the damage caused by sanctions by taking advantage of European divisions and loopholes, adjusting its banking policies, and deliberately devaluing its national currency (Ceiger 2022).
In this respect, the EU’s response between 2014 and 2021 was assessed as weak and largely symbolic. The sanctions were primarily targeted (“smart sanctions”) in nature, limited to travel bans and asset freezes. Embargoes directly targeting Russia’s main source of foreign currency revenue—energy exports—were not imposed.
Major countries such as Germany resisted tougher measures due to concerns over energy supply and economic interests, which further deepened political fragmentation within the EU. Projects such as Nord Stream 2 increased dependency even further.
Ultimately, the EU neither responded adequately to the violation of Ukraine’s sovereignty nor created a mechanism capable of deterring Russia from occupation. The soft position adopted in 2014 and the failure to reduce energy dependency created the conditions that allowed Russia in 2022 to use energy leverage to threaten Europe with crisis (Bret 2021).
2022–2023 — A Flood of Sanctions, Embargo Loopholes, and the “Third Countries” Problem
Russia’s full-scale aggression against Ukraine, launched on February 24, 2022, produced a shock effect across the West, accompanied by a rapid succession of sanctions resolutions. The newly adopted sanctions packages no longer envisioned merely targeted embargoes, but systemic restrictions.
In fact, the first sanctions package of this period was announced two days before the full-scale invasion. The package included asset freezes, restrictions on financial transactions, travel bans, and transit prohibitions targeting 351 members of the Russian State Duma, as well as 27 other high-ranking individuals and entities. It also included a ban on exports from the occupied regions of Ukraine to the EU and restrictions on Russia’s access to EU investment and financial markets, among other measures. The trigger was the appeal by members of the Russian Duma to President Putin to recognize the so-called Donetsk and Luhansk republics (Consilium Europa 2022).
The second package, dated February 25, and the third package, adopted between February 28 and March 2, introduced sanctions unprecedented in their severity and scope. These measures included removing seven Russian banks from SWIFT, targeting the banking system, the energy and transport sectors, aviation, and technology, as well as banning the broadcasting within the EU of propaganda outlets such as “Russia Today” and “Sputnik” (European Commission 2025). In total, in 2022 the European Union adopted nine sanctions packages aimed at weakening Russia’s economic base, depriving it of critical technologies and markets, and severely limiting its ability to wage war (European Commission 2025).
As of April 1, 2022, the Baltic states completely halted gas imports from Russia (LSM, 2022). This was one of the most concrete and impactful measures taken against Russia’s energy sector. Subsequently, the European Union transformed this line into a common policy and adopted a plan to completely eliminate dependence on Russian oil and gas by the end of 2027 (European Commission 2022).
Less than a year after the 2022 sanctions, facts and allegations concerning the circumvention of embargoes began to surface. This occurred primarily in three directions.
The first direction was the re-export system mediated by third countries and various interest groups. Embargoed goods began to be exported from the EU to third countries and then re-exported to Russia (Chupilkin, Javorcik, Plehanov 2023). This circumvention was particularly noticeable in the export of dual-use goods and industrial components. According to a 2023 report by the European Bank for Reconstruction and Development, although official statistics showed a decline in direct exports from the EU and the United Kingdom to Russia following the 2022 sanctions, this decline was compensated by indirect exports. While direct exports to Russia decreased, exports to Central Asian and Caucasus countries—particularly Armenia, Kazakhstan, and Kyrgyzstan—increased. These two trends were more pronounced in sanctioned goods. The decline in exports to Russia was approximately 80 percent greater for sanctioned goods compared to other goods, while the increase in exports of sanctioned goods to Armenia, Kazakhstan, and Kyrgyzstan was about 30 percent higher than for other goods. A portion of sanctioned goods was redirected to Russia via the Caucasus and Central Asia—especially through Armenia, Kazakhstan, and Kyrgyzstan. These three countries were particularly suitable channels because they are part of a Customs Union with Russia, which facilitated the “transfer” of goods (Chupilkin, Javorcik and Plehanov 2023).
