In 2022, as part of a
multi-country response to Russia’s full-scale invasion of Ukraine, the European
Union began adopting wide-ranging restrictive measures (‘sanctions’) against
Russia. Simultaneously, the EU increased its attention to sanctions
enforcement, recognizing that enforcement affects its foreign policy interests.
Indeed, due to historically uneven enforcement by Member States, the EU has at
best a mixed reputation for enforcement. To enhance its credibility at home and
abroad, the Commission has begun offering guidance on the scope of sanctions as
a means of strengthening enforcement.
This article analyses
how the EU’s decentralized sanctions enforcement system affects its actorness,
defined as its ‘capacity to act’ in a way that enables influence on the
international stage, and concludes it suffers from a lack of cohesion and
autonomy. It then examines whether the Commission’s guidance has strengthened
the EU’s enforcement environment and, by extension, the EU’s actorness. Based
on an analysis of public documents and interviews with the private sector,
there exists a significant level of dissatisfaction with the guidance and
continued lack of uniformity in how sanctions are enforced. Thus, the article
contends that the EU’s actorness continues to suffer the complications that
result from its decentralized enforcement system and concludes that because
even improved guidance will not resolve this issue, broader changes should be
considered to bring about meaningful improvements in the EU’s enforcement
environment and actorness.