This Month in EU Sanctions

Nine consecutive Foreign Affairs Council meetings have adopted Russia-related sanctions, and 250 new listings are being prepared — the largest single round since 2022. Yet the 21st package remains under negotiation. Meanwhile, EU sanctions policy needs to tackle other issues such as the situation in Sudan, or contingency planning as the US-Iran MoU is now, in President Trump's own words, "over."

Amid this volatility, Jan Dunin-Wasowicz takes a step back with two EU sanctions scholars — Celia Challet (Université Catholique de Lille) and Francesca Finelli (University of Luxembourg) — for a mid-year review of what's been happening before the EU courts since January 2026. Topics include:

• The Pumpyanskiy appeal and the Court of Justice's ruling on criterion (g), the "leading businesspersons" listing criterion
• Why Russian oligarchs remain the core litigants — and the new categories of applicants now reaching Luxembourg: shadow fleet operators, third-country companies, the Russian Central Bank, and even Hungary and Slovakia
• The Global 8 Airlines case and the pending appeal that could reshape a key element of the EU's sanctions architecture
• Euro Asia Cargo and what the ruling means for third-country operators' compliance obligations and the anti-circumvention logic behind EU sanctions
• EM System and T Trust: how the Court has expanded the scope of asset freezes to reach 50%-owned companies and trust structures, and the cross-fertilisation between sanctions law and anti-money laundering law
• Traugott Ickeroth: the broadcasting ban, personal blogs, and why the Court broke from the Commission's own FAQ guidance
• Pending cases to watch: Reibel (arbitration and the no-claim clause) and Inter Rao Lietuva (Member States' power to list additional targets)

Chapters

00:00 – 21st package update
01:54 – Welcoming Celia Challet and Francesca Finelli
02:58 – The core of sanctions litigation: individual applicants and Russian "leading businesspersons"
04:43 – What is criterion (g)?
07:01 – Inside Pumpyanskiy: five cases, one appeal
11:12 – Beyond the oligarchs: who else is litigating?
12:30 – New applicants: shadow fleet operators, third-country companies, and the Russian Central Bank
14:51 – Procedural hurdles: standing and admissibility across different case types
15:24 – Global 8 Airlines and the fight over Commission accountability
19:59 – Circumvention and compliance: the Euro Asia Cargo case
24:58 – Scope of asset freezes: EM System and the 50% presumption of control
29:12 – T Trust: sanctions law meets anti-money laundering law
31:06 – The role of the Commission's FAQs in the Court's reasoning
34:23 – Traugott Ickeroth: broadcasting bans and personal blogs
41:14 – Looking ahead: the Reibel case and arbitration
43:16 – Looking ahead: Inter Rao Lietuva and Member State listings
44:17 – Closing thoughts

June 2026 may prove to be a pivotal moment for Iran and Russia sanctions. Following the G7's summit in Evian, which welcomed the US-Iran memorandum of understanding while explicitly committing to increased pressure on Russia's oil and gas sectors, this episode comes at a special moment.

Jan Dunin-Wasowicz welcomes Dawson Law, founder of Conseil Global Advisors and former Senior Sanctions Policy Advisor at OFAC and US Treasury Representative to the United Kingdom, for a wide-ranging conversation on US sanctions policy and its implications for the EU. Topics include:

• What the US-Iran MOU actually commits to, what it doesn't, and what it means for business and compliance
• What US sanctions relief on Iran's nuclear program would mean for the EU, given that the MOU leaves human rights, ballistic missiles, and Iran's regional proxies — including support for Russia — entirely unaddressed
• The G7's explicit linkage between Hormuz de-escalation and intensified Russia pressure — and whether US action will follow the rhetoric
• How US perceptions of the EU as a sanctions actor have evolved, and how the EU has become more disruptive through sophisticated network-based targeting
• Findings from a new report on the A7 network, a Russia-linked sanctions evasion network moving over $25 billion through SWIFT, including the use of AI-generated fake invoices
• Emerging EU-UK-US convergence on sanctions targeting migrant smuggling, and the secondary sanctions exposure created by US cartel designations in Mexico, Venezuela and Brazil

All of this as the EU extended the Russia sanctions for one year and the 21st package is on the horizon.

