Weak and inconsistent enforcement by member states has undermined the European Union’s trade sanctions against Russia, the bloc’s auditors have found.
In a special report published on November 10, the European Court of Auditors (ECA) said national authorities applied the restrictions in markedly different ways. That reduced their impact and made them easier to circumvent, it said.
The auditors warned of so-called “forum-shopping”, whereby companies deliberately pick authorisation offices or customs points in member states with less stringent controls.
The ECA examined enforcement in five member states: Bulgaria, Germany, Latvia, the Netherlands and Poland. According to the report, Bulgaria has not recorded a single case of non-compliance with the trade sanctions since 2022 involving EU exports transiting its territory.
Mihails Kozlovs, the ECA member responsible for the report, said the sanctions would deliver their intended impact “if all member states apply them in a uniform and coordinated way”. He acknowledged the Commission had worked hard to build the framework, though he said unclear rules and weak enforcement limited the measures’ effect.
Since February 2022, the EU has adopted 21 sanctions packages against Moscow in response to the Ukraine War. The ECA described them as “the most far-reaching restrictive measures the EU has ever agreed to”.
Trade between the EU and Russia fell from €253 billion in 2022 to €58 billion in 2025, the auditors found. Even so, the EU was still Russia’s third-largest trading partner in 2025 and indirect shipments through third countries continued to pose a problem.
The report also pointed to vague wording in sanctions legislation, particularly on exemptions, and to mismatches in terminology between customs law and sanctions rules. As a result, national authorities had interpreted the same measures differently.
The flexibility needed to secure unanimity among member states had also opened the door to loopholes, according to the auditors. Danish news agency Ritzau reported that the report cited Italy and France pushing to exempt luxury goods such as clothing and handbags, while Belgium sought to protect its diamond trade.
The ECA was also critical of the European Commission, saying it did not sufficiently monitor implementation and lacked criteria to assess the sanctions’ overall effectiveness. That made it hard to judge whether the measures were working or whether more were needed, the auditors said.
They recommended clearer legal drafting, an in-depth review of whether member states applied the sanctions uniformly, fuller use of information-exchange systems and better monitoring.
In its reply, the Commission said it took the recommendations on legal clarity very seriously and had already stepped up its support for national authorities. It added that it was closely tracking trade flows, circumvention schemes and the impact of the measures on the Russian economy.
