Approaching the EU Sanctions Policy: An Experiment with Event Analysis

For a long time, the U.S. has been a global leader in terms of use of unilateral sanctions. However, the EU is getting increasingly active as sanctions initiator. Currently, the EU runs at least 26 regimes of sanctions to address relations with foreign states or tackle functional problems like human rights, non-proliferation, cyber security or counterterrorism. Russia is one of the targets. The EU sanctions policy raises a number of research questions. How active is the EU policy in comparison with other initiators? What are the peculiarities of the EU institutional process of sanctions implementation? What are the key targets and what is the distribution of EU decisions and actions among those targets? To address these questions the article provides analysis of Sanctions Events Database (SED), designed by Russian International Affairs Council. The research implies empirical analysis of EU sanctions policy everyday events in 2020. It also covers sanctions and enforcement actions of separate EU members as well as alignment with the EU sanctions of the third countries. The article attempts to fill in the gap in the literature between quantitative analysis of multiple sanctions cases on the one hand and in-depth analysis of particular cases on the other. It puts a special focus on EU sanctions related to Russia.

The EU has become a significant actor that makes use of restrictive measures. It is far behind the U.S. but it is also far ahead of all other countries and international organizations, the UN included. Our data demonstrates that the EU has its own sanctions agenda that does not duplicate that of the U.S.

Within the EU’s sanctions practice, the number of positive events is far smaller than that of negative and neutral events. This is also typical of other initiators. Decision-making processes on sanctions are dominated by the Council of the European Union, with its decisions drafted by the European Commission. The example of Cyprus voting against Belarusian sanctions in 2020 demonstrated that the Council’s consensus over restrictions is not predetermined. Visa restrictions and blocking financial sanctions are the EU’s key sanctions instruments.

Russia is the key target of EU sanctions as regards the number of events. Anti-Russian restrictions are imposed under several mechanisms at once. The decisions are mainly manifested in targeted sanctions, prolongations of existing regimes, declarations or dismissals of court claims. So far, the EU is at odds with the U.S. over sanctions on Nord Stream 2.

First published: Timofeev, Ivan (2021). Approaching the EU Sanctions Policy: An Experiment with Event Analysis // Contemporary Europe, No 2. Pp. 17-27. DOI: http://dx.doi.org/10.15211/soveurope220211727

Sanctions are one of the defining features of the EU’s foreign policy. In this article, sanctions stand to mean unilateral restrictions imposed on states, organizations or individuals in pursuit of specific foreign policy objectives. These might include forcing the target state to change its behavior, containing it or sending it a message that a policy or certain actions are unacceptable [Giumelli 2016: 38–59]. Sanctions encompass financial, trade, visa and other restrictions. As a rule, these are unilateral restrictions initiated without UN Security Council approval. Sanctions are important for the EU for a number of reasons. While the EU has limited military and political capabilities, it does have tremendous economic power. EU restrictions can cause damage to target states or individuals, forcing them to behave in a particular way or punishing them for specific actions. Sanctions allow Brussels to partially make up for the scant military power and to use its economic potential for political purposes. Besides, sanctions can be seen as a symbol of unity among the EU member states on key international dossiers.

For a long time, the U.S. has remained the world leader in exertion of sanctions [Hufbauer et al 2009: 113—124]. Even so, since the Maastricht Treaty, the EU has become a noticeable initiator of sanctions. So far, the EU has imposed no fewer than 26 country- and function-based restriction regimes [1]. In particular, the EU makes active use of sanctions against Russia.

This makes the case for a number of research questions. How active is the EU in its sanctions policies in comparison to the U.S. and other initiators as of today? What are the specific features of the EU institutional mechanism as regards sanctions policy? Which countries and functional areas are the key targets of the EU restrictions and how are the EU’s political decisions and actions in imposing sanctions distributed between them?

