Sanctions 2026

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

for over a decade, including those covering imports of Syrian oil, petroleum products, gold and precious metals, and creates the legal framework within which European businesses and financial institutions can begin to normalise commercial relations with Syria. Renewal of Assad regime measures and targeted delisting The EU’s approach remains carefully calibrated. On 18 May 2026, the Council renewed the restrictive measures targeting individuals and entities linked to the former Assad regime for another year, while simul - taneously delisting certain entities that no longer met the criteria for designation. This dual action (renewing accountability measures while removing entities that no longer warrant listing) reflects the EU’s intention to achieve accountability for past atrocities without deterring legitimate commercial re-engagement. The active management of the delisting process dem - onstrates that the EU’s Syria sanctions framework – unlike the more entrenched Russia regime – is being calibrated dynamically to reflect evolving geopolitical conditions. Looking ahead on Syria Despite the lifting of most economic measures, a range of security-based prohibitions, individual asset freezes and sector-specific controls remain in place. Clients engaging with Syria in trade, investment or financial services should conduct careful sanctions screening and jurisdiction-specific legal analysis before committing to transactions. Conclusion The period from 2025 to mid-2026 represents a defin - ing chapter in the development of the EU’s sanctions regimes. Across all three jurisdictions examined, the EU has demonstrated strategic intent, legislative inno - vation and geopolitical purpose. Against Russia, the cumulative effect of seven major packages is a sanctions framework of exceptional scope. The most significant structural development is the first use of the Anti-Circumvention Tool against a third country, Kyrgyzstan. The EU has demonstrated that it will impose systemic trade restrictions on juris - dictions facilitating evasion, rather than merely des - ignating individual companies within them. This is a

fundamental escalation in enforcement posture whose implications extend well beyond Russia sanctions alone. The proposed 21st package, with its extension of sanctions into fisheries and its proposed full ban on third-country crypto platforms, signals that the regime will continue to broaden in scope and sophistication. Against Iran, the EU is managing its most complex and multi-layered sanctions architecture to date. The Strait of Hormuz navigation framework sets a prec - edent for the use of EU sanctions to enforce inter - national maritime law that may be applied in other strategic contexts in the future. For Syria, the EU has shown that sanctions can be deployed as a genuine foreign policy instrument in both directions: as pressure and as re-engagement, calibrated to political reality. The sequenced unwind - ing of the Syria sanctions programme offers a model that may inform future post-conflict transitions. Looking beyond 2026, businesses and legal practi - tioners should expect: • continued expansion of Russia sanctions, with anti-circumvention measures becoming more geographically targeted, energy restrictions more comprehensive, and digital finance restrictions more sophisticated; • intensified enforcement, with growing pressure on national competent authorities across EU member states to harmonise implementation and pursue violations more robustly; • greater third-country exposure, as the Kyrgyzstan precedent incentivises the EU to apply similar tools to other high-risk re-export jurisdictions; • persistent pressure on Iran, with any easing of restrictive measures contingent on verifiable policy change by Tehran; and • continued Syria engagement, requiring practition - ers to navigate a layered legal landscape where broad economic sanctions have been lifted but targeted restrictions remain.

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