RUSI commentary examines effectiveness of EU sanctions against criminal networks

A new commentary by Tom Keatinge, Director of the Centre for Finance and Security (CFS), and Kinga Redlowska, Head of CFS Europe, examines the conditions needed for the EU’s planned sanctions regime targeting criminal networks to be effective.

Published by RUSI on 18 June 2026, How Can the EU’s Criminal Network Sanctions Succeed? draws on a CFS workshop in The Hague involving 50 representatives from law enforcement, sanctions policymaking and the private sector across the EU.

The commentary argues that sanctions targeting serious organised crime require a distinct approach from those focused on foreign policy and national security. It calls for a clear theory of change, identifying the behaviours and network functions sanctions aim to disrupt. Sanctions should complement, not replace, investigation, prosecution, confiscation and international cooperation. They may be particularly valuable where conventional tools cannot reach criminal actors or facilitators.

It also highlights the importance of targeting key enablers and chokepoints within criminal networks, including financial facilitators, logistics networks and corrupt officials. It argues that effectiveness should be measured by the disruption of criminal networks and infrastructure, and by changes in facilitator behaviour, rather than simply by the number of designations.

The commentary relates to the wider SOC ACE project, Assessing the effectiveness of sanctions as a tool to disrupt serious organised crime, which examines gaps in evidence on the effectiveness of sanctions against serious organised crime and lessons for the UK. Its first phase identified political will in host countries as a key factor in Colombia and Libya. The second phase explores this further, examining how political, geopolitical and domestic factors shape sanctions policy and effectiveness.