During the same period, exports from Turkey to Russia showed the largest differential increase—35 percent—for goods resembling sanctioned categories. The additional increase in sanctioned goods amounted to 21 percent. Moreover, exports of sanctioned goods from Turkey to countries such as Armenia, Kazakhstan, and Kyrgyzstan increased by 20 percent (Chupilkin, Javorcik and Plehanov 2023).
According to a 2025 study by OSW, Turkey and Kazakhstan played particularly active roles in circumventing sanctions. The research focused on a specific dual-use product—tapered roller bearings. It found that exports of tapered roller bearings from Europe to Turkey increased by 37 percent after the 2022 sanctions compared to 2021 levels. The main source of this increase was Germany, which raised its sales of this product to Turkey by 67 percent. Similarly, in 2022 and 2023 Estonia and Germany significantly increased their exports of bearings to Russia, later replaced by France in Estonia’s role. Data obtained from the UN Comtrade database show that during the same period, exports of tapered roller bearings to Russia increased substantially both from Turkey and from Kazakhstan, a country that had previously exported this product only rarely (Pierzchala 2025).
The European Commission reports that numerous fraudulent methods were used in re-export schemes: altering product classification and origin, establishing complex holding and trust networks disproportionate to the client’s business profile, layering offshore structures and Russia-friendly jurisdictions to conceal beneficial ownership, employing formal compliance tricks, transferring assets connected to sanctioned individuals through family members or third parties, conducting multiple chain transfers from sanctioned to non-sanctioned entities, and manipulating documentation and logistics (European Commission 2023).
The second direction that reduced the impact of sanctions was maritime shipping. To shield its revenues from the “grip” of sanctions, Russia began transporting oil through a “shadow fleet,” allowing sanctioned products to be effectively “laundered” via third countries. Between December 5, 2022—when the oil embargo and price cap mechanism came into effect—and September 2023, 36 percent of Russia’s oil exports were transported via “shadow” tankers. Research indicates that during the 16 months following the launch of the full-scale invasion, the share of shadow tankers rose from 13 percent to 42 percent (July 2023). The primary driver of this increase was not only the expansion of the fleet but also the growth in the number of voyages—shadow voyages increased by 82 percent after sanctions were imposed. Data show that approximately 69 percent of crude oil transported by shadow tankers was directed to China and India, while 29 percent went to Turkey. Furthermore, 41 percent of crude oil shadow tankers were registered in the United Arab Emirates (Levi, Katinas, Myllyvirta, Hemalatha 2023).
The third direction involved energy dependence within the EU and the resistance of countries with significant Kremlin influence to energy embargoes. Due to resistance from certain EU member states—such as Hungary and Slovakia—mandatory softening measures were introduced into sanctions packages, and exemptions were granted to those countries (Reuters 2022).
Such a situation—namely, the circumvention of sanctions through indirect channels and political pressure—confronted the European Union with the necessity of redesigning its sanctions mechanism. The four packages adopted in 2023 were specifically aimed at preventing these loopholes and ensuring the effectiveness of sanctions. The key turning point in this context was the 11th package adopted in June 2023. For the first time, it introduced anti-circumvention mechanisms. These tools enabled the EU to impose restrictions not only on Russia but also on third countries facilitating the export of sanctioned goods and technologies to Russia (European Commission 2023). Another significant milestone in the 2023 sanctions chronology was the 12th package adopted in December, which introduced restrictions on Russian-origin diamonds (European Commission 2023).
2024–2025 — The Redesign Period
The subsequent four packages adopted from 2024 to mid-2025 were primarily aimed at closing earlier loopholes and increasing practical impact on Russia. Packages 13–16 included measures restricting exports of critical components for Russia’s military industry—such as drones and sensitive technologies—by third countries and intermediaries; preventing the transshipment of Russian LNG in EU ports; blocking the entry and maritime activities of shadow fleet vessels in EU ports; banning imports of primary aluminum from Russia; and restricting access to the EU market for third-country airlines that expanded sanctions loopholes through domestic Russian flights or aviation support.