In his recent work, Francesco Giumelli, an eminent scholar of the EU’s sanctions policy, refers to these questions as to “what, where, when, and why”: what specific steps does the EU take? in relation to which state or actor? during which period and for what reason? In 2020, Giumelli et al compiled the most systematized database of EU sanctions [Giumelli et al 2020]. In terms of its structure, it is similar to the earlier studies of UN sanctions [Biersteker et al, 2016], where cases and episodes are the basic observation units. A case has to do with the aggregate number of sanctions targeting a particular state or related to a particular subject. An episode usually means an individual action within a case. Giumelli’s team analyzed 48 cases and 85 episodes of the EU’s sanctions over the period of 1989 through 2019. They found that the number of EU-related cases and episodes is steadily growing, with this growth picking up in pace since 2010. The study conducted by Giumelli and his team deserves credit for defining the types of EU sanctions—including financial restrictions, blocking of assets, visa restrictions, trade embargos, diplomatic measures, restrictions on sales of weapons and dual-purpose commodities. They have also developed a typology of the motives for sanctions—human rights and democracy, influence on conflicts abroad and post-conflict dynamics, opposing non-proliferation regimes, counterterrorism, etc. Unlike the previous studies [such as Portela 2010], the authors did not set themselves the objective of assessing the effectiveness of the EU’s sanctions policy.

Giumelli’s approach to studying sanctions policy is an example of macroanalysis, which means researching sanctions as a set of cases. An opposite approach is an in-depth study of individual cases, such as studying sanctions policy against individual states or targets [see, for instance, Connolly 2018].

This article offers a third approach. Like Giumelli, we are interested in the “what, where, when, and why” set of questions. However, Giumelli’s analytical approach seems too generalized. It provides valuable material on the macroprocesses, while overlooking what the microlevel has to offer: the quotidian interplay of sanctions policy events. The number of cases affords a glimpse into the structure of that interplay but, when looking at numbers, we lose sight of the political process as a corpus of events. In using the second approach, we gain insights into the very fabric of the process through an in-depth analysis conducted using qualitative methods. Such a method prevents us from making quantitative generalizations and makes it more difficult to systematize and formalize facts.

Our approach consists in quantitative analysis of everyday events in the world of sanctions. Answering the questions of “what, where, when, and why,” we move to the microlevel of sanctions policy while retaining the option of quantitative processing. As such, we are attempting to move to another level of generalization, filling in the gap in the existing research. Additionally, we supplement the answer to the questions of “what, where, when, and why” with an understanding of how individual EU institutions function. Finally, we compare the EU’s sanctions policy with that of other actors: the U.S., the UK and others.

Research design

Ivan Timofeev:
Sanctions Against Russia: A Look into 2021

The Sanctions Events Database (SED) designed by the Russian International Affairs Council served as the empirical basis for our research. We use a twelve-month data segment (January 2020 to January 2021). A sanctions policy event is the analysis unit. An event is a smaller unit than a case or an episode, as studied by Giumelli. Both a case and an episode can start with a specific event; yet, both a case and an episode can also include a whole number of events. For instance, a case of sanctions against Russia may open with an event, such as the 2014 decision No. 145 adopted by the Council of the European Union on sanctions against persons connected with the situation in Ukraine. Subsequently, additional episodes mount within the case. For instance, Ukraine-related sanctions against Russia have come to include sectoral sanctions related to the situation in Donbass or sanctions related to non-recognition of Crimea’s accession to Russia. Giumelli confined himself to studying the episode. We go further and analyze events that occur within cases and episodes. For instance, different actions may be undertaken within Crimea-related sanctions, such as updating the list of persons hit by sanctions, enforcement measures, court judgments on lifting sanctions, humanitarian exemptions, etc.

Information on each of the events is derived from open sources to be encoded in a series of variables.

The first variable is the event’s initiators, including individual nation states, groups of states and international organizations.

The second variable is the government institution or the body within an international organization that initiates the event. For states, we list a ministry, agency, legislative or judicial body. For international organizations, we list a body or an institution within such an organization.

