The Shape of a Twentieth EU Sanctions Package against Russia

Tuesday 23 December 2025

As the war in Ukraine enters another tense winter, the question haunting Brussels is no longer whether further sanctions are necessary but how they might be crafted to break the strategic stalemate. The European Union’s existing nineteen sanctions packages have incrementally tightened the screws upon the Russian Federation, yet the Kremlin continues to adapt, reconfigure supply chains, and lean upon a network of permissive states to obtain the goods and revenue streams upon which her war machine depends. A twentieth sanctions package must therefore be markedly different in conception: sharper in its strategic intent, more coherent in its execution, and better insulated against the evasion pipelines that have proliferated since 2022.

The essential problem is that sanctions, by their nature, lose force as targets reorient. The Russian economy has shifted decisively from integration with Europe to integration with Asia, the Middle East, and parts of Africa and Latin America. The West cannot prevent this realignment altogether, but it might still slow or complicate the Kremlin’s access to critical goods and financial instruments. To do that, a twentieth sanctions package must focus upon chokepoints, not symbols; upon enforceability, not rhetoric.

A first pillar should address extraterritorial procurement networks for dual-use goods and microelectronics. The European Union has already sanctioned a number of Chinese, Central Asian, and Middle Eastern intermediaries, but the list remains incomplete, and the pace of updating this list too slow. Evidence from Ukrainian battlefield recovery teams shows that Russian drones, glide bombs, guided missiles, and armoured vehicle systems continue to rely heavily upon Western-made components that arrive indirectly via such intermediaries. A more ambitious approach would be to introduce a graduated system of secondary sanctions upon any foreign entities that repeatedly re-export sensitive goods to Russia - and the Commission could house a unit tasked with constantly updating this list. This would involve denying such entities access to the European banking system, revoking market access in sectors such as aviation or pharmaceuticals, and imposing targeted asset freezes on their directors. Although the European Union has traditionally been reluctant to employ secondary sanctions, the scale of the Russian Federation’s evasion networks has rendered the old approach insufficient.

A second pillar should confront maritime evasion. The so-called shadow fleet transporting Russian crude oil, often in decrepit tankers operating under obscure flags of convenience, continues to provide the Kremlin with substantial revenues. Although the G7 price cap has weakened in effect (not least due to the deep discounts on Urals crude caused by cumulative sanctions regimes), its intent remains sound: to reduce Russian fiscal income by limiting the value at which her crude can be sold. The European Union might enhance this regime by requiring European insurers, reinsurers, classification societies, and shipping service providers to conduct due diligence upon any vessel suspected of carrying Russian cargoes. Where compliance is lacking, licences should be revoked. The European Union might also consider a ban on port entry for vessels linked to the shadow fleet, irrespective of cargo, to increase the commercial costs of involvement with Russian oil. Such a measure would not end Russian exports, but it would create friction, delay, and higher costs for the Kremlin’s maritime exporters.

A third pillar must target Russia’s financial capacity to sustain her war. The Central Bank of Russia has proved adept at managing sanctions pressure, but she remains vulnerable in subtle ways. One avenue is to restrict access to the European Union’s financial infrastructure for subsidiaries of foreign banks still operating in Russia. A number of European and Asian institutions maintain sizeable Russian operations and remit profits to parent companies headquartered within jurisdictions that maintain friendly relations with Brussels. By restricting these flows or subjecting them to punitive windfall taxes, the European Union might diminish the Kremlin’s access to hard currency. A further measure would involve closing remaining loopholes in cryptocurrency markets. A significant portion of payments for sanctioned goods is believed to move through decentralised exchanges or opaque digital platforms. The European Union might require all digital asset service providers operating under its jurisdiction to block transactions involving designated Russian wallet clusters, and to report attempts at circumvention to national authorities for enforcement measures.

A fourth pillar must focus on material constraints. Russia’s defence-industrial complex is expanding rapidly, yet it depends upon foreign machine tools, high-precision metal alloys, bearings, lubricants, and chemicals. The European Union should introduce an exhaustive list of manufacturing inputs for sanctioning, not merely tariffing. Tariffs invite redirection and substitution; prohibitions backed by enforcement measures choke supply. This list must be dynamic and reviewed frequently in consultation with Ukrainian military intelligence, which is uniquely placed to identify components found in captured or downed Russian equipment. The process should be transparent to industry, allowing legitimate European exporters to adjust compliance protocols.

A fifth pillar involves aviation and space. Russia continues to fly a sizeable commercial fleet maintained largely with smuggled Western parts. The safety risks are accumulating, and the economic benefit to the Kremlin is considerable because air travel remains a prestige industry, supporting both domestic legitimacy and foreign access. The European Union might sanction any third-country maintenance, repair, and overhaul facility known to service Russian aircraft, thereby isolating Russia’s civil aviation sector further. A similar approach could apply to Roscosmos, the Russian space agency, which still relies upon European-origin hardware and partnerships in subtler ways than official statements suggest.

A sixth pillar should address Russian influence operations in Europe. Although sanctions packages often include symbolic designations of propagandists and media outlets, a more practical approach would be to sanction firms and individuals who provide logistical, financial, or recruitment support for influence campaigns, cyber-operations, or networks of proxy political actors. The aim is not to police speech but to diminish the Kremlin’s capacity to finance and coordinate activities that undermine European cohesion.

Finally, a twentieth sanctions package must embed within it a mechanism for enforcement harmonisation. At present enforcement varies markedly across member states, enabling sophisticated networks to exploit disparities in customs oversight, financial regulation and corporate transparency. A centralised European sanctions bureau—with authority to investigate cross-border evasion, mandate compliance actions, and coordinate with foreign partners—would reduce these disparities. Such a bureau need not necessarily replicate the American OFAC model, but it should possess sufficient authority to impose fines and direct corrective measures across the single market.

Critics will argue that additional sanctions risk diminishing returns, or that they may provoke further retaliatory measures from Moscow. Yet the alternative—sanctions erosion and strategic drift—poses greater dangers. A twentieth sanctions package does not need to inflict immediate economic collapse upon Russia; it must simply constrain the Kremlin’s war-making potential more efficiently than at present. If crafted with intelligence, care and an eye to the loopholes that have plagued earlier packages, it might make meaningful progress towards that end.

The task before the European Union is therefore not merely to add another layer of restrictions but to rethink the structure of the sanctions architecture. War is a contest of logistics and adaptation. A sanctions regime that fails to adapt risks becoming irrelevant. A twentieth package that targets evasion networks, maritime vulnerabilities, financial conduits, industrial inputs, civil aviation and influence operations—while strengthening enforcement—would serve as a signal that Europe understands this reality, and intends to act accordingly.