EU Sanctions Against Russia And Criminal Law: A Mismatch?

Since the Russian attack on Ukraine in late February 2022, the European Union was quick to respond with sanctions in order to ramp up economic pressure on the Russian government and cripple its ability to finance the war. As the war continues, almost every month a tightening of the sanctions is announced. So far, the EU has enacted eight sanction packages, which include export and import bans of certain products, embargos with regard to Donetsk, Luhansk, Crimea and Sevastopol, asset freezes and prohibitions to make economic funds available to certain listed persons as well as many financial and other transactional restrictions with regard to Russian entities. The Council Regulations are directly binding on all persons under the jurisdiction of EU Member States. For example, regulations imposing freezing measures apply, among others, to EU companies, including financial and credit institutions, doing business in whole or in part in the EU, and to EU nationals.