The third variable is the event’s objective. Here, we determine the event’s target state. We also list a state in cases when sanctions are imposed on individuals and legal entities on the basis of regulations and rules reflecting the initiator’s policy toward this state. Instead of a state, though, we may indicate a functional issue, be it human rights, cyber security or terrorism. Actions aimed at changing the sanctions mechanism as such are coded as “all sanctions.” If several targets are combined, they are listed as several variables.

The fourth, fifth and sixth variables are, respectively, the number of individuals, legal entities, maritime vessels and aircraft hit by sanctions.

The seventh variable has to do with the event’s immediate cause. It constitutes an open question and spans a broad range of categories, including the state of bilateral relations, armed conflicts, human rights violations or more sector-specific actions, such as electoral abuse, arrests of important public figures, weapons testing etc.

The eighth variable accounts for the type of actions on the part of initiators. When new sanctions are imposed, their type is reflected in the database (blocking of assets, visa restrictions, sectoral sanctions etc.). There may be, however, other actions to mention, such as a threat to impose sanctions, easing or lifting of sanctions. If several measures are combined, they are reflected as several variables.

The ninth variable reflects the nature of the actions taken. It is encoded in the range of 1 to -1, where 1 signifies positive actions (lifting or easing of sanctions, humanitarian exemptions, general and special licenses etc.), while -1 stands for negative actions (imposing sanctions, tightening existing sanctions, measures for enforcing sanctions regimes, including penalties, criminal proceedings, individual episodes of investigating sanctions violations etc.). Finally, 0 signifies neutral events: statements, threats, resolutions, draft decisions; everything that involves declarations but does not entail specific binding actions that are enshrined in legislation or that enforce the sanctions legislation already in place.

The tenth and eleventh variables reflect the source of information and the event’s date. Most variables have a nominal scale or a ratio scale. Although these variables cannot be ordered, they do allow us to identify the typical features of events and assess their attributive distributions.

As our first step, we compare the number of events connected with different initiators to identify the indicators of the EU, its member states and their partners. Then, we go on to identify a group of events connected solely with the “European cluster.” We review the actions of individual EU institutions and analyze the principal objectives of the EU’s sanctions as well as actions of the member states, the reasons for imposing sanctions, means of application, and the ratio of positive, negative and neutral measures.

Sanctions events: global statistics

Throughout 5 January 2020 and 10 January 2021, SED records contain 848 sanctions events. The U.S. is the most active initiator, with 499 units out of 848, which is 52.94 per cent. The EU accounts for 108 events (12.73 per cent). We should also mention the 40 events initiated by individual EU states as well as some 36 events of EU partners (Georgia, Moldova, Albania etc.) as they joined EU sanctions regimes. All in all, there are 184 events to bear the “European cluster” label, or 21.69 per cent of the total number of observation units. The UK is a noticeable sanctions initiator, with 61 events translating into 7.19 per cent. Following Brexit, the UK has been conducting an independent sanctions policy. The UK’s relatively high indicator stems from a large number of events connected with adapting sanctions regimes to the national legislation. By comparison, Russia initiated only 16 events (1.8 per cent), while China initiated 12 (1.4 per cent). Switzerland and Canada account for 8 events each (0.94 per cent, respectively). Norway accounts for 1 event. It is important to note that the UN initiated 58 events (6.83 per cent) only.

From a global perspective, three states are the “top” targets for sanctions. These are Iran (116 events), China (94) and Russia (90). Other targets include Venezuela (44), Syria (35), Belarus (33), North Korea (33), Cuba (23), Nicaragua (18), Libya (18), Turkey (17) and the U.S. (12). As far as functional issues are concerned, we have to mention counterterrorism (62), human rights (34), non-proliferation (18), combating drug trafficking (14). 513 events (60.49 per cent) are negative, another 205 (24.17 per cent) are neutral, while only 107 (12.61 per cent) are marked as positive. The remaining 23 events describe actions by individual legal entities hit by sanctions. Over the period under consideration, sanctions events affected 1,278 individuals, 1,063 legal entities and 188 maritime vessels and aircraft.

