International Partnership on Human Rights and Global Diligence: Proposal for EU’s 12th Package of Sanctions

2023-10-31 | Expert publications, Sanctions

This paper argues for three specific actions that would improve the effectiveness of EU restrictive measures against Russia:

  1. Progressively trigger the third-party circumvention tool introduced through Council Regulation (EU) 2023/1214 with respect to Kazakhstan, Armenia, Belarus, Kyrgyzstan (Eurasia Economic Union countries) and Uzbekistan. There is significant evidence that these countries are being used to circumvent EU sanctions and export controls, particularly in relation to critical components to the development of Russian weaponry.
  2. Improve efforts to synchronize sanctions lists with allies, including creating a permanent inter-governmental sanctions coordination body to streamline synchronicity and information sharing.
  3. Boost member state capacity to recommend and enforce sanctions.

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