Economic Sanctions and the Geopolitical Commission: Evaluating the Effects of Decentralized Sanctions Enforcement on the EU’s Global Actorness

In 2022, as part of a multi-country response to Russia’s full-scale invasion of Ukraine, the European Union began adopting wide-ranging restrictive measures (‘sanctions’) against Russia. Simultaneously, the EU increased its attention to sanctions enforcement, recognizing that enforcement affects its foreign policy interests. Indeed, due to historically uneven enforcement by Member States, the EU has at best a mixed reputation for enforcement. To enhance its credibility at home and abroad, the Commission has begun offering guidance on the scope of sanctions as a means of strengthening enforcement. This article analyses how the EU’s decentralized sanctions enforcement system affects its actorness, defined as its ‘capacity to act’ in a way that enables influence on the international stage, and concludes it suffers from a lack of cohesion and autonomy. It then examines whether the Commission’s guidance has strengthened the EU’s enforcement environment and, by extension, the EU’s actorness. Based on an analysis of public documents and interviews with the private sector, there exists a significant level of dissatisfaction with the guidance and continued lack of uniformity in how sanctions are enforced. Thus, the article contends that the EU’s actorness continues to suffer the complications that result from its decentralized enforcement system and concludes that because even improved guidance will not resolve this issue, broader changes should be considered to bring about meaningful improvements in the EU’s enforcement environment and actorness.