The “collective West” is the most active initiator of sanctions, accounting for 711 events out of 848. Although the U.S. remains the leading initiator, also noticeable is the role of the EU, its individual member states and partners joining EU sanctions regimes.

Specific features of the EU’s sanctions policy

Before analyzing the statistics of EU sanctions, we need to make a few remarks about the specific features of the EU restrictions policies. A crucial feature is that decisions on sanctions are adopted collectively, by the Council of the European Union, upon submission of the High Representative of the Union for Foreign Affairs and Security Policy [2]. Sanctions are among the instruments of the Common Foreign and Security Policy. Article 31 of the EU Treaty stipulates that decisions in this area are made by the members of the Council of the European Union unanimously [3]. Implementation of a decision is reflected in the regulations of the Council of the European Union. So, decisions on sanctions are set forth as two documents: Council decisions and Council regulations of the Council of the European Union.

Ivan Timofeev:
The EU as a Significant Initiator of Sanctions

The second feature is that the EU imposes targeted sanctions. The EU prefers targeted restrictions against individuals and organizations to measures against a country. Such sanctions have become particularly widespread after the end of the Cold War [Dresner, 2015], whereas previously the most popular type of sanctions had to do with trade and economic embargos imposed on individual countries. Targeted sanctions became widespread because the 1991 Iraq case demonstrated the humanitarian costs of large-scale embargos. Besides, targeted sanctions made it possible to punish, at least theoretically, only those directly responsible rather than an entire nation. The U.S. became the flagship initiator of such sanctions. The instruments themselves primarily presupposed freezing financial assets and prohibiting transactions with persons hit by sanctions. The emergence of EU’s sanctions policy largely dovetailed with the trend to impose targeted sanctions. The declared objectives of imposing restrictions also made targeted sanctions a convenient instrument for Brussels. These objectives included protection of human rights, democracy, rule of law and good governance. Basic Principles on the Use of Restrictive Measures (Sanctions) issued in 2004 have specifically come to indicate that targeted sanctions, such as visa restrictions, assets freezes (blocking sanctions) and prohibitions on sales of weapons are preferable [4]. Application of such measures is detailed in the 2018 Sanctions Guidelines Update [5].

Persons affected by targeted sanctions are usually listed in addenda to decisions and regulations of the Council of the European Union. At the same time, targeted sanctions are linked with the EU’s policy on specific countries or issues. They should not be interpreted solely as sanctions against persons or organizations or as sanctions against a “regime” as opposed to “people.” Targeted sanctions are frequently imposed in connection with a specific state’s domestic or foreign policies. Blocking sanctions against major business people or companies may be detrimental to the country as whole, particularly if these are backbone enterprises. The EU has introduced the practice of sectoral sanctions that might entail painful consequences for the entire economy [see, for instance, Frits et al, 2017].

The third feature consists in the ability to challenge targeted sanctions in EU courts and the rather extensive practice of doing so. An EU court may dispute a decision of the Council of the European Union to put a particular person on sanctions lists. What is essentially disputed is the application of a decision to a particular person rather than the decision or regulation itself.

The fourth feature has to do with how decisions and regulations of the Council of the European Union are implemented at the level of nation states. The EU does not have a specialized body for enforcing sanctions. Several experts believe this undermines the effectiveness of the EU’s sanctions policy, and it has been suggested that such a body be established [see, for instance, Blockmans et al, 2020]. The role of nation states will remain high in any case, as the EU will not, for instance, be able to assume the role of states in case of criminal prosecution for violating a sanctions regime.

The fifth feature is the extensive practice of other countries joining the EU’s sanctions regimes. Brussels’s major achievement is making this policy’s regulatory framework a yardstick for third countries, mostly EU partners.

Finally, the sixth feature is the EU’s own vulnerability to ex-territorial sanctions of third countries, primarily the U.S., although the EU can also regard China as a source of such a threat [Blockmans, 2021]. Increasing the EU’s resistance to third state sanctions is also a priority for the European Commission [6].

