European Union

The European Union is a treaty-based political and legal union that exercises economic statecraft through common commercial policy, restrictive measures, regulation, market access, finance, development instruments and economic-security measures. It is neither a state nor a private collective. Its authority and decision process vary by instrument.

Institutions and legal architecture

EU restrictive measures begin with a Common Foreign and Security Policy decision adopted by the Council of the European Union. Decisions in that field generally require unanimity. Where action falls within the scope of Article 215 of the Treaty on the Functioning of the European Union, the Council then adopts the necessary regulation on a joint proposal from the High Representative and the European Commission. The Council's adoption and review procedure records this sequence, while its voting guidance limits the unanimity rule to the relevant fields.

Member states and their competent authorities implement and enforce much of the sanctions regime within Union law. The Commission's May 2022 proposal expressly recorded that implementation and enforcement were primarily member-state responsibilities at that stage (COM(2022) 247 final). The Commission monitors implementation and supports coordination, but it does not alone police every measure. The European Council, Council of the European Union, Commission, High Representative, European Parliament, Court of Justice and member states remain distinct institutions and actors. The Council of Europe is not an EU institution.

Coercion, resilience and economic security

The Union has used restrictive measures against multiple targets and has acted as a sender, target and adapter. Its Russia regime expanded after February 2022. On 23 July 2026, the Council announced the 21st package of sanctions. The current Russia sanctions portal links to the operative legal acts, which control specific prohibitions and expiry dates.

The Commission stated in May 2026 that more than EUR 210 billion in Russian central-bank assets were immobilised in the Union and separately described the use of extraordinary revenues generated by those assets (European Commission, 18 May 2026). Immobilisation of principal, custody of assets and use of extraordinary revenues are legally distinct. A total for the Union does not by itself establish the amount held by any named custodian.

The European Economic Security Strategy organises policy around promoting competitiveness, protecting against defined risks and partnering with other states. Investment screening, dual-use controls, energy adaptation and supply-chain policy sit within this wider resilience programme. Restrictive measures adopted during an armed conflict do not by themselves make the Union a belligerent or turn every measure into wartime economic action.

Anti-coercion and autonomy

The Anti-Coercion Instrument establishes procedures for determining economic coercion by a third country and authorising Union response measures. The Council's adoption statement explains its institutional purpose but does not replace the regulation. Its procedures, legal findings and any later use must be checked in the operative record rather than inferred from political statements.

The Blocking Statute and INSTEX were distinct efforts to respond to United States extraterritorial measures. Their practical limits do not establish one general inability to act. The bounded assessment is that the Union can mobilise substantial market and regulatory power, while treaty competences, national implementation, legal review and differing member-state exposures shape the speed and reach of action.

See also

Autonomous versus multilateral sanctions · Article 215 TFEU and CFSP sanctions architecture · EU Anti-Coercion Instrument (2023) · Coalition sanctions and export controls against Russia after the full-scale invasion of Ukraine (2022-present) · Immobilised Russian assets · INSTEX · Economic coercion · Economic statecraft

Sources

• Consolidated Treaty on the Functioning of the European Union, Article 215, Official Journal C 326 (26 October 2012): 144.
• Council of the European Union, How the EU adopts and reviews sanctions, current to 29 July 2026.
• Council of the European Union, Unanimity, current to 29 July 2026.
• Council of the European Union, 21st package of sanctions: EU hits Russian energy, financial services and crypto hard (23 July 2026).
• Council of the European Union, EU sanctions against Russia, current to 29 July 2026.
• Regulation (EU) 2023/2675, on the protection of the Union and its Member States from economic coercion by third countries, Official Journal L (7 December 2023).
• Council of the European Union, Trade: Council adopts a regulation to protect the EU from third-country economic coercion (23 October 2023).
• European Commission and High Representative, European Economic Security Strategy, JOIN(2023) 20 final (20 June 2023).
• European Commission, Proposal for a Council Decision on adding violation of Union restrictive measures to the areas of crime, COM(2022) 247 final (25 May 2022).
• European Commission, Holding Russia accountable, revised 18 May 2026.