The 17th package, adopted in May 2025, was the largest sanctions package targeting Russia’s shadow fleet. The list of vessels belonging to the “hidden fleet” contributing to Russia’s energy revenues was doubled to 342, and port access and service bans were imposed on them (European Commission 2025a).
However, the two most critical and concrete documents adopted by the European Union to date are the 18th and 19th packages, adopted in the second half of 2025, as these directly target Russia’s key revenue sources.
The 18th package combines two core components aimed at reducing Russia’s energy revenues. First, it lowers the crude oil price cap from $60 to $47.6 and establishes an automatic, dynamic adjustment mechanism for future revisions. Second, it introduces a full transaction ban concerning Nord Stream 1 and Nord Stream 2, legally preventing any potential future “return.” Imports of products derived from Russian crude oil were also banned under this package. Alongside measures targeting the shadow fleet, restrictions on Russia’s banking system, and strengthened economic levers, the package added four Turkish companies and seven companies from China and Hong Kong to the sanctions list for directly or indirectly supporting Russia’s military-industrial complex (European Commission 2025).
The 19th and, for now, most recent package introduced a complete ban on imports of liquefied natural gas (LNG) from Russia—effective from early 2027 for long-term contracts and from April 2026 for short-term contracts. All exceptions allowing Rosneft and Gazprom Neft to export oil and gas to EU countries were revoked. An additional 117 vessels were added to Russia’s shadow fleet list. Furthermore, elements of financial infrastructure and measures concerning cryptocurrencies were, for the first time, addressed separately (European Commission 2025).
II. SANCTIONS IN NUMBERS AND FACTS
Within the framework of the 19 sanctions packages adopted since February 2022, the European Union has frozen approximately €210 billion in Russian sovereign (state) assets and around €28 billion in private assets under its jurisdiction (Veber 2025a). Of the frozen sovereign assets, €185 billion is held at Euroclear (a Belgium-based securities depository). Of this amount, €176 billion has been converted into cash, while the remaining €9 billion in securities will mature in 2026–2027 (Reuters 2025).
For a long time within Europe, discussions have been ongoing about directing these funds toward reparations for Ukraine under international law. Initially, the EU proposed issuing reparation loans using only the funds held at Euroclear, but Belgium has advocated including the additional €25 billion in frozen sovereign assets held in other EU countries. A large portion of these funds is held in French banks, and unlike the funds at Euroclear, Russia continues to earn interest on them (Reuters 2025).
On the other hand, many legal questions remain unresolved regarding the confiscation and management of sovereign assets. By the end of 2025, one of the two major obstacles in this area was removed: the European Union agreed to freeze the assets of the Central Bank of Russia indefinitely, eliminating the requirement for a vote every six months to renew the freeze. This decision was adopted to prevent Hungary and Slovakia from using veto threats in periodic EU voting procedures (Reuters 2025).
The other obstacle concerns the protection of Central Bank assets under the doctrine of state immunity; the conditions under which these assets could legally be used for reparations remain under question (Veber 2025b). Nevertheless, without touching the principal amount of sovereign assets, the European Union has already operationalized the use of windfall profits generated by the freezing of these assets. In particular, Belgium has imposed a 25 percent tax on profits derived from Russian Central Bank assets and directed the revenues to support Ukraine (Veber 2025). In 2024, windfall profits generated from Russian assets reached €4 billion (Seabright 2025). This amount was transferred to Ukraine in three tranches during 2024–2025 (European Commission 2025).