The “European Cluster” of sanctions events

The “European cluster” consists of three components. The first is the actions of the EU as a whole. The second is the actions of individual member states, whereas the third deals with those of EU partners acting within the framework of the EU’s sanctions policy. The EU accounts for 108 events. Russia is the most frequent target (18 events), followed by Belarus and Syria (12 each). Six events are related to Iran, five to Turkey and to Venezuela, four to Libya and to Ukraine, three to China and to the Democratic Republic of the Congo, two to Zimbabwe and to the U.S. Finally, Guinea, Myanmar, Sudan, Yemen and North Korea feature one event each. Functional—so to say, “horizontal”—subjects are also important for sanctions events; they include human rights issues (8 events), counterterrorism (6), non-proliferation (3) and cyber security (2). The motives for sanctions may be combined. For instance, imposing sanctions on Russian citizens over an alleged hacker attack on the Bundestag’s information system combines both Russia and cyber security as motives for sanctions. The structure of the EU’s sanctions events differs from that of other initiators. For instance, the U.S. has primarily targeted Iran (89 events out of 449), China (81 out of 449) and Russia (47 out of 449).

Out of 108 events initiated by the EU, 59 are negative (54.62 per cent), 37 are neutral (34.25 per cent), while 12 (11.1 per cent) are positive. This distribution is different from the U.S. In the latter instance, out of 449 events, 300 are negative (66.8 per cent), 86 are neutral (19.15 per cent), with 63 positive (14.03 per cent). As for the UN, the picture is somewhat different: 20 out of 58 events have been negative (34.48 per cent), with 23 neutral events (39.65 per cent) and 15 positive events (25.42 per cent). In other words, the U.S. and the EU have a mostly “negative” track record as regards sanctions policies, while positive events constitute a minority in all three cases.

Out of the EU’s negative actions, 15 events entail the Council of the European Union imposing blocking sanctions and visa sanctions. Another 28 events involve resumption or prolongation of existing regimes. 12 cases entail negative rulings rendered in sanctions-related claims filed with EU courts. A single event is related to each of the following subjects: amending the existing sanctions regime (Yemen); a decision to impose additional sanctions on Turkey; institution of a new regime (related to human rights); and launching an operation for implementing the sanctions regime against Libya.

The Council of the European Union accounts for 60 events out of 108. Most of them (47 out of 60) are negative events connected with imposing or prolonging sanctions. Seven events are neutral (threats and declarations), while 6 events are positive. These are confined to deleting individuals from sanctions lists. Over the period under consideration, there has been no single event involving lifting or easing of any legal sanctions-related mechanism.

The European Commission, as well as the European External Action Service and its High Representative of the Union for Foreign Affairs, account for 25 events. Of these, 22 are neutral and three are positive. Two positive events are connected with publishing guidelines on humanitarian exemptions from the sanctions regime on account of the COVID-19 pandemic. One event is connected with launching the first humanitarian transactions through INSTEX. Absence of negative events has to do with the powers the Commission is endowed with. It does not make decisions on sanctions, although it does take part in arranging them. 16 events are connected with judgments of EU courts. In only three cases did courts grant the plaintiff’s claim to be struck from sanctions lists (two cases of Ukrainian citizens and one of an Egyptian citizen), while the claim was dismissed in 12 cases, including the claims of Russia’s Rosneft and VTB. One neutral event is the opinion of the advocate general on the claim filed by Refah Kargaran, a bank within Iran’s jurisdiction.

The European Parliament initiated seven events. All of them are neutral and constitute calls to impose sanctions framed as resolutions or letters by individual MEPs. The absence of negative events can also be explained through the powers enjoyed by the European Parliament, as it can recommend that sanctions be imposed but its resolutions are not binding.

