BELGIUM Law and Practice Contributed by: Valerijus Ostrovskis, Coline Cauvin, Delphine Buyle and Yapa Thepkanjana, ACQUIS
1.2 Key Trends Co-Ordination With International Partners
chains, and significant financial losses from opera - tions in Russia and Belarus. Sanctions Sector Compared to 12 Months Ago Over the past year, the volume of compliance queries related to Russia has remained steady, but enforce - ment activity has notably increased as the Russian sanctions regime matures and crosses the four-year mark. Enforcement remains uneven across member states, but there is a clear uptick in investigations, seizures and asset-freezing measures, particularly in jurisdictions with stronger enforcement capacity. At the same time, the focus of EU sanctions policy continues to diversify. Iran remains a priority target, with the EU having extended and expanded its sanc - tions regime – now covering not only Iran’s military support for Russia but also threats to freedom of navi - gation in the Middle East. Enforcement attention is now firmly focused on enti - ties engaged in sanctions circumvention. The 20th package lists 60 entities subject to enhanced export restrictions, of which 28 are located in third countries such as China (including Hong Kong), Türkiye, Thai - land and the UAE. Transaction bans have also been extended to financial institutions in the Kyrgyz Repub - lic, Laos and Azerbaijan involved in activities that sig - nificantly frustrate sanctions or connect Russia to the Russian System for Transfer of Financial Messages. For the first time, the EU has deployed its Anti-Circum - vention Tool to block supplies of sanctioned goods to a third country. The Kyrgyz Republic has been for - mally designated as a jurisdiction that systematically and persistently fails to prevent the re-exportation of restricted goods from the EU to Russia. For EU-based companies, novel business models and cross-border structures carry increased circum - vention risks, which the European Commission (the “Commission”) and national regulators continue to highlight through guidance and outreach. Businesses operating through third-country channels face sharply increased scrutiny.
The EU continues to align its sanctions efforts with international partners, particularly the USA, the UK and other G7 nations. This enhanced co-ordination is designed to boost the effectiveness of sanctions and limit the scope for sanctions evasion. This includes, for instance, joint action on the G7 Oil Price Cap Coali - tion and the multilaterally co-ordinated prohibition on imports of Russian diamonds. However, alignment has become more complex. The US sanctions regime against Russia remained largely intact under the Trump administration, and the USA imposed new sanctions on Rosneft and Lukoil in October 2025. At the same time, the USA did not always move in parallel with the EU, UK and other partners, including on the July 2025 lowering of the oil price cap. The position is therefore better described as continued co-ordination among international part - ners, but with less automatic transatlantic alignment than in the earlier phase of the sanctions regime. Beyond G7 partners, the EU actively pursues sanc - tions alignment with EU candidate countries and with countries belonging to the European Free Trade Asso - ciation (EFTA) and the European Economic Area (EEA). Systemic Targeting of Circumvention The first activation of the so-called Anti-Circumven - tion Tool, the wave of third-country entity designations (China, UAE, Kyrgyzstan, Türkiye) and the extension of transaction bans to third-country financial institutions all point to a distinct enforcement phase. Combating circumvention has therefore reached a new level and has become a primary issue addressed in the new measures. Technological, Cyber and Hybrid Sanctions In response to the growing cyber and hybrid threat landscape, the EU has expanded its sanctions tar - geting cyber-attacks, disinformation and destabilising activities. In December 2025, January and April 2026, the Council of the European Union (the “Council”) adopted sanctions against individuals and entities for their involvement in Russia’s continued hybrid activi - ties, foreign information manipulation and malicious cyber-activities against the EU and its member states.
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