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168 | Zsolt Nagy, Zoltán Simon, Viktor Szép, and Tamás Dezső Ziegler
crisis management (33%), and post-conflict management (27%). These are
followed by the EU’s willingness to uphold certain international norms (15%),
interests’ promotion (13%), non-proliferation (9%), and finally terrorism
(7%) (Giumelli et al. 2021, 12-13).
Despite the increased political willingness to pay the price for implementing
sanctions, scholars have rightly pointed to inconsistencies with regard to their
practice. The Union, for instance, imposed sanctions against Myanmar for
violations of minimum labour rights, whereas it failed to adopt similar measures
against Pakistan for the same violations in the same year. Similarly, the EU
used sanctions against Zimbabwe for violating fundamental principles of
democracy, but adopted no measures against Nigeria for the same behaviour in
the subsequent year (Fürrutter 2020). This lack of consistency, at least in the area
of sanctions, can often be explained by “considerable commercial or strategic
EU interests ... at stake in the target countries” (Portela and Orbie 2014, 72).
Whenever the Union decides to impose sanctions, it rarely does it alone.
There is along tradition of cooperating with like-minded third countries, such
as the United States or Canada. Recently, the EU-US summit of 2021 also
underlined the importance of enhancing coordination in sanctions matters.
This cooperation between the EU and US proved to be beneficial for both
sides on various occasions, such as in the cases of Iran or Russia. The case of
Belarus also demonstrates the importance of transatlantic cooperation when
it comes to enhancing the effectiveness of international sanctions mechanisms
(Van Elsuwege and Szép 2022).
The EU’s neighbouring states, in most of the cases, have also proven to be
reliable partners in this field: enlargement candidate and European Free Trade
Association (EFTA) countries tend to implement almost all EU sanctions.
Although with more fluctuations, potential candidate and Eastern Partnership
countries cooperate with the Union on sanctions matters as well, although
rather on a case-by-case basis (Szép and Van Elsuwege 2020, 229).
a. Extraterritorial sanctions
Nevertheless, the United States is not only a partner in sanctions matters
but, as the past few years clearly demonstrated, can also harm EU interests.
Today, an important question in the Unions sanctions policy is how to reduce
the extraterritorial impact of certain US sanctions. The prominent role of
the dollar in global finances allows Washington to threaten non-US actors,
including European entities, to restrict their access to American markets
if they engage with partners that are subject to US sanctions. In particular,
recent American measures against Russia and Iran discouraged EU operators
to do business with US targets.
Clearly, the limitations imposed by these extraterritorial sanctions are at
odds with the EU’s ambition to strengthen its strategic sovereignty. In fact,