The second component consists of actions undertaken by individual EU states. Over the period under consideration, these actions have demonstrated the following distribution: Germany – 10 events, France — 6, the Netherlands — 4, Estonia — 2, while Cyprus (blocking the decision of the Council of the European Union concerning sanctions against Belarus), Denmark, Finland, Italy, Latvia, Lithuania, Luxembourg, Malta and Spain account for one event each. In some cases, these are actions undertaken by groups of states. For instance, France, Germany and the UK together account for five events (although the UK is no longer an EU member, two EU member states being in the group allows us to mark the event as part of the “European cluster”); Latvia, Estonia and Lithuania together account for 2 events; Germany, France, Italy, Slovenia and Latvia together account for one event. We can identify several types of such events. Either states make declarations and statements or they impose independent sanctions (for instance, Latvia, Estonia, and Lithuania have instituted independent visa restrictions against Belarusian citizens). Alternatively, these can be decisions of justice agencies and courts of EU member states enforcing EU sanctions regimes.

Finally, the third component encompasses third states (EU partners in particular) joining the EU’s sanctions regime. Such episodes include sanctions against Belarus, Russia, Syria, Turkey and Venezuela as well as functional matters, such as cyber security, terrorism, human rights and non-proliferation. 33 such events in the database are classified as negative. Three events represent individual declarations and are classified as neutral.

The following facts are to be reported in connection with Russia and the sanctions imposed by the EU, its individual member states and its partners. Out of the 18 EU-initiated events, 13 are negative. They include six instances of new blocking and visa sanctions imposed in response to the alleged cyberattacks on the Bundestag by means of computer viruses WannaCry and NotPetya, the alleged poisoning of the Russian politician Alexey Navalny, alleged shipments of weaponry to Libya, construction of the Crimea bridge, organizing and holding elections in Crimea. In five instances, the existing sanctions regimes were prolonged: personal Ukraine-related sanctions (twice for six months each time), sectoral Ukraine-related sanctions (twice for six months each time) and the sanctions regime against Crimea. In two instances, court claims of Russian entities to be struck from sanctions lists were dismissed. Six events were declarations, and the database marks them as neutral. Of these, four were instances of calls to impose new sanctions on Russia, while the other two expressed dissatisfaction with the U.S. over Nord Stream 2 sanctions. There has been no single event to entail easing or lifting the sanctions against Russia.

Steps taken by individual EU member states in relation to Russia included individual restrictions, court rulings and statements. In Estonia, for instance, restrictions adopted by the authorities forced the Sputnik Estonia information agency to shut down. Latvia’s authorities proscribed nine Russian TV channels, and the court subsequently upheld this decision. In Finland, the Helsinki District Court ruled against Boris Rotenberg in favor of several European banks that had refused to service the claimant owing to sanctions. German courts passed a jail sentence for violation of the EU’s sanctions regime against Russia, while also arresting an individual for a similar crime. France, Germany and the UK made a joint statement calling for sanctions over Alexey Navalny’s alleged poisoning (later, the EU and the UK imposed such sanctions). Germany called for sanctions for the alleged hacking into the Bundestag’s information systems (the EU would later impose such sanctions). This series does not have a single positive event. As for third states supporting the EU’s sanctions, this support has become a widespread phenomenon in regard to Russia. In particular, third states supported the prolongation of Ukraine-related sanctions and sanctions imposed over Alexey Navalny’s alleged poisoning.

Conclusions

Ivan Timofeev:
What to Do with Extraterritorial Sanctions? EU Responses

As far as the frequency of sanctions events is concerned, the EU has become a significant actor that makes use of restrictive measures. It is far behind the U.S. but it is also far ahead of all other countries and international organizations, the UN included. Should we combine sanctions imposed by the EU as a whole with actions of its member states to implement restrictions and with instances of third states joining the EU’s sanctions regimes, the EU’s lead as compared to other initiators becomes even more pronounced. Our data demonstrates that the EU has its own sanctions agenda that does not duplicate that of the U.S. For instance, the EU’s sanctions do not affect China and Iran to the same degree as the American sanctions do. They overlap when it comes to Russia but they are not identical in this case either. Moreover, in several events, the EU has criticized the U.S. (for instance, over the American sanctions against Nord Stream 2).

