This Month in EU Sanctions

Nine consecutive Foreign Affairs Council meetings have adopted Russia-related sanctions, and 250 new listings are being prepared — the largest single round since 2022. Yet the 21st package remains under negotiation. Meanwhile, EU sanctions policy needs to tackle other issues such as the situation in Sudan, or contingency planning as the US-Iran MoU is now, in President Trump's own words, "over."Amid this volatility, Jan Dunin-Wasowicz takes a step back with two EU sanctions scholars — Celia Challet (Université Catholique de Lille) and Francesca Finelli (University of Luxembourg) — for a mid-year review of what's been happening before the EU courts since January 2026. Topics include:The Pumpyanskiy appeal and the Court of Justice's ruling on criterion (g), the "leading businesspersons" listing criterionWhy Russian oligarchs remain the core litigants — and the new categories of applicants now reaching Luxembourg: shadow fleet operators, third-country companies, the Russian Central Bank, and even Hungary and SlovakiaThe Global 8 Airlines case and the pending appeal that could reshape a key element of the EU's sanctions architectureEuro Asia Cargo and what the ruling means for third-country operators' compliance obligations and the anti-circumvention logic behind EU sanctionsEM System and T Trust: how the Court has expanded the scope of asset freezes to reach 50%-owned companies and trust structures, and the cross-fertilisation between sanctions law and anti-money laundering lawTraugott Ickeroth: the broadcasting ban, personal blogs, and why the Court broke from the Commission's own FAQ guidancePending cases to watch: Reibel (arbitration and the no-claim clause) and Inter Rao Lietuva (Member States' power to list additional targets)Chapters00:00 – 21st package update01:54 – Welcoming Celia Challet and Francesca Finelli02:58 – The core of sanctions litigation: individual applicants and Russian "leading businesspersons"04:43 – What is criterion (g)?07:01 – Inside Pumpyanskiy: five cases, one appeal11:12 – Beyond the oligarchs: who else is litigating?12:30 – New applicants: shadow fleet operators, third-country companies, and the Russian Central Bank14:51 – Procedural hurdles: standing and admissibility across different case types15:24 – Global 8 Airlines and the fight over Commission accountability19:59 – Circumvention and compliance: the Euro Asia Cargo case24:58 – Scope of asset freezes: EM System and the 50% presumption of control29:12 – T Trust: sanctions law meets anti-money laundering law31:06 – The role of the Commission's FAQs in the Court's reasoning34:23 – Traugott Ickeroth: broadcasting bans and personal blogs41:14 – Looking ahead: the Reibel case and arbitration43:16 – Looking ahead: Inter Rao Lietuva and Member State listings44:17 – Closing thoughts

June 2026 may prove to be a pivotal moment for Iran and Russia sanctions. Following the G7's summit in Evian, which welcomed the US-Iran memorandum of understanding while explicitly committing to increased pressure on Russia's oil and gas sectors, this episode comes at a special moment.Jan Dunin-Wasowicz welcomes Dawson Law, founder of Conseil Global Advisors and former Senior Sanctions Policy Advisor at OFAC and US Treasury Representative to the United Kingdom, for a wide-ranging conversation on US sanctions policy and its implications for the EU. Topics include:What the US-Iran MOU actually commits to, what it doesn't, and what it means for business and complianceWhat US sanctions relief on Iran's nuclear program would mean for the EU, given that the MOU leaves human rights, ballistic missiles, and Iran's regional proxies — including support for Russia — entirely unaddressedThe G7's explicit linkage between Hormuz de-escalation and intensified Russia pressure — and whether US action will follow the rhetoricHow US perceptions of the EU as a sanctions actor have evolved, and how the EU has become more disruptive through sophisticated network-based targetingFindings from a new report on the A7 network, a Russia-linked sanctions evasion network moving over $25 billion through SWIFT, including the use of AI-generated fake invoicesEmerging EU-UK-US convergence on sanctions targeting migrant smuggling, and the secondary sanctions exposure created by US cartel designations in Mexico, Venezuela and BrazilAll of this as the EU extended the Russia sanctions for one year and the 21st package is on the horizon.Chapters00:00 – Mid-June 2026 EU Sanctions Update07:09 – Welcoming Dawson Law07:39 – What does the US-Iran MOU actually say?09:26 – A framework, not a final deal11:16 – Performance-based relief: the undefined conditions13:03 – Frozen assets, oil export licenses, and political sensitivities14:10 – The Congressional pathway to sanctions relief15:32 – Lessons from the JCPOA: legal permission vs. business appetite19:02 – What the MOU leaves unaddressed — and the EU's overlapping concerns20:41 – The G7's enthusiasm in Évian — what's driving it22:08 – The G7's Russia pivot: rhetoric or real action?25:19 – How the US view of the EU as a sanctions actor has evolved28:10 – From symbolic measures to network-based targeting29:52 – The EU, the US, and the G7 as a coordination platform33:27 – Inside the A7 network: $25 billion in evasion, AI-generated fake invoices36:08 – Compliance lessons: correspondent banking and pattern detection38:42 – Closing thoughts: migrant smuggling sanctions and cartel-related exposure

