The European Union has expedited its sanctions review cycle against Russia as hybrid warfare has a greater impact across European Union member states. Recent incidents of drone attacks on the Danish mainland, sabotage attacks on critical infrastructure, and shadow fleets have reduced the level of security policy dialogue among EU leaders. Faced with growing regional threat to security, the bloc is now reviewing further actions to target Russia’s military-industrial complex, inzarrection measures to greater measures, such as countering cunning of Moscow’s dwarfing actions.
European leaders unite against escalating Russian provocations
European leaders are sounding the alarm over escalating Russian provocations across the Baltic region. Polish Prime Minister Donald Tusk declared “this is war” on Thursday as he urged NATO to abandon “illusions” and confront what he called a “new type of war.” The remarks came during a high-level summit in Copenhagen focused on bolstering continental defense amid a wave of suspected sabotage and drone activity.
Tusk said Poland shot down Russian drones violating its airspace in early September. He warned that incidents near Polish infrastructure—including ports and pipelines—are happening “almost every day.” Danish Prime Minister Mette Frederiksen called the situation a “hybrid war” targeting NATO allies. German forces raided the Russian vessel Scanlark, uncovering evidence of drone launches and sabotage. French commandos arrested crew members of the suspected “shadow fleet” tanker Borocay in Saint-Nazaire.
Shadow fleet operations intensify sanctions evasion efforts
Since October 2024, the EU has implemented a separate Russia sanctions framework targeting so-called “hybrid activities” which include activities aimed at undermining electoral processes, sabotaging economic activities, and other such actions designed to destabilise the EU and its Member States. Those designated under the framework will be subject to an asset freeze and will be forbidden from having funds made available to them by EU citizens and companies.
Comprehensive sanctions framework targets the military-industrial complex
The EU has implemented a range of measures aimed at tackling circumvention. EU parent companies are required to undertake their “best efforts” to ensure that their third-country subsidiaries do not circumvent sanctions. “Best efforts” means all actions that are suitable and necessary to achieve the result of preventing the undermining of the restrictive measures.
Common High Priority items are listed in Annex XL to Regulation (EU) No 833/2014. They are items that are commonly found on the battlefield in Ukraine or critical to the development, production, or use of Russian military systems. To respond to the problem of these items being re-exported to Russia, the EU has introduced a requirement for EU exporters of Common High Priority items and certain other sensitive goods to contractually prohibit their customers in third countries from re-exportation of the goods to or for use in Russia.
Enhanced due diligence requirements strengthen enforcement mechanisms
An EU operator who has failed to carry out appropriate due diligence may be held liable for a violation of sanctions. They will not be able to rely on claiming that they did not know, and had no reasonable cause to suspect, that their actions would violate the sanctions. EU guidance clarifies that due diligence should be proportionate, but at a minimum, it should include screening of all parties to the transaction, including indirect parties (suppliers, service providers, transporters, banks).
The EU’s update to its approach to sanctions reflects the changing nature of Russian hybrid threats to the security of Europe. Enhanced enforcement mechanisms and widened targeting criteria reflect the desire of Brussels to attack the circumvention tactics of Moscow. As hybrid warfare activities intensify, the ability of the bloc to ensure unity, which also meets the need for making adjustments in the sanctions frameworks, will be key for deterring further Russian provocations as well as securing critical infrastructure across member states.