Lessons From Russia & Iran

Sanctions are a tool used to further foreign policy objectives and a way to uphold international law and respond to global crises without resorting to force. The EU’s legal sanctions programs are drafted in Brussels, but the real test of these measures plays out in the world’s conflict zones, energy markets, and corporate boardrooms. Some of the most evident cases are in the EU’s sanctions regimes on Russia and Iran. 

Both cases offer important lessons about how the EU uses sanctions, not just to send signals, but to shape outcomes. They also show how sanctions policy has evolved: from a reactive tool to a more proactive and strategic approach, increasingly aligned with global partners but still uniquely European in its legal architecture and political logic. 

According to EU law, EU member states have three responsibilities when it comes to sanctions:

1. Adopt internal measures imposing penalties
2. Take concrete steps to enforce such measures
3. Ensure that the measures taken are sufficiently effective, proportionate, and dissuasive, in line with the case law of the EU Court of Justice 

EU member states must implement EU sanctions regulations, but can also expand on these regulations within their own legislations. 

Russia: A Sanctions Regime at Scale 

Since the annexation of Crimea in 2014 and especially following the full-scale invasion of Ukraine in 2022, the EU has rolled out one of the most expansive sanctions programs in its history. Over 16 packages of sanctions have been imposed, targeting everything from financial institutions and defense exports to luxury goods and energy revenues. 

This sanctions regime is notable not just for its scope, but also for its coordination with allies. The EU has worked in lockstep with the United States, UK, Canada, and others, showing that sanctions are most effective when deployed as part of a multilateral strategy. It has also demonstrated agility through updating listings, expanding categories, and plugging loopholes with increasing speed. 

But it hasn’t all been smooth sailing. The limits of EU unity have occasionally surfaced, particularly when energy dependencies or trade interests come into play. Enforcement also remains uneven across member states, with implementation challenges affecting overall impact. Still, the Russia program has pushed the EU into new territory: designing sanctions not just to punish, but also to economically isolate and constrain a major global power. The learning curve has been steep, and it has driven innovation in how sanctions are drafted, monitored, and enforced. 

Iran: A Study in Strategic Pressure 

The EU’s sanctions on Iran date back to 2007 and have gone through several phases: tightening, relaxing, and tightening again depending on the status of nuclear negotiations and regional tensions. These sanctions target Iran’s nuclear and ballistic missile programs, human rights abuses, and support for terrorism. 

What’s unique here is how EU sanctions have been used to support multilateral diplomacy, particularly the Joint Comprehensive Plan of Action (JCPOA). Unlike the United States, which has often taken a more maximalist approach, the EU has framed its sanctions as tools to bring Iran back to the negotiating table. This reflects the EU’s broader commitment to diplomacy and international institutions. 

However, the Iran program also reveals the challenges of sanctions as a bridge between policy and practice. The U.S. withdrawal from the JCPOA in 2018 and its re-imposition of secondary sanctions effectively sidelined European efforts to keep the deal alive. Despite strong political support for the JCPOA within the European Union and diplomatic efforts to uphold the agreement, the EU’s attempts to circumvent U.S. sanctions, most notably through the creation of the Instrument in Support of Trade Exchanges (INSTEX), proved largely symbolic. The mechanism struggled to gain traction and failed to facilitate meaningful trade, ultimately rendering European efforts to preserve the nuclear deal ineffective in the face of overwhelming U.S. financial leverage. 

This demonstrates that even the most carefully designed sanctions regime can be undermined by geopolitical shifts and asymmetries in enforcement power. Coordination remains key, but so does clarity about leverage and limits. 

Lessons for Policy and Compliance 

The Russia and Iran sanctions programs differ in many ways—geography, objectives, intensity—but they share a common thread: both are windows into how the EU tries to achieve its foreign policy objectives, and how sanctions translate those ideas into action. 

For policymakers, these cases show the importance of flexibility, coordination, and credibility. Sanctions need to be clear, enforceable, and dynamic. And they must be paired with political strategies that give them meaning beyond symbolism. 

For financial institutions and other businesses, the message is even clearer: EU sanctions are complex, but they are not optional. Understanding the rationale behind them and the specific obligations they create is now a matter of legal compliance, reputational risk, and operational necessity.  

There has been an increase in the number of enforcement actions and in penalties imposed by certain member states. As the EU’s global role grows, so too will its reliance on sanctions as a tool of strategic influence. Whether you’re working in policy, compliance, legal, or risk, staying ahead of this evolving landscape is critical.