How Can the EU’s Criminal Network Sanctions Succeed?

The EU is moving towards a new sanctions regime targeting criminal networks, reportedly focusing on migrant smuggling. In the main, restrictive measures have been used by the EU primarily as instruments of foreign policy, national security and economic statecraft. Russia’s full-scale invasion of Ukraine forced the EU and its partners to become far more ambitious in the design, implementation and enforcement of sanctions. Now, the bloc is turning that ambition towards serious organised crime.

The sanctions community in the EU is relatively young, forged in response to Russia’s aggression in Ukraine, but ensuring the effectiveness of criminal network sanctions requires different skills and strategy. Put simply, sanctions against criminal networks are not merely Russia sanctions with different names on the list. They require a different logic, an adapted institutional model and a more nuanced assessment of impact. If the EU wants the proposed regime to matter, it must avoid merely creating a symbolic tool that allows policymakers to announce action without changing the operating environment for criminal actors and the threats they pose to member states.

This risk is real. Sanctions can be politically attractive. They are visible, flexible and often quicker to deploy than prosecutions or asset recovery proceedings. They allow governments to signal resolve in response to emerging threats. But sanctions are not automatically effective. If poorly designed, they can become performative and dismissed as mere attempts to look tough, without achieving the promised impact.

This is the core challenge that emerged from a recent workshop hosted by the Centre for Finance and Security in The Hague, that gathered 50 representatives from law enforcement, sanctions policymaking, and the private sector from across the EU. The short answer, for those involved, is that for the EU’s planned criminal network sanctions to succeed, they must meet a set of clear criteria.

The Nine Step Test

Most importantly, the regime must be built around a clear theory of change. The central question should not be whether the EU can impose sanctions on criminal networks. Rather the EU should clearly articulate what behaviour it is trying to alter? What capability is it trying to constrain? What network function is it trying to disrupt? Is the objective to deter, expose, isolate, immobilise assets, support investigations, deny access to the legitimate economy, or create leverage over facilitators and host states?

These are not abstract questions. Different objectives imply different targets. If the purpose is to signal political condemnation, the most notorious criminal figures – or their political patrons – may be attractive targets. If the purpose is disruption, the more valuable targets may be less visible such as those providing ‘crime-as-a-service’, financial facilitation and logistics; or corrupt officials, company formation agents, and port insiders. A regime without clarity of purpose will drift towards easy, performative designations rather than impactful ones.

Second, sanctions must add value beyond existing law-enforcement tools. Serious organised crime is already illegal. Criminal justice should remain the primary response wherever investigation, prosecution, confiscation and international legal cooperation are viable. Sanctions should not become a workaround for difficult cases, nor a substitute for proper resourcing of law enforcement and asset recovery efforts.

The strongest case for sanctions arises where ordinary tools cannot reach the threat quickly or effectively: where criminal actors operate from jurisdictions with limited cooperation; where evidence is sufficient to justify restrictive measures but not at the threshold for use in court; where financial or professional facilitators sit outside the immediate reach of investigators; or where a network’s reliance on the formal economy creates a point of vulnerability that law enforcement alone cannot exploit. The question should always be, ‘what can sanctions do here that other tools cannot?’.

Third, the EU must think strategically rather than tactically. There will be pressure to use the regime against prominent individuals or politically salient cases. Some of that may be justified. But organised-crime sanctions will be most effective when used to alter the operating environment, not merely to name individual wrongdoers.

The regime should therefore focus on strategic enablers and chokepoints. In drug trafficking, this may mean money brokers, logistics networks, corrupt port facilitators and laundering structures; or, with migrant smuggling or human trafficking, it may mean coordinators, document providers, transport networks and financial intermediaries.

This is where sanctions can be most useful: not as a symbolic label, but as a disruption tool aimed at the connective tissue of criminal markets.

Fourth, the regime must be carefully scoped while remaining future-proof. There is an understandable debate over whether the EU should create a broad serious organised crime regime or a narrower instrument focused on specific offences such as migrant smuggling, drug trafficking, or human trafficking. A narrow regime may be easier to agree politically. A broader regime – built on an agreed definition of serious organised crime – may be more useful operationally, especially given the increasingly poly-criminal nature of criminal networks. Thus, a regime that is too narrow may rapidly become obsolete or encourage displacement into adjacent crime types. But a regime that is too broad risks legal uncertainty, inconsistent use and political hesitation.