Since the start of Russia’s invasion, the number of individuals and legal entities sanctioned by the European Union has exceeded 2,500 (Veber 2025). These persons do not represent only Russia and Belarus—the primary actors in the sanctions packages—but also various third countries whose names have appeared in different contexts as supporters of Russia. Their citizens and companies have also been subjected to embargoes. An analysis of the 19th sanctions package shows that sanctioned foreign legal and natural persons primarily represent Tajikistan, Kyrgyzstan, the United Arab Emirates, Hong Kong, Belarus, Kazakhstan, China, India, Thailand, and Turkey. From Turkey alone, at least 17 companies have faced restrictions for allegedly assisting Russia in circumventing sanctions, and the assets of one company have been frozen (EurLexEuropa 2025).
The EU Remains the Main Buyer of Russian Pipeline Gas
When discussing sanctions, the energy sector attracts the most attention. The EU’s share of oil imports from Russia fell from 29 percent in the first quarter of 2021 to 1 percent in the third quarter of 2025 (Eurostat 2025). Russia’s share in the EU’s natural gas imports via pipeline declined from 40 percent in 2021 to 6 percent in 2025 (13 percent including LNG). In 2025, EU imports of natural gas from Russia decreased by 31 percent to 16.62 billion cubic meters.
However, in December of last year, EU gas imports from Russia increased by 13 percent compared to November. While most of this increase was due to LNG, pipeline gas imports also rose by 6 percent. The EU still accounts for 35 percent of Russia’s pipeline natural gas exports, making it the largest buyer (CREA 2025).
According to the European Commission’s roadmap, by the end of 2025 Estonia, Lithuania, Latvia, Denmark, Finland, Sweden, Germany, Poland, Croatia, Malta, Ireland, Luxembourg, Austria, and the Czech Republic had halted direct imports from Russia. However, the same document notes that some of these countries, even without direct contracts, may indirectly purchase Russian-origin gas via wholesale market mechanisms (Eur-Lex Europa 2025).
At the same time, certain countries remain highly dependent on Russia—most notably Hungary and Slovakia. These two countries argue that their geography is unsuitable for LNG terminals and therefore resist reducing imports from Russia and oppose Brussels’ decisions (Reuters 2025). In December alone last year, Hungary purchased €337 million worth of Russian energy, becoming the largest importer within the EU. During the same period, Slovakia imported €194 million worth of Russian crude oil and gas (CREA 2025).
Since January 27 of this year, when Ukraine shut down the Druzhba pipeline due to Russian missile attacks, energy tensions have risen in Central Europe. Hungary and Slovakia requested assistance from Croatia to secure Russian oil supplies. The Croatian government rejected the request, stating that more oil could be imported via the Adria pipeline (JANAF), but that it would not be Russian oil. Croatia’s Minister of Economy Ante Šušnjar stated: “A barrel of oil bought from Russia may seem cheaper to some countries, but it helps finance the war and attacks against the Ukrainian people” (Reuters 2026).
The EU Purchases Half of Russia’s LNG
Unlike oil and pipeline gas, imports of liquefied natural gas (LNG) from Russia were largely excluded from sanctions frameworks in previous years. As a result, although LNG imports from Russia initially declined at the start of the war, they began rising again from the fourth quarter of 2023 onward. Russia remains the EU’s second-largest LNG supplier after the United States (Eurostat 2025).
The EU remains the largest buyer of Russian LNG; last year it accounted for nearly half (49 percent) of Russia’s total LNG exports (CREA 2025). The largest importers of Russian LNG within Europe are France, Belgium, Spain, the Netherlands, and Portugal (European Commission 2025b). Reports indicate that in December 2025, France and Spain increased their LNG imports from Russia by 18 percent and 27 percent respectively (CREA 2025).
This situation compelled the EU to prepare a new roadmap in May 2025 aimed at fully ending dependence on Russian energy. In January of this year, the Council of the European Union announced a new decision: by 2027, LNG and natural gas imports into EU countries will be completely banned. LNG imports will cease at the beginning of 2027, while natural gas imports will stop in autumn 2027. The prohibitions will begin to be implemented in phases six weeks after the decision enters into force (2026), approximately in mid-March. There will be a transitional period for existing contracts. Before authorizing natural gas imports, EU countries must provide verified information regarding the country of origin of the gas. The EU Council has given member states until March 1 to prepare their plans in this regard (Consilium Europa 2026).
