How Russia’s war against Ukraine changed EU sanctions decision-making

Russia’s invasion of Ukraine in 2022 marked a turning point in the EU sanctions policy. Understanding this transformation matters not only for sanctions scholars but also for appreciating how the EU navigates such crises. We study how internal institutional dynamics and external influences from third countries as well as lobbying by economic interests interact to shape the genesis of the EU’s sanctions regime against Russia. In the absence of a specific procedure in EU primary law, two processes have emerged: one for ordinary and one for exceptional, emergency situations, the latter only intended for Russian sanctions. The Commission has secured greater clout in the emergency process, which has strengthened the role of interest groups and third countries in decision-making. The emergency process is meant to be a temporary arrangement, but, since institutional development rarely regresses, at least some new elements are likely to persist in the post-war context.