The EU should therefore design a regime with clear designation criteria but sufficient flexibility to adapt. Criminal networks innovate faster than public authorities. They shift routes, change ownership structures, exploit new technologies, move assets, rotate front companies and use legitimate businesses as cover. The EU should assume that every designation will trigger adaptation. A successful regime must be capable of regular updating, rapid follow-on action and adjustment as criminal methods change.

Fifth, the right agencies must be involved from the outset. This is perhaps the most important distinction between criminal network sanctions and many other sanctions regimes. Russia sanctions encompass foreign ministries, finance ministries, and other authorities such as export-control bodies, customs agencies, and maritime authorities, along with the private sector. Criminal network sanctions require many of these actors too, but the centre of gravity is different.

Law enforcement is key, so too are prosecutors, the wider illicit finance community and national and EU-wide organised crime agencies. Foreign ministries and their sanctions teams will remain essential, particularly for legal design, diplomacy and listings, but they cannot design an effective criminal network regime alone. The intelligence needed to understand criminal markets, select targets and anticipate displacement will often sit outside traditional sanctions communities.

This also means that member states will need to expand existing domestic coordination mechanisms. If Brussels creates the regime but national systems cannot generate targets, share evidence or support implementation, the regime will underperform. The EU should not underestimate the institutional work required.

Sixth, the cooperation of sanctions target host-countries must be treated as a core condition of impact. Some governments will welcome EU designations as support against entrenched criminal networks. Others may be indifferent, embarrassed, resistant or complicit. In some cases, sanctions may help stimulate cooperation. In others, they may provoke diplomatic pushback or drive actors further underground.

The EU should therefore build diplomacy into the regime from the start and consider how affected third countries are likely to respond; whether cooperation can be secured; whether listings may support local law-enforcement action; and whether there is a plan where host-country cooperation is absent.

Seventh, the regime must be politically sustainable. Creating a sanctions framework is easier than using it well. The EU will need agreement among member states on scope, priorities and target selection. Some crime types may attract consensus more readily than others. Migrant smuggling, human trafficking and major drug trafficking networks may be politically compelling. More sensitive cases involving partner-country elites, corrupt officials, business facilitators or jurisdictions with close diplomatic ties may be harder.

This is where political will becomes decisive. If the regime is established but used timidly, inconsistently or only against low-risk targets, it will not have credibility. The EU must be prepared to take politically difficult decisions where the evidence and strategic case justify them. It must also avoid overpromising. Sanctions will not dismantle organised crime. They may, however, disrupt specific networks, deny access to services, expose facilitators and support wider enforcement.

Eighth, success must be measured by impact, not activity. A long list of names is not evidence of success. Nor is the mere freezing of assets, unless it contributes to a broader objective. The EU should develop regime-specific impact indicators from the outset. These might include disruption of network functions, loss of access to financial or professional services, increased private-sector reporting, support to prosecutions, assets preserved for recovery, host-country action, behavioural change by facilitators or measurable degradation of criminal infrastructure. Measuring sanctions impact is notoriously difficult, yet without a framework for assessing impact, the regime risks defaulting to counting designations and press releases.

Finally, the regime must be integrated into a broader EU-wide serious organised crime strategy. Sanctions should be one tool among many. Used alone, sanctions are unlikely to shift criminal markets. Used intelligently, they can help expose and disrupt the infrastructure that allows those markets to function.

The EU is right to explore criminal network sanctions. The threats are real. Criminal networks are transnational, adaptive and increasingly intertwined with cyber threats, corruption, illicit finance and hostile-state activity. Traditional tools remain essential, but they are often too slow, too jurisdictionally constrained or too reactive to deal with the speed and flexibility of modern criminal enterprise.

But this ambition must be matched by discipline. A successful EU regime will need a clearly articulated strategy and theory of change, supported by the steps outlined above. Anything less risks the EU slipping back to the ‘pre-Russia’ performative use of sanctions that might be politically satisfying but will be administratively burdensome and operationally weak.

The opportunity is not simply to create more sanctions. It is to build a more integrated disruption model in which restrictive measures reinforce the existing ecosystem deployed by EU member states against criminal networks.

The writing of this commentary was supported by the AI transcription of the workshop discussion from which the recommendations are drawn.

© RUSI, 2026.

The views expressed in this Commentary are the authors', and do not represent those of RUSI or any other institution.

For terms of use, see Website Terms and Conditions of Use.

Have an idea for a Commentary you'd like to write for us? Send a short pitch to commentaries@rusi.org and we'll get back to you if it fits into our research interests. View full guidelines for contributors.