France Leads Within the EU in Purchasing Low-Enriched Uranium from Russia
Within the EU, certain countries remain dependent on Russia in the field of nuclear energy. These countries operate 19 Soviet-era nuclear reactors. In 2023, Russian fuel supplies for these reactors increased significantly, but from 2024 onward they began to decline again. Bulgaria’s and Finland’s shift toward alternative fuel suppliers has played a significant role in this trend (Bellona 2025).
The European Commission identifies Bulgaria, the Czech Republic, Finland, Hungary, and Slovakia as countries still dependent on Russian nuclear fuel. The Commission’s document also states that seven EU countries imported enriched uranium or uranium-related services from Russia in 2024, although it does not name them (Eur-Lex 2025).
However, other sources indicate that in 2024 the majority of low-enriched uranium imported into the EU from Russia was purchased by French companies—partly directly and partly through a French-owned company in Germany. While in some years prior to 2022 the EU’s share in Russia’s enriched uranium exports exceeded 50 percent, by 2024 it had fallen to 15 percent. Countries such as the Netherlands and Sweden, which previously imported uranium from Russia, halted imports after 2022. Although France has reduced its purchases, it remains the largest buyer of Russian uranium within the EU (Bellona 2025).
A Significant Portion of the “Shadow Fleet” Consists of G7+ Tankers
One of the most important methods Russia uses to circumvent oil embargoes—the “shadow fleet”—has recently become a major focus of EU attention. With the 19th sanctions package, the number of sanctioned vessels belonging to this fleet increased from 444 to 557. Ships listed by the EU are subject to port access bans and service prohibitions (European Commission 2025).
Nevertheless, facts indicate that Russian vessels operating under false flags continue transporting oil. In the final month of 2025 alone, at least 93 “shadow ships” were recorded operating under false flags, and 26 of them carried out sales of Russian crude oil and petroleum products worth €0.8 billion. Of the volume transported by tankers sailing under false flags, 46 percent (worth €380 million) passed through the Danish Straits—carried out by just 13 vessels. In the final month of 2025, Russia’s seaborne crude oil exports increased by 10 percent.
Moreover, during that period 43 percent of Russia’s crude oil and petroleum product exports were transported by G7+ tankers (G7 countries, the European Union, and Australia—the coalition implementing the oil price cap). In total, in December €176 million worth of Russian oil was transferred ship-to-ship within EU waters (CREA 2025).
III. ECONOMIC CONSEQUENCES OF THE SANCTIONS
Since 2022, EU sanctions have significantly restricted Russia’s direct access to European markets and the financial system. Since 2022, EU import bans and restrictions have covered 58 percent of the pre-war import volume, amounting to approximately €91.2 billion. Export bans and restrictions on goods and technologies are valued at €48 billion, corresponding to 54 percent of the EU’s pre-war exports to Russia. Restrictions on the export of business services are estimated at €3.28 billion (European Commission 2025).
Between the first quarter of 2022 and the third quarter of 2025, exports to Russia declined by 61 percent, while imports fell by 89 percent. In the third quarter of 2025, imports from Russia decreased by €1.4 billion compared to the same period a year earlier. The decline in exports amounted to €0.3 billion (Eurostat 2025).
However, this sharp contraction in official trade has not been sufficient to deter Russia. By redirecting part of its energy trade to Asian markets and establishing parallel import and re-export channels, Russia has been able to soften the shock of sanctions.
In December Alone, Five EU Countries Paid €1.4 Billion to Russia for Energy
Reports indicate that in December of last year, Russia’s energy revenues declined by 2 percent compared to November, falling to €500 million per day. Oil revenues decreased, while revenues from pipeline gas increased sharply by 17 percent (to €70 million per day). LNG revenues also rose by 13 percent compared to November, reaching €48 million per day. Revenue from seaborne petroleum product exports increased by 10 percent in December alone, generating €116 million per day for Russia (CREA 2025).