The EU is not inclined to revise its legal sanctions mechanisms. None of these mechanisms has been modified over the period under consideration. The practice of the Council of the European Union to grant exemptions from sanctions lists has also been quite limited. Such rulings are made by the EU’s Court of Justice but the case law on these issues leans heavily toward negative rulings. The courts may indeed rule to strike a person or entity from sanctions lists but they do so far less frequently than they dismiss such claims. Within the EU’s sanctions practice, the number of positive events is far smaller than that of negative and neutral events. This is also typical of other initiators. Decision-making processes on sanctions are dominated by the Council of the European Union, with its decisions drafted by the European Commission. The role of the European Parliament centers around recommendations. Yet, such a distribution reflects the specifics of the EU’s institutional design. An important role is played by the rule mandating that the Council of the European Union adopt foreign policy decisions unanimously. The example of Cyprus voting against Belarusian sanctions in 2020 demonstrated that the Council’s consensus over restrictions is not predetermined. Visa restrictions and blocking financial sanctions are the EU’s key sanctions instruments. The use of “targeted” sanctions is a global trend, with the EU’s policy in this regard being quite typical. The EU’s sanctions regimes are temporary but they are prolonged on a rather routine basis.

Russia is the key target of EU sanctions as regards the number of events, although their share in the overall set of events is not too large. Anti-Russian restrictions are imposed under several mechanisms at once, including the decisions the Council of the European Union adopted regarding Crimea, cyber security, non-proliferation and human rights issues. At the same time, the decisions are mainly manifested in targeted sanctions, prolongations of existing regimes, declarations or dismissals of court claims. So far, the EU is at odds with the U.S. over sanctions on Nord Stream 2.

The approach we have proposed for analyzing the EU’s sanctions policy constitutes a middle-of-the-road solution between quantitative databases of cases and episodes in sanctions policies, on the one hand, and in-depth studies of individual cases using qualitative methods, on the other. Even so, our analysis has been faced with several limitations.

The first has to do with the assessment of events. The scale we use distinguishes between positive, neutral and negative events. In and of themselves, however, they differ in “magnitude.” For instance, putting a person or an entity on a sanctions list and creating a new legal mechanism for sanctions are both negative events, yet the latter is more fundamental in comparison to the former. Additionally, the damage caused by sanctions depends on which person or entity has been hit by them. It is one thing to impose sanctions on an official or a public figure, while targeting a major company or a bank is a different story. The SED records the gist of an event but fails to draw the more subtle distinctions between them.

The second limitation is the difficulty in covering all possible events. While formalized decisions are fairly easy to identify and record, doing so when it comes to declarations is a more complicated task.

The third limitation originates from the different cultures of sanctions policies. The U.S. and the EU policies are highly formalized. In other instances (as in the case of China), official sanctions can co-exist with unofficial measures. Their identification is difficult, so it is possible that the SED records a greater number of sanctions initiated by the West simply because they are more carefully reflected in the bureaucratic process.

The fourth limitation is the short observation period. So far, our data has been collected over a year only. Putting them in historical retrospective is rather problematic. In time, however, the SED will provide a greater array of information.

References

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Blockmans, S., Gott, IL, Hagemejer, J. and others (2020) Exterritorial Sanctions on Trade and Investments and European Responses. Study Requested be the INTA Committee, European Parliament. URL: Extraterritorial sanctions on trade and investments and European responses - Think Tank (europa.eu) (accessed: 01.03.2021)

Connolly, R. (2018) Russia’s Response to Sanctions. How Western Economic Statecraft is Reshaping Political Economy of Russia? Cambridge: Cambridge University Press.

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Giumelli, F., Hoffmann, F. and Ksiazczakova, A. (2020) ‘The When, Where and Why of European Union Sanctions’, European Security, Vol 30 (1): 1-23.

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