Restrictive measures – also known as sanctions – serve as an essential tool for the EU to prevent conflicts or address emerging or ongoing crises. They are directed at non-EU countries, but are enforceable only within the bloc’s jurisdiction. The EU imposed its most comprehensive sanctions following Russia’s full-scale invasion of Ukraine in 2022: these included financial and trade sanctions, asset freezes, and travel bans. They mainly affect Russia, but also Belarus and Iran. However, the effectiveness of this tool – as well as the integrity of the EU’s internal market – could suffer if they are not applied consistently by EU countries. The auditors will examine whether the European Commission helps EU countries to apply trade sanctions effectively, and whether it keeps a close eye on the way they implement them. They will also assess whether the Commission has investigated the overall impact of the measures.

Sanctions are an EU foreign policy instrument which aims to encourage a change in harmful or destabilising policies by non-EU countries. Their objectives include promoting international peace and security, preventing conflicts, and supporting democracy. They fall into two categories: those that affect international trade and commerce, and those that affect the financial sphere. Both can affect individuals, entities, or countries. The obligations that are imposed are binding on EU nationals in any location; on organisations and companies incorporated under the law of an EU member state – including branches of EU companies in third countries; and on board aircraft or vessels that come under the jurisdiction of EU member states.

The Council of the EU agrees on the measures, following preparatory work by the European External Action Service (EEAS). EU countries are primarily responsible for enforcement. They must operate within the framework designed by the Council, and cooperate with the Commission in this regard. However, their systems for implementing sanctions vary in some crucial respects, such as the number of national authorities dealing with them and the way infringements are prosecuted. The Commission therefore has overall responsibility for monitoring the measures, and ensuring they are implemented harmoniously throughout the EU.

In terms of trade sanctions, a total of 20 different countries are affected by EU sanctions, with a primary focus on import and export bans on military equipment and dual-use goods, i.e. those that could be used for both civilian and military purposes. Since March 2014, the EU has progressively imposed trade sanctions on Russian imports and exports in specific economic sectors, including energy, raw materials, aircraft and advanced technology, dual-use goods, luxury products, and diamonds. The EU has also imposed trade sanctions on other countries such as Belarus and Iran in response to their apparent collaboration in Russia’s military aggression against Ukraine. Moreover, in 2024 the EU significantly expanded the list of entities targeted by military and dual-use export restrictions, adding companies from China, Kazakhstan, Kyrgyzstan, India, Serbia, Thailand, Sri Lanka, Turkey, and the United Arab Emirates.

The EEAS estimates that the total value to date of export restrictions and bans on goods and technologies for Russia is €52 billion, i.e. 58 % of the EU’s exports to Russia before the invasion. In terms of imports, the impact of the restrictive measures is estimated to be around €95 billion, i.e. about 61 % of pre-war imports from Russia.

The audit will focus on trade sanctions, including their circumvention. The report is expected in about a year’s time. Until then, the auditors will keep radio silence in order to avoid compromising any of their work. They will be checking whether the Commission has established a robust framework to support the implementation of sanctions, addressed any loopholes in a timely manner, and assessed the overall impact of the sanctions. They will carry out audit visits in a handful of EU countries.