EU sanctions are no longer only about restricting trade or freezing assets. Increasingly, they sit at the center of a much wider debate about economic security, resilience, strategic autonomy, and the EU’s ability to project power in a fragmented geopolitical landscape. Beyond law and compliance, how does an economic perspective approach EU sanctions?Following the recent adoption of the EU’s 20th Russia sanctions package — and what may prove to be a broader turning point in EU sanctions policy — the latest episode of This Month in EU Sanctions welcomes Maria Demertzis, Professor of Economic Policy at the Florence School of Transnational Governance.The discussion explores the evolving role of EU sanctions, the economics of coercion, and why the future of EU economic statecraft may depend as much on reducing vulnerabilities, finding leverage, and speaking with one voice as on the sanctions themselves.

In episode 10 of the podcast, Jan Dunin-Wasowicz provides an update on the latest developments as Russia’s war of aggression against Ukraine enters its fifth year, highlighting how overlapping geopolitical crises are placing new pressure on the EU’s sanctions framework. Against the backdrop of escalating tensions in the Middle East, the discussion underscores the growing complexity of managing intersecting sanctions regimes and the increasing need for strategic readiness in an uncertain global environment.The episode reflects on recent remarks by Ursula von der Leyen, who has emphasized that the EU can no longer rely solely on the traditional rules-based international system, but must instead “build its own path.” This sets the stage for a broader exploration of the future direction of EU sanctions law and policy, including what a more coherent and autonomous EU sanctions doctrine might look like, and how compliance frameworks must evolve in response to overlapping geopolitical shocks.The show then welcomes Paschalis Paschalidis for an in-depth discussion on how EU sanctions are reshaping the landscape of international dispute resolution. The conversation examines the growing role of sanctions in driving litigation, arbitration, and complex cross-border disputes, with particular focus on contractual claims, investment protection, enforcement challenges, and jurisdictional questions.CHAPTERS00:00 - Overlapping geopolitical shocks and impact on EU sanctions04:50 - Introducing Paschalis Paschalidis07:59 - General impact of EU sanctions on the litigation and arbitration practice08:55 - How do disputes about EU sanctions arise?12:00 - Mapping sanctions-related claims16:00 - Anti-suit and anti-anti-suit injunctions20:08 - New attitudes towards litigation and arbitration21:05 -The relationship between the EU legal order, sanctions, and arbitration27:28 - Reviewing awards dealing with EU sanctions issues29:13 - EU sanctions and investment-state arbitration33:31 – Force majeure and sanctions clauses 39:34 – Looking ahead: rules-based international order and dispute resolution

In episode 08 of the podcast, Jan Dunin-Wasowicz provides an update on January 2026 developments, focusing on the importance of readiness in adaptation. The show then welcomes Rūta Bajarūnaitė, Head of the Sanctions Policy Team at the Ministry of Foreign Affairs of the Republic of Lithuania. The conversation touches on the evolving landscape of EU sanctions in response to geopolitical crises, particularly focusing on the implications of Russia's war of aggression against Ukraine. A discussion on the past, present and future of EU sanctions law and policy from a Lithuanian perspective.CHAPTERS00:00 January 2026 Updates03:29 Introducing Rūta Bajarūnaitė, the Lithuanian Framework for EU Sanctions Implementation and Current Priorities08:03 Lessons from 2022 and Initial Responses to the Full-scale Invasion of Ukraine19:44 Protecting the EU's External Borders22:51 Tackling Circumvention of EU Sanctions25:31 Exemptions & Enforcement34:40 Interpretation - the Notion of Control39:52 Compliance Expectations - the Example of Best Efforts46:30 2026 OutlookSubscribe on LinkedIn https://www.linkedin.com/build-relati...Subscribe on Substack: https://eusanctions.substack.com/ Hosted on Acast. See acast.com/privacy for more information.