Chapters

00:00 – Mid-June 2026 EU Sanctions Update
07:09 – Welcoming Dawson Law
07:39 – What does the US-Iran MOU actually say?
09:26 – A framework, not a final deal
11:16 – Performance-based relief: the undefined conditions
13:03 – Frozen assets, oil export licenses, and political sensitivities
14:10 – The Congressional pathway to sanctions relief
15:32 – Lessons from the JCPOA: legal permission vs. business appetite
19:02 – What the MOU leaves unaddressed — and the EU's overlapping concerns
20:41 – The G7's enthusiasm in Évian — what's driving it
22:08 – The G7's Russia pivot: rhetoric or real action?
25:19 – How the US view of the EU as a sanctions actor has evolved
28:10 – From symbolic measures to network-based targeting
29:52 – The EU, the US, and the G7 as a coordination platform
33:27 – Inside the A7 network: $25 billion in evasion, AI-generated fake invoices
36:08 – Compliance lessons: correspondent banking and pattern detection
38:42 – Closing thoughts: migrant smuggling sanctions and cartel-related exposure

EU sanctions are no longer only about restricting trade or freezing assets. Increasingly, they sit at the center of a much wider debate about economic security, resilience, strategic autonomy, and the EU’s ability to project power in a fragmented geopolitical landscape. Beyond law and compliance, how does an economic perspective approach EU sanctions?

Following the recent adoption of the EU’s 20th Russia sanctions package — and what may prove to be a broader turning point in EU sanctions policy — the latest episode of This Month in EU Sanctions welcomes Maria Demertzis, Professor of Economic Policy at the Florence School of Transnational Governance.

The discussion explores the evolving role of EU sanctions, the economics of coercion, and why the future of EU economic statecraft may depend as much on reducing vulnerabilities, finding leverage, and speaking with one voice as on the sanctions themselves.

In episode 10 of the podcast, Jan Dunin-Wasowicz provides an update on the latest developments as Russia’s war of aggression against Ukraine enters its fifth year, highlighting how overlapping geopolitical crises are placing new pressure on the EU’s sanctions framework. Against the backdrop of escalating tensions in the Middle East, the discussion underscores the growing complexity of managing intersecting sanctions regimes and the increasing need for strategic readiness in an uncertain global environment.

The episode reflects on recent remarks by Ursula von der Leyen, who has emphasized that the EU can no longer rely solely on the traditional rules-based international system, but must instead “build its own path.” This sets the stage for a broader exploration of the future direction of EU sanctions law and policy, including what a more coherent and autonomous EU sanctions doctrine might look like, and how compliance frameworks must evolve in response to overlapping geopolitical shocks.

The show then welcomes Paschalis Paschalidis for an in-depth discussion on how EU sanctions are reshaping the landscape of international dispute resolution. The conversation examines the growing role of sanctions in driving litigation, arbitration, and complex cross-border disputes, with particular focus on contractual claims, investment protection, enforcement challenges, and jurisdictional questions.

CHAPTERS

00:00 - Overlapping geopolitical shocks and impact on EU sanctions

04:50 - Introducing Paschalis Paschalidis

07:59 - General impact of EU sanctions on the litigation and arbitration practice

08:55 - How do disputes about EU sanctions arise?

12:00 - Mapping sanctions-related claims

16:00 - Anti-suit and anti-anti-suit injunctions

20:08 - New attitudes towards litigation and arbitration

21:05 -The relationship between the EU legal order, sanctions, and arbitration

27:28 - Reviewing awards dealing with EU sanctions issues

29:13 - EU sanctions and investment-state arbitration

33:31 – Force majeure and sanctions clauses

 39:34 – Looking ahead: rules-based international order and dispute resolution

In episode 08 of the podcast, Jan Dunin-Wasowicz provides an update on January 2026 developments, focusing on the importance of readiness in adaptation. The show then welcomes Rūta Bajarūnaitė, Head of the Sanctions Policy Team at the Ministry of Foreign Affairs of the Republic of Lithuania. The conversation touches on the evolving landscape of EU sanctions in response to geopolitical crises, particularly focusing on the implications of Russia's war of aggression against Ukraine. A discussion on the past, present and future of EU sanctions law and policy from a Lithuanian perspective.

