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We need a more agile EU sanctions regime to counter the Kremlin

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The author is a commissioner for sanctions policy and an advisor to the office of the president of Ukraine.

Last month we experienced 1,000 days of violence against Ukraine. Since the beginning of the large-scale Russian invasion, the EU has provided considerable military and economic assistance to kyiv. It has also created a centralized sanctions regime against Moscow, targeting sectors, companies and individuals with asset freezes and trade measures, albeit with a somewhat myopic focus on “the next big package.”

Skeptics claim that this regime has failed to contain the Russian war effort while the Kremlin quickly adapts to our efforts to restrict its actions. However, although Russia continues its aggression against Ukraine, the sanctions do have an impact and limit the Kremlin’s ability to wage war. Since 2022, EU exports to Russia have decreased by 58 percent and imports from Russia by 86 percent. The country’s trade costs have increased significantly. The increase in interest rates to 21 percent in October, and the recent fall of the ruble against the dollarshows the tension below the surface.

And yet, through determination and quick action, the Russian war machine presses on, adapting to the measures that Brussels puts in place. Since the summer, Russian forces have been capturing Ukrainian territory at a faster pace than at any time since 2022.

Time is of the essence: the EU needs to maneuver more quickly. It recently adopted a new framework to target the individuals and entities behind Russia’s hybrid attacks that undermine the security, independence and integrity of the EU. This adds to numerous existing frameworks. However, it is estimated that up to $3 billion in officially banned Western exports reaches Russia each month. The excuse that “we don’t know how the critical components continue to pass” cannot stand. We must quickly and continually identify and enumerate infringing entities.

While a 15th sanctions package is imminent, the last time Brussels imposed new The sanctions ended four months ago. For comparison, the United Kingdom last month announced 56 new sanctions against the Russian military-industrial complex, paralyzing the supply of military equipment, in addition to sanctioning Russian-backed mercenary groups. The United States also imposed new sanctions, targeting 118 individuals and entities in Russia’s financial services sector. This is in addition to the almost 400 lists made on October 30. Both countries regularly update their lists to match Moscow’s attempts to circumvent them, allowing them to renew pressure just as the Kremlin tries to adapt.

The United States has also sanctioned entities in third countries to a greater extent than the EU, effectively preventing such actors from helping Russia overcome trade restrictions. While Europe is cautious about protecting commercial interests and “not crossing any red lines,” Chinese trade delegations are evaluating the purchase of Russian goods and companies. Institutions and companies, within and outside Europe, that facilitate financial flows and trade with Russia should be subject to EU measures as soon as their involvement is known.

The global shipping market has proven to be vulnerable to misuse, and this must be addressed systematically, starting with swift and effective sanctions and measures for the oil tankers that make up Russia’s shadow fleet. This armada of at least 600 tankers undermines the impact of sanctions on Russia’s state budget. In August 2024 alone, this shadow fleet accounted for 90 percent of Russia’s maritime crude oil shipments.

The rules-based international order is at risk: the principles of national sovereignty and fundamental human rights are under attack. While the EU debates large and complex sanctions packages, Russia receives drones from Iran and bombs and soldiers from North Korea. Failure to break the momentum of Russia and its allies will allow them to maintain the advantage at a time when global stability desperately requires firm and effective action. Ukraine faces not only Russia, but also the consequences of non-compliance with sanctions against other third countries.

An agile EU sanctions regime will enable a just and lasting peace in Ukraine. It is time to stop focusing primarily on cumbersome packages and match Russia’s ability to circumvent them. The EU may be held back by its consensus-based approach to decision-making on many issues, but sanctions do not have to be one of them. We must use the full power of the EU sanctions framework to provide vital leverage in any future negotiations.