Main messages 1

  Why this area is important 1

  What we found and recommend 11

A closer look at our observations 24

  The Commission has established extensive coordination tools to support the effective implementation of trade sanctions 24

    The Commission’s coordination framework at EU level supports implementation 25

    The Commission is regularly engaging with non-EU countries through diplomatic channels, and with other tools 31

  Trade sanctions together with anti-circumvention measures have significantly reduced trade between the EU and Russia 36

    EU-Russia trade declined sharply;some trade remains 37

    EU sanctions have been largely effective in stopping the direct export of goods Russia’s military needs most, but circumvention remains an issue 43

    The EU has put in place a range of measures to prevent circumvention with varying effectiveness 47

  Ambiguities and divergences in the EU’s legal framework can undermine uniform implementation of sanctions 57

  Varying national practices in enforcing EU trade sanctions create opportunities for “forum-shopping” 65

    “Forum-shopping” remains a key risk undermining the effective implementation of EU trade sanctions 67

    Differences in member states’ administrative capacities also affect the implementation of EU trade sanctions 74

    Initiatives are in place to address the gaps in the harmonisation of sanctions implementation 76

  Commission guidance is comprehensive but not legally binding, and information systems are not used uniformly across member states 80

    The Commission’s guidance on the implementation of sanctions covers a broad spectrum of issues despite some remaining gaps 81

    The Commission has put information-exchange systems in place, but they are not being used to their full potential 88

  The Commission’s monitoring of the effectiveness of EU trade sanctions focuses on their impact on the Russian economy and trade flows, and not on intra-EU aspects 98

    The Commission regularly monitors how the sanctions are implemented with data collection spread over different departments 100

    The absence of clearly defined criteria limits the Commission’s assessment of the economic impact of EU trade sanctions 107

    The Commission’s analysis informs the design of subsequent sanctions packages, although decisions are driven by political objectives 110