CHAPTERS

00:00 January 2026 Updates

03:29 Introducing Rūta Bajarūnaitė, the Lithuanian Framework for EU Sanctions Implementation and Current Priorities

08:03 Lessons from 2022 and Initial Responses to the Full-scale Invasion of Ukraine

19:44 Protecting the EU's External Borders

22:51 Tackling Circumvention of EU Sanctions

25:31 Exemptions & Enforcement

34:40 Interpretation - the Notion of Control

39:52 Compliance Expectations - the Example of Best Efforts

46:30 2026 Outlook

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In episode 07 of the podcast, Jan Dunin-Wasowicz provides an update on the EU's response to the U.S.-led peace proposal and implications for EU sanctions against Russia. The show then welcomes Celia Challet, Assistant Professor in Law and Public Policy at the Université Catholique de Lille to discuss the growing role of the Court of the Justice of the EU in interpreting EU sanctions through references for preliminary rulings.

CHAPTERS

0:00 Introduction

1:55 EU Responses to the U.S-led Pease Initiative and Implications for EU Sanctions

7:49 Introducing Celia Challet

9:01 EU Sanctions Litigation - Validity v. Interpretation

11:45 Basics of References for Preliminary Rulings

15:26 Examples of EU Sanctions Issues Raised (Rosneft, Afrasiabi)

18:54 The Court's Contribution to EU Sanctions

20:35 Examples of Practical Questions

26:24 Notions of Economic Resources, Ownership & Control

28:05 Jurisdictional Questions

31:01 Canons of Interpretation

40:48 Looking Ahead

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In episode 06 of the podcast, host Jan Dunin-Wasowicz discusses the proposed 19th package of EU sanctions against Russia and G7 developments, the reimposition by the EU of comprehensive sanctions against Iran, as well as the latest update to the EU Dual Use Regulation. The show then welcomes Marcin Lukowski, a Warsaw-based trade compliance expert, for a conversation on the legal framework for implementation and enforcement of sanctions and export controls in Poland.

0:00 Introduction

1:20 Russia Sanctions, Iran Snapback and Dual Use Regulation Updates

6:29 A Discussion with Marcin Lukowski on the Polish Sanctions Framework

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In episode 05 of the podcast, host Jan Dunin-Wasowicz discusses select summer 2025 developments in EU sanctions and export controls, focusing on the 18th package and the potential 19th package of EU sanctions against Russia. The show welcomes Ingrid Breit, Deputy Head of Unit within the Directorate-General for Justice and Consumers (DG JUST) at the European Commission, for a conversation on Directive (EU) 2024/1226 of the European Parliament and of the Council of 24 April 2024 on the definition of criminal offences and penalties for the violation of Union restrictive measures.

0:00 Introduction

1:12 18th Package, Iran Snapback, Israel Updates

3:50 A Discussion with Ingrid Breit on the EU Sanctions Directive

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Episode 04 of the podcast offers a mid-year review of key developments in EU sanctions, with a deep dive on the state of play of the Russia and Syria sanctions. The episode then discusses the increasingly complex relationship between EU sanctions and international arbitration, taking Case C-802/24 (Reibel v. Stankoimport) and the "no claims clause" as an example. 

0:00 Introduction

2:26 EU Russia Sanctions Status Update

11:40 EU Syria Sanctions Update

17:00 Sanctions Compliance & Enforcement Updates

18:20 EU Sanctions & Arbitration - Introducing Case C-802/24 (Reibel v. Stankoimport)

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In the third episode of the podcast, host Jan Dunin-Wasowicz discusses select April 2025 developments in EU sanctions and export controls, focusing on the potential renewed convergence between the EU and the US on Russia sanctions. The show welcomes Jan Lepeu of the European University Institute for a conversation on the history of EU sanctions and the growing role of the European Commission as an architect of EU foreign policy.

0:00 Introduction

1:11 April 2025 EU Sanctions & Export Control Updates

4:32 A Discussion with Jan Lepeu on the History of EU Sanctions

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