By the end of 2025, the EU remained Russia’s fourth-largest buyer of fossil fuels. In December alone, five EU countries paid €1.4 billion to Russia for energy purchases (CREA 2025). In addition, in December, five oil refineries in India, Turkey, and Brunei that process Russian crude oil exported petroleum products worth €943 million to sanctioning countries. The EU was again the largest importer of these products, accounting for €436 million (CREA 2025).
According to the World Bank’s 2025 assessment, Russia’s economy is expected to slow overall. This is attributed to tighter policy, weakening fiscal support and exports, the long-term burden of military expenditures, labor shortages fueled by state-directed lending, and rising credit risks. However, the Bank notes that despite this weakening, Russia continues to remain afloat through a “war economy” model (World Bank 2025).
The primary instrument Russia has used to weaken the impact of sanctions is the embargo-circumvention mechanism discussed above. Over four years, Moscow has institutionalized this mechanism—developing re-export and parallel export channels through third countries, intermediary companies, and manipulative trade practices—allowing it to partially bypass sanctions, particularly in the trade sector. Through alternative supply routes, it has continued to supply its military-industrial complex, effectively constructing a new import structure for this purpose (CEPR 2023). At the same time, it has expanded the use of the shadow fleet as a mechanism to evade energy sanctions.
CONCLUSION
The four-year picture suggests that the EU’s sanctions policy against Russia has not achieved its primary objective in the short and medium term—deterring Moscow from occupation. While sanctions have played a certain role in weakening Russia’s economy over the long term and increasing its costs, the fragmented and complex enforcement mechanisms, internal divisions within the EU, and parallel economic channels established through third countries have not been sufficient to shake Moscow’s economic resilience to a degree that would end the war. On the contrary, since 2022 Moscow has succeeded in institutionalizing a model of adaptation to the sanctions regime.
Since 2023, the EU has rightly adjusted its sanctions policy—moving from largely formal measures toward more practical steps. It has introduced sanctions in previously unregulated sectors and developed new mechanisms to prevent circumvention of existing embargoes. From the second half of 2025 onward, the EU has begun targeting more critical revenue sources—energy flows, price mechanisms, and transaction bans have entered the agenda. At the same time, concrete efforts have been undertaken to reduce energy dependence and address key legal obstacles preventing the use of Russia’s frozen assets to support Ukraine.
However, the facts presented in this article demonstrate that these efforts are still insufficient. The problem does not lie in the scale, severity, or sequencing of sanctions, but in their implementation. The EU must apply sanctions more consistently, strengthen oversight and loophole-closing mechanisms, and create or enforce mechanisms to limit the energy dependence and political leverage of Kremlin-aligned member states in order to prevent sabotage within the Union. It must also increase pressure on the “third countries” that serve as Russia’s principal supporters.
Discussions are currently underway regarding the EU’s 20th sanctions package. On February 9, the European Commission presented its proposal for the 20th package. For the first time, the proposal envisages targeting ports in third countries—specifically, sanctions on ports in Georgia and Indonesia where Russian oil is processed. It also proposes, for the first time, specific restrictions against a third country: a ban on the sale to the EU of metal-cutting equipment, modems, and audio-visual-data transmission communication devices from Kyrgyzstan. If adopted, several banks in Kyrgyzstan, Laos, and Tajikistan would also be added to the sanctions list (Reuters, February 9, 2026).
European Commission President Ursula von der Leyen stated that the EU would take serious steps to limit Russia’s ability to create alternative payment channels to finance its banking system and economic activities, that all maritime activities related to Russian crude oil would be prohibited, and that the anti-circumvention mechanism would be activated for the first time (Eunews 2026).
The timing of the adoption of the new package remains uncertain. However, one thing is clear—Russia cannot be deterred from war through lenient sanctions or symbolic measures. As the President of the European Commission expressed it, “the only language Moscow understands” is firm pressure.
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