EU sanctions (restrictive measures) explained

Last checked: 20 October 2026 · Measures explained

EU sanctions, called restrictive measures, are adopted in two steps ¹. The Council first adopts a decision under the Common Foreign and Security Policy by unanimity ¹. Where economic or financial measures such as asset freezes are needed, the Council then adopts a regulation on a joint proposal from the High Representative and the Commission ^1,3. Member states implement and enforce the measures, and the Commission oversees how they do so ^1,7. Listed persons can ask the Council to reconsider and can go to the General Court ¹.

Treaty basis for decisions: Article 29 of the Treaty on European Union ⁴
Treaty basis for regulations: Article 215 of the Treaty on the Functioning of the European Union ³
Vote on the decision: Unanimity in the Council ¹
Vote on the regulation: Qualified majority, on a joint proposal of the High Representative and the Commission ³
Who enforces: Member states, with oversight by the European Commission ^1,7
Official list of asset freezes: EU consolidated financial sanctions list, managed by DG FISMA ⁷
Court: General Court, under the Treaty on the Functioning of the European Union ^1,5
Criminal law rules: Directive (EU) 2024/1226, adopted 24 April 2024 ¹⁰

Legal basis: a decision, then a regulation

Article 29 of the Treaty on European Union lets the Council adopt decisions that define the approach of the Union to a matter of a geographical or thematic nature ⁴. Member states must bring their national policies into line with those decisions ⁴.

The Council says the High Representative proposes the measures, Council preparatory bodies examine them, and Coreper II agrees the text ¹. The Council adopts the decision by unanimity and publishes it in the Official Journal ¹.

A Council regulation is needed for asset freezes and other economic or financial measures ¹. Article 215 of the Treaty on the Functioning of the European Union says the Council acts by a qualified majority on a joint proposal from the High Representative and the Commission ³. Article 215(2) allows restrictive measures against natural or legal persons, groups and non-State entities ³. Article 215(3) says these acts must include provisions on legal safeguards ³.

Types of measures

The Council lists the main types of EU restrictive measures ². Measures can target non-EU governments, entities, groups and individuals ².

Arms embargo: a ban on exports of goods and technology on the EU military list ².
Travel ban: listed persons cannot enter or transit through EU territories ².
Asset freeze: all assets of listed individuals and entities in the EU are frozen ².
Ban on making funds available: EU persons and entities cannot make funds available to those listed ².
Economic sanctions: restrictions in the trade, defence, technology, finance, transport and energy sectors ².
Diplomatic sanctions: cutting diplomatic ties or recalling EU diplomatic representatives ².

Who must comply and who enforces

The European Commission says EU sanctions are binding on EU nationals and on people located in the EU or doing business there ⁷. They do not apply outside EU jurisdiction ⁷.

Member states are primarily responsible for implementing and enforcing EU sanctions ¹. They must have effective, proportionate and dissuasive penalties and must enforce them ⁷. The Commission, as guardian of the treaties, oversees implementation across member states ^1,7.

Directive (EU) 2024/1226 sets common rules on criminal offences and penalties for the violation of Union restrictive measures ¹⁰. It was adopted on 24 April 2024 and entered into force on 19 May 2024 ¹⁰.

Review and renewal

Type of measure	Duration and review
Measures that carry out UN decisions	No end date. They change after a UN decision ¹.
EU autonomous Council decisions	Usually apply for 12 months ¹.
Regulations that go with them	Open-ended ¹.
Mixed provisions	Reviewed at least once every 12 months ¹.

Lists and the EU Sanctions Map

DG FISMA, the Commission's financial services department, manages the consolidated list of individuals, groups and organisations subject to EU financial sanctions ⁷. The Commission says the list reflects the texts published in the Official Journal of the EU ⁷.

The EU Sanctions Map gives details of EU sanctions regimes and their legal acts, including UN regimes transposed at EU level ⁷. When it was presented in April 2022, it covered over 40 regimes ⁸. On 11 May 2022 the Commission added a consolidated list of travel bans to the map ⁹.

Challenging a listing

A listed person or entity can ask the Council to reconsider the listing and send supporting documents to the Council's General Secretariat ¹. The person can bring a case before the General Court ¹.

Article 275 of the Treaty on the Functioning of the European Union gives the Court of Justice of the European Union power to review the legality of Council decisions with restrictive measures against natural or legal persons ⁵. Cases follow the conditions in Article 263, fourth paragraph ^5,6. Article 263 sets a time limit of two months, counted from publication, notification or the day the applicant learned of the measure ⁶.

Common questions

Who decides EU sanctions?

The Council of the EU. It adopts the decision by unanimity, and the regulation on a joint proposal of the High Representative and the Commission ^1,3.

Who enforces EU sanctions?

Member states implement and enforce them and set penalties. The Commission oversees how they do this ^1,7.

Do EU sanctions apply outside the EU?

The Commission says they apply only within EU jurisdiction, binding EU nationals and people located in the EU or doing business there ⁷.

How long do EU sanctions last?

EU autonomous decisions usually apply for 12 months. Measures that carry out UN decisions have no end date ¹.

How can a listing be challenged?

By asking the Council to reconsider, and by bringing a case before the General Court within two months ^1,6.

Rules and fees change. Check the official site linked above before you apply or pay. Spotted an error? Email [email protected] with the official link.

Sources

UK sanctions explained
How UK sanctions work: the Sanctions and Anti-Money Laundering Act 2018, the FCDO's UK Sanctions List, OFSI, asset freezes, penalties and challenges.
UN Security Council sanctions explained
How UN Security Council sanctions work: Article 41 of the UN Charter, sanctions committees, panels of experts, the Consolidated List and delisting routes.
OFAC sanctions explained
What OFAC sanctions are, the legal basis under IEEPA, the SDN List, blocking, the 50 percent rule, licenses and how delisting works.
How sanctions delisting works: OFAC, UK, EU and UN
The official routes to ask for removal from OFAC, UK, EU and UN sanctions lists: who to apply to, what to send, review steps and court options.
Global Magnitsky sanctions explained
The Global Magnitsky Act of 2016 and Executive Order 13818: who can be designated, what designation does, and examples from Treasury releases.
The UK Global Anti-Corruption Sanctions Regulations 2021
What the UK Global Anti-Corruption Sanctions Regulations 2021 do, who can be designated, the measures that apply and how to check a name.
The EU Global Human Rights Sanctions Regime
The EU Global Human Rights Sanctions Regime: its legal basis, the abuses it covers, the travel ban and asset freeze, how listing works and current numbers.