On 5 November 2026, Maria Luís Albuquerque, the European Commissioner for Financial Services, announced the planned creation of an EU Sanctions Office within the European Commission.
Main missions
The Office will cover the entire lifecycle of EU economic sanctions, "from policy design to outreach implementation, and of course circumvention". According to the Commission, it is intended to:
strengthen coordination between Member States and EU institutions;
give Member States faster access to guidance, data sharing and economic and technical analysis;
harmonise the implementation and enforcement of EU restrictive measures across the Union; and
support closer cooperation with G7 and like-minded partners, both inside and outside the EU.
Its main focus is stated to be sanctions against third countries, particularly the Federation of Russia.
Origin
As part of the Union’s pledge to strengthen sanctions enforcement, the Office responds to a long-standing structural impediment. While the EU adopts sanctions at Union level, it is for the Member States to implement and enforce them, including by identifying breaches and imposing penalties. As such, the EU Commission's role is limited to monitoring uniform implementation and issuing guidance, mainly through DG FISMA.
However, current uneven enforcement leaves gaps that sanctioned countries, entities and individuals can exploit or suffer from. This was confirmed on 10 November 2026 by the European Court of Auditors, which reported that restrictive measures against Russia are applied unevenly across Member States.
While commentators have long argued for a dedicated EU body for sanctions enforcement, similar to certain national authorities outside of the EU, nothing suggests that the Office will assume any enforcement role per se. Yet, David O’Sullican, EU Sanctions Envoy, stated that the Office may, in time, grow into a one-stop shop for licenses and derogations.
Current grey areas
So far, the Commission has only announced the planned creation of the Office. Accordingly, no legal act, mandate or organisation chart has been published, meaning that several key points remain open:
legal basis and powers – described as an "internal" Commission body, the Office should not have its own investigative or sanctioning powers, as enforcement currently remains a national competence and as listing decisions remain with the Council;
timing, staffing and scope – no timetable has been given, and it is also unclear whether the Office will cover regimes other than Russia; and
relationship with existing actors – it is not yet clear how the Office will work with DG FISMA, the EU Sanctions Envoy, OLAF, Europol or the competent national authorities.
Practical consequences
Following the announcement, we can expect the creation of an EU Sanctions Office to lead to more consistent enforcement across Member States, supported by better sharing of data and information between authorities. Divergences in national enforcement practices are likely to narrow and sanction-related Commission FAQs and guidance are expected to be issued quicker and more homogeneously. More coordinated enforcement may also lead to closer scrutiny of derogation requests and may also lead to more cross-border investigations into suspected circumvention.
Combined with the new criminal regime in force in most Member States by now, this makes robust screening, ownership and control analysis and anti-circumvention due diligence essential. All in all, stakeholders may expect faster and more harmonised EU Commission guidance to lead to more legal certainty.
While talks surrounding the EU Sanctions Office continue, the Commission continues to plan its 22nd sanctions package against Russia, as the importance of restrictive measures and export controls as instruments of EU economic security continues to grow.
For further information, please contact Bruno Lebrun and Antoine Barazzoni