In episode 07 of the podcast, Jan Dunin-Wasowicz provides an update on the EU's response to the U.S.-led peace proposal and implications for EU sanctions against Russia. The show then welcomes Celia Challet, Assistant Professor in Law and Public Policy at the Université Catholique de Lille to discuss the growing role of the Court of the Justice of the EU in interpreting EU sanctions through references for preliminary rulings.CHAPTERS0:00 Introduction1:55 EU Responses to the U.S-led Pease Initiative and Implications for EU Sanctions7:49 Introducing Celia Challet9:01 EU Sanctions Litigation - Validity v. Interpretation11:45 Basics of References for Preliminary Rulings15:26 Examples of EU Sanctions Issues Raised (Rosneft, Afrasiabi)18:54 The Court's Contribution to EU Sanctions20:35 Examples of Practical Questions26:24 Notions of Economic Resources, Ownership & Control28:05 Jurisdictional Questions31:01 Canons of Interpretation40:48 Looking AheadSubscribe on LinkedIn https://www.linkedin.com/build-relation/newsletter-follow?entityUrn=7202058107378647044Subscribe on Substack: This Month in EU Sanctions | Jan Dunin-Wasowicz | Substack Hosted on Acast. See acast.com/privacy for more information.

In episode 06 of the podcast, host Jan Dunin-Wasowicz discusses the proposed 19th package of EU sanctions against Russia and G7 developments, the reimposition by the EU of comprehensive sanctions against Iran, as well as the latest update to the EU Dual Use Regulation. The show then welcomes Marcin Lukowski, a Warsaw-based trade compliance expert, for a conversation on the legal framework for implementation and enforcement of sanctions and export controls in Poland.0:00 Introduction1:20 Russia Sanctions, Iran Snapback and Dual Use Regulation Updates6:29 A Discussion with Marcin Lukowski on the Polish Sanctions FrameworkSubscribe on Substack: This Month in EU Sanctions | Jan Dunin-Wasowicz | Substack Hosted on Acast. See acast.com/privacy for more information.

In episode 05 of the podcast, host Jan Dunin-Wasowicz discusses select summer 2025 developments in EU sanctions and export controls, focusing on the 18th package and the potential 19th package of EU sanctions against Russia. The show welcomes Ingrid Breit, Deputy Head of Unit within the Directorate-General for Justice and Consumers (DG JUST) at the European Commission, for a conversation on Directive (EU) 2024/1226 of the European Parliament and of the Council of 24 April 2024 on the definition of criminal offences and penalties for the violation of Union restrictive measures.0:00 Introduction1:12 18th Package, Iran Snapback, Israel Updates3:50 A Discussion with Ingrid Breit on the EU Sanctions DirectiveSubscribe on Substack: This Month in EU Sanctions | Jan Dunin-Wasowicz | Substack Hosted on Acast. See acast.com/privacy for more information.

Episode 04 of the podcast offers a mid-year review of key developments in EU sanctions, with a deep dive on the state of play of the Russia and Syria sanctions. The episode then discusses the increasingly complex relationship between EU sanctions and international arbitration, taking Case C-802/24 (Reibel v. Stankoimport) and the "no claims clause" as an example. 0:00 Introduction2:26 EU Russia Sanctions Status Update11:40 EU Syria Sanctions Update17:00 Sanctions Compliance & Enforcement Updates18:20 EU Sanctions & Arbitration - Introducing Case C-802/24 (Reibel v. Stankoimport) Hosted on Acast. See acast.com/privacy for more information.

In the third episode of the podcast, host Jan Dunin-Wasowicz discusses select April 2025 developments in EU sanctions and export controls, focusing on the potential renewed convergence between the EU and the US on Russia sanctions. The show welcomes Jan Lepeu of the European University Institute for a conversation on the history of EU sanctions and the growing role of the European Commission as an architect of EU foreign policy.0:00 Introduction1:11 April 2025 EU Sanctions & Export Control Updates4:32 A Discussion with Jan Lepeu on the History of EU Sanctions Hosted on Acast. See acast.com/privacy for more information.