Sanctions 2026

EU Trends and Developments Contributed by: Valerijus Ostrovskis, Coline Cauvin, Yapa Thepkanjana and Delphine Buyle, ACQUIS

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Executive Summary The EU’s sanctions regime has entered a new phase of strategic maturity. Across its three most active fronts (Russia, Iran and Syria), the period from 2025 to mid- 2026 has been defined not merely by the accumula - tion of additional measures but by qualitative shifts in how the EU designs, targets and enforces its restric - tive measures framework. Against Russia, the EU has adopted seven major packages since February 2025, each building sys - tematically on the last. The most significant devel - opments are the progressive dismantling of Russia’s energy revenue base, the sustained campaign against the shadow fleet, and the landmark first use of the EU’s Anti-Circumvention Tool to impose direct export restrictions on Kyrgyzstan as a third country identi - fied as a conduit for the re-exportation of sanctioned goods. On Iran, the triggering of the Joint Comprehensive Plan of Action (JCPOA) snapback mechanism in September 2025 resulted in the reimposition of com - prehensive nuclear-linked sanctions, while the EU simultaneously created an entirely new framework addressing Iran’s interference with freedom of navi - gation in the Strait of Hormuz in light of the recent geopolitical developments. On Syria, the EU has demonstrated that sanctions can function as an instrument of positive transition support. The progressive lifting of economic sanc - tions, culminating in the restoration of the full EU-Syria Cooperation Agreement in May 2026, reflects a strate - gic decision to re-engage with post-Assad Syria while preserving targeted accountability measures against former regime figures.

The overarching trends are: • sustained and deepening pressure on Russia’s war economy; • a stronger and more geographically expansive enforcement posture; • a willingness to impose direct costs on third coun - tries considered to be facilitating circumvention; and • the capacity to deploy sanctions dynamically as a tool of both pressure and re-engagement. Introduction The EU’s sanctions architecture has undergone a period of extraordinary evolution. What began in 2022 as an urgent response to Russia’s full-scale invasion of Ukraine has since matured into one of the most sophisticated EU restrictive measures frameworks. A clear set of structural trends has emerged that togeth - er define the trajectory of EU sanctions policy for the foreseeable future. The most dominant trend is the persistent expansion of the Russia sanctions regime , with the EU progressively tightening restrictions on energy revenues, financial services and trade while closing loopholes. Alongside this sits a noticeably stronger anti - circumvention pos- ture : the listing of Kyrgyzstan under the 20th package marks a watershed, signalling that the EU is willing to impose direct costs on third-country jurisdictions that they consider to be involved in facilitating EU sanctions evasion. The Iran sanctions landscape has simultaneously diversified, with nuclear-linked, human rights and maritime navigation regimes now operating in parallel. Finally, the Syria experience illustrates the EU’s capacity to use sanctions removal as a genuine tool of foreign policy re-engagement.

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