FRANCE Trends and Developments Contributed by: William Julié, Amélie Beauchemin, Camille Gosson and Elena Moreno, WJ Avocats
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As Russia’s war in Ukraine enters its fourth year, the EU has continued to expand its sanctions policy, which has increased in complexity and scope. What began as a relatively narrowly focused legal tool has transformed into a broad, strategic instrument designed to influence global behaviour. This transfor - mation raises critical questions about the effective - ness, proportionality and long-term implications of EU sanctions, particularly in light of their increasingly extraterritorial application and the controversial inclu - sion of third-country actors and family members of sanctioned individuals. Sanctions have long served as a core component of the EU’s common foreign and security policy (CFSP). Yet, recent developments reveal a significant doctrinal shift – one that moves beyond traditional state-to- state measures and ventures into the realms of family relations and international trade. This article explores two notable trends in the EU’s recent sanctions prac - tice: • the expansion of listings to non-Russian actors through individual and sectoral sanctions; and • the increasingly tenuous justifications for targeting relatives and associates of sanctioned persons. Expanding the Scope: An Increase in the Listing of Non-Russian Individuals and Entities The shift towards extraterritoriality: Regulation 269/2014 Traditionally, the EU has maintained a cautious stance on the concept of secondary sanctions, often criticis - ing the USA for imposing measures on third-country entities engaged in lawful business. However, recent
sanctions packages adopted under Council Regula - tion (EU) No 269/2014 suggest a departure from this posture. Between the 10th and 17th sanctions rounds (2023–2025), the EU systematically broadened its reach to target individuals and companies based in jurisdictions such as China, North Korea, Iran, Turkey, the UAE and Central Asia. The rationale underlying these listings is the alleged provision of goods or services that “materially sup - port” the Russian war effort or undermine the effective - ness of existing EU sanctions. For instance, through Regulation 2024/753 of the 13th package, the Coun - cil of the EU included Chinese technology firms and logistics operators deemed to have supplied Russia with dual-use goods. Similarly, with its 15th package in December 2024, the EU invoked Article 3 (1)(h) of Regulation 269/2014 to list non-Russian nationals and companies because of their role in facilitating sanc - tions evasion or materially supporting destabilising activities in Ukraine. This trajectory persisted with the adoption of the 16th sanctions package on 24 February 2025, which expanded the EU’s sanctions list to include additional non-Russian individuals and entities. Through these designations, the EU targets not the primary subjects of its restrictive measures against the Russian Fed - eration, but rather those who are alleged to materially support the direct targets and thereby undermine the overarching objectives of the EU’s sanctions policy against Russia. Thus, a clear doctrinal evolution is emerging: in con - trast to its prior focus on essentially directly involved
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