The Latest Developments in EU Sanctions and Export Controls

In our recent Ashurst Trade Pulse Webinar Series, titled “The Latest Developments in EU Sanctions and Export Controls”, we examined how the EU is intensifying its sanctions and export-control architecture in response to geopolitical risks, circumvention patterns, and enforcement gaps. Below are the key take-aways for businesses operating across complex international supply chains:

1. Anti-Circumvention as "Creeping Extraterritoriality"?

• Although EU sanctions do not apply extraterritorially, the EU is increasingly targeting indirect trade flows and re-exports of sensitive goods to Russia via intermediaries in third countries.
• This shift is reflected in tighter contractual “no-Russia” clauses, higher expectations for EU subsidiaries in third countries due diligence, and a growing number of third-country entities added to sanctions and export-control lists.
• Businesses are expected not only to avoid direct violations, but to actively prevent circumvention, with compliance obligations extending deeper into supply chains.

2. Geographic Hotspots and Energy-Focus

• The EU has intensified its scrutiny on trade routes through Central Asia, the South Caucasus, the Middle East, Türkiye, and parts of East Asia, where diversion risks are considered elevated.
• In parallel, enforcement around energy-related measures is tightening: this includes crude and refined petroleum products, oil price-cap compliance, shipping and insurance services, the so-called “shadow fleet”, and restrictions affecting logistics providers and trans-shipment hubs.

3. Harmonisation of Member State Sanctions Frameworks

• The EU Sanctions Harmonisation framework signals a move toward more consistent criminal enforcement across Member States, and closer cross-border coordination among prosecutors.
• At the same time, the EU is making more frequent use of horizontal sanctions regimes to designate individuals and entities implicated in human rights abuses, cyber attacks, and proliferation related activities, including Unmanned Aerial Vehicle supply chains.

4. Practical Business Implications

• Sanctions and export controls are no longer a purely transactional check: they increasingly require ongoing monitoring, contractual safeguards, and governance frameworks that address downstream and third-country risks.
• Companies face heightened exposure where compliance programmes cannot demonstrate risk-based due diligence, effective escalation mechanisms, and documented controls over distributors, logistics partners, and customers.
• Enforcement trends show a clear expectation that EU operators act proactively, not reactively, when red flags emerge.

5. Strategic Outlook

• Businesses should reassess their sanctions and export-control compliance frameworks with a focus on anti-circumvention controls, third-country risk mapping, and contractual risk allocation.
• The trajectory is clear: EU sanctions and export controls are becoming more horizontal, more enforced, and more demanding, making early adaptation a key differentiator between compliance resilience and enforcement risk.

If you missed the session, the full recording is available here: