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Transatlantic Action: Sanctioning Third-Country Enablers of Russia’s War Economy

2026-04-24 05:08:09

Executive Summary

In the effort to deter Russia’s aggression, allies on both sides of the Atlantic are struggling to maintain a sufficiently strong sanctions regime. American sanctions designations have slowed to an inconsistent trickle, at best. The West faces a pivotal moment: The fate of negotiations over Ukraine relies heavily on transatlantic commitment to sanctions and the leverage that comes with them. If Russia is to be deterred, the United States and Europe must send a clearer signal to Russian entities and third-country enablers, in order to chart a course to a just and durable peace. 

  • Russia’s wartime economy persists despite direct sanctions by relying on third-country channels. 
    • Shell companies in third countries help circumvent sanctions by supporting the shipment of illicit goods and facilitating payments between Western banks and sanctioned Russian banks. 
  • Allied efforts to restrict Russia’s shadow fleet are important, yet they are riddled with loopholes.  
    • From Russia to Turkey to China, the US and EU have restricted specific companies, vessels, and refineries that make up the shadow fleet. 
    • Though the West occasionally targets entire ecosystems and geographic areas, efforts generally focus on individual companies, trapping sanctions enforcers in a cat-and-mouse game with shell companies. 
  • The transatlantic community must update sanctions regularly, staying ahead of emerging trends.  
    • The EU and US must puncture the Kremlin’s belief that time is on its side, laying out dynamic sanctions that curb new evasion techniques. 
  • When implementing secondary sanctions, the EU and US must target more financial institutions. Sanctions efforts should be complemented with diplomatic outreach. 
    • Sanctions should act as a signaling tool, and issues of sanctions circumvention should become an integral part of broader diplomatic outreach to third countries.  
    • Allies should consistently prosecute enablers in order to demonstrate zero tolerance for sanctions evasion.  
    • Secondary sanctions should complement primary sanctions, not replace them. 
  • Follow new sanctions with designations, maintaining credibility and deterrence.  
    • For credibility’s sake, allies must keep their strategy united and back threats with real action. 
  • Sanction-enforcing countries should offer off-ramps and reward changes in behavior. 
    • Policymakers should reward sanctioned entities if they cease cooperation with Russia. 
Photo: People walk past a board showing currency exchange rates of the euro against the ruble in a street decorated with festive illumination lights, part of the New Year and Christmas holidays celebration, in central Moscow, Russia, December 29, 2015. Credit: REUTERS/Maxim Zmeyev
Photo: People walk past a board showing currency exchange rates of the euro against the ruble in a street decorated with festive illumination lights, part of the New Year and Christmas holidays celebration, in central Moscow, Russia, December 29, 2015. Credit: REUTERS/Maxim Zmeyev

Introduction: Increasing Sanctions Attention toward Russia’s Enablers

In response to Russia’s full-scale invasion of Ukraine in February 2022, many countries imposed a raft of industrywide and individual sanctions to increase the price of aggression for Russia, forming a so-called sanctions coalition.1 Although the first sanctions were put in place after the illegal annexation of Crimea in 2014, with some additions made in the following years, the sanctions imposed since 2022 have been significantly more far-reaching, covering the most important sectors of the Russian economy. According to one estimate, sanctions imposed by the UK, the US, and the EU have denied Russia access to more than $450 billion since the start of the full-scale war of aggression (including immobilized foreign currency reserves and lost oil tax revenues).2

While the Trump administration has largely refrained from increasing sanctions pressure on Russia (with a few notable exceptions discussed below), it has not lifted the measures put in place by the Biden administration.3 The EU has continued to raise the price of aggression for Russia, adopting several sanctions packages in 2025, with the latest 20th sanctions package being adopted in April 2026.

The level of sanctions pressure on Russia is unprecedented for such a large economy integrated into the global economy.4 Yet the Russian economy has proved to be more resilient than many expected. Russia has exported more than $1 trillion worth of fossil fuels since the start of the full-scale war, and it continues to have access to critical goods and technology necessary for sustaining the war effort.5 As Russia has adapted to the restrictions imposed by the sanctioning coalition — including by sanctions evasion with the help of companies in third countries — there has been increasing attention to sanctioning the enablers of Russian aggression.

North Korea has supplied Russia with millions of artillery rounds, and its soldiers have fought on the front lines in the Kursk region, while Iranian support has been crucial in Russian drone production, with the Iranian-designed Shahed kamikaze drones massively used in strikes across Ukraine.6 These two key enablers directly involved in the war effort are special cases, as the countries are already under significant sanctions pressure (with the reimposition of JCPOA-related sanctions against Iran by the UN in September 2025 adding to that). The extensive sanctions against Belarus are also unique and stem from the country’s complicity in facilitating Russian aggression, with many of the sanctions on Russia and Belarus aligned to thwart possible evasion.7

Photo: Russia's President Vladimir Putin and North Korea's leader Kim Jong Un visit the Vostochny Сosmodrome in the far eastern Amur region, Russia, September 13, 2023. Credit: Sputnik/Mikhail Metzel/Kremlin via REUTERS
Photo: Russia’s President Vladimir Putin and North Korea’s leader Kim Jong Un visit the Vostochny Сosmodrome in the far eastern Amur region, Russia, September 13, 2023. Credit: Sputnik/Mikhail Metzel/Kremlin via REUTERS

Besides these special cases, new jurisdictions that have rarely or never featured in sanctions lists are involved in the trans-shipment of sanctioned goods to Russia, host financial institutions facilitating payments between Western banks and blacklisted Russian banks, or are enabling the continued operation of inadequately insured aging tankers in carrying Russian oil. These evasion channels are shifting sanctions policy further toward action against these enablers of Russia, in parallel to imposing further restrictions on Russia directly.

While the US has a long history of applying sanctions on actions abroad and making use of secondary sanctions, the EU has criticized this approach, even adopting blocking statutes to defend European economic operators from them.8 But as Russia’s war against Ukraine drags on, the political will to sanction Russia’s enablers is growing, and the EU is increasingly adopting restrictions that could be viewed as secondary sanctions (even if in legal terms they are not). 

US sanctions have long been considered more potent than EU ones, given the nature of the international financial system and the widespread use of dollar payments. The US Treasury’s sanctions list is a powerful tool, as implementing sanctions is mandatory not just for US citizens and companies registered there, but for all transactions processed via the financial system of the US (including US dollar payments). Secondary sanctions go even further and target those economically involved with actors under primary sanctions. In a similar fashion, EU sanctions can still reach beyond the EU’s jurisdiction, posing reputational risks and influencing those operators in third countries who are strict about due diligence and compliance, but they have considerably less effect on third-country operators than US sanctions do. The US also has a wide-ranging sanctions enforcement capacity, while EU sanctions are implemented and enforced by the member states, not a single supranational authority.

This paper will look into actions by the EU and the US in sanctioning the enablers of Russia in third jurisdictions. The research will consider restrictions on trade and finance, and sanctions on Russia’s oil exports, as well as the efficiency of various strategies to tackle sanctions evasion. Based on these findings, the paper will offer policy recommendations for further action.

Trade Sanctions: Stopping the Trans-Shipment of Sensitive Technology

Western countries have imposed massive trade sanctions to curb Russia’s military-industrial output, banning the export of military and dual-use technology and other items contributing to Russia’s industrial capacity. Beyond that, they have imposed financial (blocking) sanctions against countless Russian military factories, which should cut all business ties between them and Western companies. Yet Russia continues to have access to sensitive technology and other components, which are in huge demand by its military-industrial complex, via third jurisdictions, where companies are involved in the transshipment of such goods. As noted by a report by the US-China Economic and Security Review Commission, companies (often shell companies) in China and Hong Kong play an especially important role in this.9

In response, the EU and US have targeted some of the companies involved, mainly by hitting them, or the people behind them, with full blocking sanctions or milder restrictions, such as a ban on or licensing requirement for exporting dual-use technology to those companies.

The EU has established a list of companies that are part of or support Russia’s military-industrial complex.10 Although it contains primarily Russian companies, an increasing number of third-country operators involved in shipping sensitive technology to Russia have been added in recent years (from mainland China, Hong Kong, Turkey, the United Arab Emirates, and Central Asian countries, to name some of the most prominent jurisdictions).11 As a consequence, the EU has prohibited the export of dual-use goods and other sensitive technology to those companies. The EU has also established a framework to impose full financial sanctions on companies in third countries that are involved in circumventing EU sanctions, although the rigorous evidentiary threshold required to impose sanctions in the EU means it has been used rather sparingly.12 These sanctions have a far greater scope and, in essence, cut off the sanctioned companies from doing business with EU members and freeze their assets located in the EU.

Photo: YANTAI, CHINA - APRIL 26, 2023 - An LNG tank is hoisted at the construction site of an LNG receiving station in the Xigang area of Yantai Port, Shandong Province, China, April 26, 2023. On April 26, 2023, the five 200,000 cubic meter storage tanks of the Xigang Area liquefied natural gas (LNG) receiving terminal project at Yantai Port in Shandong Province were completed, marking the transfer of the construction phase of the storage tanks from civil construction to installation. The LNG receiving station project is a key implementation project of the National Implementation Plan for the Construction of Liquefied Natural Gas Storage and Transportation System in the Bohai Rim Region. Upon completion, it will provide energy security for Shandong, Bohai Rim and even North China in a sustainable and stable manner, and enhance regional peak regulation, gas storage and winter supply protection capabilities. Credit: Photo by CFOTO/Sipa USA
Photo: YANTAI, CHINA – APRIL 26, 2023 – An LNG tank is hoisted at the construction site of an LNG receiving station in the Xigang area of Yantai Port, Shandong Province, China, April 26, 2023. Credit: Photo by CFOTO/Sipa USA

The US has also used its Bureau of Industry and Security’s (BIS) Entity List to restrict the export of sensitive high-tech equipment to many Russian and third-country operators. Like the equivalent EU list, most entries related to Russia’s war of aggression against Ukraine are Russian companies, but many third-country entries appear for their support of Russia’s war effort. The US has used full financial sanctions far more extensively than the EU against third-country operators, with hundreds of companies under full blocking sanctions for supplying Russian companies with sanctioned goods used in the military industry. Notably, the State Department’s announcements have specified the value of the supplied goods as well as the periods when the trans-shipments took place.13

Viewing the situation purely in terms of numbers, companies involved in trans-shipping sanctioned goods make up the bulk of third-country designations on the sanctions lists of the US and the EU. Tellingly, in the summer of 2024, BIS moved to allow entire addresses to be added to the list in an effort to thwart the frequent use of shell companies in some jurisdictions to evade restrictions imposed on specific companies.14 In Hong Kong, particularly, corporate structure and ownership can be obscured and new companies can be set up or dissolved swiftly to facilitate transshipping of sanctioned goods.15 Designating specific addresses helps in further disrupting trans-shipment schemes, as setting up shell companies relies on intermediaries who offer registration services for specific addresses, but it falls short of decisively stopping the trans-shipment of sanctioned goods.16

Photo: Rohuneeme. Estonian authorities detained an oil tanker which forms part of Russia's "shadow fleet" and which had been sailing through Estonian waters in the Gulf of Finland. The vessel Kiwala is not permitted to sail on the open seas. Credit: Photo Eero Vabamägi, Postimees via Reuters
Photo: Rohuneeme. Estonian authorities detained an oil tanker which forms part of Russia’s “shadow fleet” and which had been sailing through Estonian waters in the Gulf of Finland. The vessel Kiwala is not permitted to sail on the open seas.
Credit: Photo Eero Vabamägi, Postimees via Reuters

Still, designating companies involved in the transshipment of sanctioned technology to Russia does make a difference. It disrupts supply chains that have been set up to continue procurement of high-tech components for Russia’s military industry, forcing malicious actors to find new channels of sanctions evasion. Setting up these elaborate circumvention schemes can be costly and time-consuming, often concocted under the direction or with the support of Russian intelligence services.17

Such designations also serve to warn Western producers and suppliers of electronic components and other goods necessary for Russia’s military industry that they should be wary of certain jurisdictions when exporting their goods. Some countries have so many companies under Western sanctions that Western companies step up their compliance checks when doing business there. Sanctions designations also help Western diplomats spell out for their third-country counterparts which companies there are evading sanctions, and how. And too many designated companies in a given jurisdiction can be an embarrassment, prompting those governments to take action.

The limitations on sanctioning individual companies raise the possibility of sanctioning entire industries in third countries, which so far has not happened.18 In a first step in that direction, the EU in June 2023 cleared the way for banning the export of certain goods to certain third countries, if other measures have failed to prevent those goods systematically reaching Russia via that jurisdiction. While member states were hesitant to put the “anti-circumvention tool” to use, it was activated with the 20th sanctions package in April 2026, banning the export of certain sensitive technology to Kyrgyzstan. The EU thus acknowledged that, despite other measures, the high risk of sanctions circumvention persists. Overall, this indicates the breaking of a taboo in EU policy against targeting entire industries in third countries.

Financial Sanctions: Cutting the Financial Channels between Russia and the West

Sanctions on the financial industry can also help disrupt the transshipment of sanctioned goods. In parallel with the goods physically moving among jurisdictions, payments usually flow between the West and Russia via third-country intermediaries due to wide-ranging sanctions against the Russian banking sector. The more difficult it is for those payments to be made, the more complex channels must be used to allow the transfers to happen. As with intricate supply chains, setting up these payment channels takes time, effort, and money.

Much of the legislative effort of the EU and US so far regarding sanctions against the financial sector of Russia’s enablers has gone into establishing a legal basis for sanctioning foreign financial institutions that assist in circumventing existing sanctions.

Photo: Railway tank cars carrying oil in Moscow. Credit: JSPhoto / Alamy
Photo: Railway tank cars carrying oil in Moscow. Credit: JSPhoto / Alamy

The EU has introduced criteria that allow it to sanction institutions connected to Russian financial messaging systems (SPFS, SBP, Mir) or those that process transactions for sanctioned trade operations. Throughout 2025, various institutions were sanctioned under these criteria. The EU started off with designating a few Belarusian banks, then expanded to Chinese, Kyrgyzstani, Kazakhstani, Tajikistani, Azerbaijani, and Laotian banks (including subsidiaries of Russian banks in those countries). The lifting of sanctions on two regional Chinese banks in 2026 is a notable move, as the banks halted all settlements with Russia after being sanctioned. This exemplifies the direct effect EU sanctions have on changing the behavior of FFIs.

Under the Biden administration, the US repeatedly widened the criteria for allowing it to target foreign financial institutions. First, in December 2023, it authorized sanctions on institutions involved in significant transactions related to Russia’s military-industrial base. Then, in June 2024, it broadened the definition of Russia’s military-industrial base to include an extremely wide array of people and organizations previously sanctioned. Still, only Keremet Bank in Kyrgyzstan has so far been caught in the wider net, for facilitating cross-border transfers on behalf of a sanctioned Russian bank with deep ties to Russia’s military-industrial complex.19

The importance of a legal framework for sanctioning foreign financial institutions should not be underestimated. Together with loud and clear public messaging, it sends a signal to financial institutions around the world looking to evade sanctions and assist Russia in its war effort. Judging from various news reports, such signaling can be enough to limit payments between banks in Russia and third countries.20 This deterrent effect can fade over time, as institutions devise new schemes or payment channels, or if sanctions are not actually levied and market operators get bolder in carrying out their transactions. But devising new schemes soaks up money and time, which, without a doubt, hinders Russia’s war machine.

As traditional financial institutions in sanctioning countries face tighter regulations and those in third jurisdictions limit transactions due to the threat of secondary sanctions, malevolent actors have turned to cryptocurrencies to evade sanctions. That is a problem for enforcement agencies, as crypto transactions are further removed from traditional financial institutions.

Photo: Indian Prime Minister Narendra Modi talks with Russian President Vladimir Putin and Chinese President Xi Jinping ahead of the Shanghai Cooperation Organization (SCO) Summit 2025 at the Meijiang Convention and Exhibition Centre in Tianjin, China, September 1, 2025. Credit: UO TAKEKUMA
Photo: Indian Prime Minister Narendra Modi talks with Russian President Vladimir Putin and Chinese President Xi Jinping ahead of the Shanghai Cooperation Organization (SCO) Summit 2025 at the Meijiang Convention and Exhibition Centre in Tianjin, China, September 1, 2025. Credit: UO TAKEKUMA

The sanctioning coalition is taking steps to limit sanctions circumvention via cryptocurrencies, including schemes set up by Russia in other jurisdictions. Notably, the Treasury Department sanctioned entities and people related to Grinex, the reconstituted version of Garantex, a cryptocurrency exchange notorious for criminal transactions that was disrupted by US, Finnish, and German investigators in March 2025.21 In addition to Grinex, among the targets was Old Vector, which issued a ruble-backed stablecoin. Both companies were registered in Kyrgyzstan but were clearly linked to Russian efforts to circumvent restrictions on payment channels.22

Energy Sanctions: Curbing Russia’s Oil Revenues

One key pillar of Western sanctions against Russia since the start of the full-scale invasion has been to curb the energy revenues that are crucial to funding Russia’s war effort, focusing especially on oil exports. According to the Center for Research on Energy and Clean Air, Russia’s oil exports from February 2022 to April 2026 brought in more than 800 billion USD.23 It is easy to see why the sanctioning coalition has focused on limiting the revenues Russia earns from oil exports—oil makes up a large portion of Russian revenues, and even a proportionally modest impact can have a serious impact in absolute terms. The US banned the import of Russian oil in March 2022, and the EU followed suit with a ban on the seaborne import of Russian oil in December 2022.24

At the end of 2022, G7 partners also agreed to cap the price for Russian crude oil and oil-product exports to third countries, looking to leverage the widespread use of Western services, especially insurance, in shipping Russian oil and oil products. The aim was to avoid yanking Russian oil off the global market, which would risk instability, but to ensure that Russia would earn less than under normal circumstances. In response, Russia started sending oil to third countries via a “shadow fleet” of aging tankers with questionable, if any, insurance and murky ownership, sailing under flags of convenience and using shady shipping practices. By now, the shadow fleet carries the vast majority of Russian crude exports, flouting the price cap.

Sanctioned shadow fleet tankers cannot call at ports of the sanctioning countries, and they cannot use a wide variety of services provided by companies registered there, most importantly, protection-and-indemnity insurance. These restrictions complicate tanker operations — especially given that prior export routes from Russian European ports into Europe have been replaced by lengthy voyages to China and India — but sanctions themselves cannot stop sanctioned tankers from loading Russian oil and traveling to a non-sanctioning country to offload it. 

With its major role in Russia’s oil exports, the shadow fleet has become a prime target of Western sanctions against third countries, as these vessels are not under direct Russian ownership and do not fly the Russian flag. Initially, the US added more tankers to its sanctions list than the EU, but in 2025, the Europeans added hundreds of vessels and now far outpace the US. 

The EU has also moved beyond targeting individual tankers to sanction other operators involved in the broader shadow fleet ecosystem. This move has caught up various companies managing or operating shadow fleet tankers, as well as companies operating the flag registries of some countries that offer flags of convenience to shadow fleet tankers. With the last few sanctions packages, the EU has also started targeting refineries and oil traders involved in processing and trading Russian crude oil.

Photo: Cook Islands registered oil tanker Eagle S anchored near the Kilpilahti port in Porvoo, Finland on the Gulf of Finland on January 13, 2025. The tanker is suspected of the disruption of the Finland-Estonia electrical link Estlink 2 and the tanker is also suspected to be part of the so-called Russian shadow fleet. Credit: VESA MOILANEN/LEHTIKUVA/Sipa USA via REUTERS connect
Photo: Cook Islands registered oil tanker Eagle S anchored near the Kilpilahti port in Porvoo, Finland on the Gulf of Finland on January 13, 2025. The tanker is suspected of the disruption of the Finland-Estonia electrical link Estlink 2 and the tanker is also suspected to be part of the so-called Russian shadow fleet. Credit: VESA MOILANEN/LEHTIKUVA/Sipa USA via REUTERS connect

Sanctions against different nodes of the shadow fleet ecosystem have had mixed results. Designations of tankers themselves is effective because they are difficult to circumvent: Even if a vessel’s name, flag, or ownership changes, its unique identifying number issued by the UN’s International Maritime Organization stays the same. Sanctioning tanker owners or operators is less efficient, as it is easy to periodically transfer ownership to newly created shell companies. For example, one address in Dubai reportedly housed more than 60 front companies managing shadow fleet tankers, with no evidence of the companies physically operating in that location.25 Tracing the frequently changing ownership of tankers previously controlled by the Russian government via state-owned shipping company Sovcomflot reveals that as management companies are sanctioned, vessels are transferred to newly created front companies.26

Perhaps the most forceful measures are targeted sanctions on the demand side of the Russian oil trade, against refineries in third countries that accept shipments of Russian crude and process it into oil products. Continued imports into the EU of such oil products made from Russian crude have been described as a back-door way to fund the Kremlin’s war chest.27 The EU closed this loophole in January 2026 with the 18th sanctions package, which banned such oil products.28

Photo: Lukoil logo seen outside a petrol station in St. Petersburg. Credit: Photo by Maksim Konstantinov / SOPA Images/Sipa USA
Photo: Lukoil logo seen outside a petrol station in St. Petersburg. Credit: Photo by Maksim Konstantinov / SOPA Images/Sipa USA

The EU has also targeted certain companies in China and India that are major refiners of Russian oil and thus provide revenue to the Russian government. In July 2025, it sanctioned Nayara Energy, an Indian company partially owned by Russian state-owned oil giant Rosneft. In October, designations of the Liaoyang Petrochemical Company and Shandong Yulong Petrochemical Company — significant buyers of Russian oil in China — followed. The results have been clear, as non-Russian suppliers have canceled contracts and severed financial ties with the blacklisted companies, forcing changes of corporate structures and rerouting of both import and export flows.29 Coupled with US designations of oil majors Rosneft and Lukoil as well as the imposition of a secondary tariff on India for continued imports of Russian oil, these sanctions widened the discount between Brent and Urals blends. This dynamic shifted with the closure of the Strait of Hormuz, which significantly increased the demand for Russian oil, thereby surging the price of Ural even past that of Brent.30

In any case, while oil producers have often offered short-term discounts to keep business after additional sanctions pressure, they can hardly afford to offer long-term discounts,  which would significantly diminish their investment possibilities. The global decline in oil prices in 2025, coupled with additional sanctions pressure from the US and the EU, resulted in a large federal budget deficit for Russia, with mineral extraction tax lagging substantially behind year-on-year.31 In 2026, however, Russia has clearly profited from the Iran war, which has driven up the  price of oil globally.32 The price of Urals crude doubled from $45 per barrel in February to over $90 per barrel in April.33

Photo: Signages display the logos of NIS as well as Russian oil producer Gazprom Neft, in Belgrade, Serbia October 8, 2025. Credit: REUTERS/Marko Djurica
Photo: Signages display the logos of NIS as well as Russian oil producer Gazprom Neft, in Belgrade, Serbia October 8, 2025. Credit: REUTERS/Marko Djurica

Beyond the implications of the Iran war, a few things about oil sanctions remain unclear: How much can those sanctions reduce Russia’s oil revenues? Could prices for Russian oil be pushed lower with stronger enforcement of the price cap or a complete ban on providing maritime services for tankers carrying Russian oil? The US’s longtime hawkish strategy on Iran demonstrates that even aggressive targeting of vessels, refineries, and traders cannot shut down oil exports. Further, conflicting policy goals in other fields can make (sanctioned) Russian oil more attractive, as evidenced by the US loosening up restrictions on the transfer of sanctioned Russian oil to alleviate the price shock stemming from the closure of the Strait of Hormuz.

Conclusion and Policy Recommendations

Western sanctions against Russia have become a major pillar of the policy response to Russia’s war of aggression against Ukraine. Implementing tough measures to limit Russia’s access to critical goods and technology, sever financial ties between Russia and the G7+ coalition, and cut Russian energy revenues has proved a challenge, given Russia’s prewar integration into the global economy. Yet the unprecedented sanctions imposed on Russia and its enablers have to some degree achieved their goals. As evidence of sanctions pressure on the Russian economy, it is extremely telling that sanctions relief is among the top demands of Russia in any discussions over a negotiated end to the war of aggression.

Although the US has long employed secondary sanctions, the EU has been less willing. So it’s notable that various measures in recent sanctions packages have been directed toward operators in third jurisdictions, although the EU has stopped short of calling these sanctions secondary. Given the threat that Russia’s war of aggression poses to the future of European security — European leaders often call it existential — it should come as no surprise that the EU is setting precedents, with sanctions policy reaching toward extraterritoriality and employing secondary sanctions further than before, even though it has previously criticized the US for doing so. In targeting third jurisdictions, wider political considerations come into play, of course, perhaps even more than for the US. As EU sanctions require that each member agrees to them, the special interests of one member can shape the sanctions policy of the whole union.34

Although both primary sanctions against Russia and secondary sanctions on its enablers have constrained Russia’s ability to continue the war of aggression against Ukraine, there is clear room for further action and leverage not yet used. Therefore, we offer the following recommendations for policymakers:

Add new designations on a continuing basis, including (secondary) sanctions on systematic enablers of sanctions circumvention

Given the adaptation of Russia and its enablers, tactics of sanctions evasion are constantly evolving. The sanctions response should be dynamic as well, to reflect emerging trends of evasion and to target additional entities both in Russia and in third jurisdictions. This would also reinforce the restrictions in place already, making them more difficult to circumvent. Regular addition of sanctions signals political will to keep and increase the pressure on Russia, to puncture the Kremlin’s belief that time is on its side. It also sends a clear signal to jurisdictions, enabling sanctions circumvention that consequences will follow. Being on a sanctions list can scare away potential business, given the implied threat of secondary sanctions and the size of their penalties, but a long pause in imposing penalties can embolden actors to continue transactions with sanctioned parties.

Photo: Ruble bank notes. Photo: By Romi_Lado via Pixabay.
Photo: Ruble bank notes. Photo: By Romi_Lado via Pixabay.

Employ designations targeting third-country operators together with diplomatic outreach efforts.

It is clear that sanctions on operators in third countries do not significantly stop sanctions circumvention by themselves (at least in the current number and in the sectors currently targeted). However, they offer specific examples in diplomacy with those countries that sanctioning countries will not tolerate circumvention. Having numerous blacklisted companies in your jurisdiction can become an embarrassment that some countries may want to avoid. Issues of sanctions circumvention should become an integral part of broader diplomatic relations with third countries. In certain sectors and with certain countries, a clearer choice should be presented — do they wish to continue business with the G7+ coalition or with Russia? Expectations to governments of the third countries must also be clearly worded, and it should be made clear that ongoing sanctions circumvention would not be tolerated and further restrictions would follow. 

Follow emerging trends and act based on new information.

As the landscape of sanctions evasion is not static, policymakers should study emerging trends of circumvention, including new methods, new jurisdictions, and new companies involved, when considering further action. When new jurisdictions not prominently linked with sanctions evasion pop up, they can be quickly exploited if no steps are taken to limit these activities. Regarding the shadow fleet, newly emerged flag states or new destinations of oil for sanctioned vessels indicate new targets for additional sanctions leverage. Furthermore, the use of new transaction methods such as cryptocurrency indicates the need for the sanctions coalition to act, to close alternative payment channels with Russia by which sanctions evasion would otherwise be possible. This may require strengthening the capacities and capabilities of national authorities working on sanctions enforcement and analytics, in addition to improved information sharing both nationally and transnationally.

Focus designation efforts more on financial institutions, for whom continued economic ties with G7+ coalition jurisdictions are important.

The bulk of third-country operators sanctioned so far for their role in Russia’s war of aggression against Ukraine are companies involved in the transshipment of sanctioned goods. While these designations serve as good compliance indicators for risky jurisdictions, they have not had a significant direct impact in limiting this behavior. Therefore, designation efforts could focus on established operators — especially in the financial sector — as access to Western financial markets and the ability to continue business with counterparts in the sanctioning coalition remains important. It is also more difficult to circumvent such restrictions, compared with trade sanctions, by merely creating a new front company.

Follow new sanctions frameworks and criteria with designations, to maintain credibility and deterrence.


Evidence so far confirms that new frameworks and criteria for sanctioning certain actors have an effect, especially threats of secondary sanctions on financial institutions. But if sanctions are not forthcoming, that effect dilutes over time, as the possible economic benefit of continuing risky business outweighs the sanctions risk. To maintain a longer-lasting impact and send signals of credibility, designations should follow.

Articulate a clear strategy for reducing Russian oil revenues, with enforcement measures to implement it.

All G7 members except the US lowered the price cap for Russian crude oil in 2025. The EU and the UK have also sanctioned significant numbers of shadow fleet tankers and some refineries importing Russian crude. The US has stuck with a higher price cap and not sanctioned any Russian shadow fleet vessels or refineries during the Trump administration, but the US has imposed blocking sanctions on oil majors Rosneft and Lukoil. The oil price cap may have outlived its time, particularly as the Iran war has disrupted the global energy market. With flows through the Strait of Hormuz blocked, oil prices have become increasingly volatile. As discussions over a possible maritime services ban for transporting Russian oil continue, the question remains: to what extent can sanctions still meaningfully affect the amount and price of Russian oil exports, either via the price cap or a total services ban? In either case, additional enforcement measures — systematic sanctioning of the shadow fleet, including the whole ecosystem of operators involved in the trade — should be employed consistently to implement the chosen strategy. Having a clearly worded strategy to communicate to third countries continuing imports of Russian oil would also prove useful, especially if the threat of secondary sanctions looms large. 

Offer off-ramps and incentivize behavior changes to escape sanctions.  

Imposing sanctions is not the ultimate goal by itself, but rather a tool to reach a favored outcome. If there is no doubt that sanctioned people or entities have changed their behavior, lifting sanctions (partially or fully) should be an avenue for policymakers to pursue. In the 20th sanctions package, the EU delisted two regional Chinese banks (previously sanctioned for facilitating sanctions circumvention) that stopped all Russian settlements. It also introduced the possibility of granting derogations to the sanctioned Nayara refinery in India, facilitating a reduction of the intake of Russian crude oil. These are encouraging signals for other sanctioned companies whose restrictions are not permanent, should they change their behavior.

Aim for maximum possible overlap of restrictions across the sanctions coalition.

The wider the group of countries implementing certain restrictions, the more impact the restrictions have. Harmonization of sanctions lists and measures closes possible loopholes that malevolent economic operators can abuse, but also sends a stronger signal of intent and unity to third countries.

Don’t neglect primary sanctions when increasing sanctions pressure on Russia’s enablers.

Additional designations of companies operating in the military-industrial complex are important, as new companies emerge and existing companies not previously operating in the civilian sector can switch to it. All in all, operators in third jurisdictions are more wary of dealing with sanctioned companies than unsanctioned ones. Updating the primary sanctions lists also creates the legal possibility to target the enablers involved in third countries and reduce possible ambiguity that might surround continued business ties. That can also force some degree of compliance of Western companies that check the background not only of their clients, but also of the clients of their clients.

About the Author

Mihkel Märtens was a Baltic-American Freedom Foundation Fellow at the Center for European Policy Analysis, where he was researching the use of sanctions against Russia’s enablers. In Estonia, he serves at the Ministry of Foreign Affairs as Desk Officer for the Department of Sanctions and Strategic Export Control. He has been involved in negotiations of numerous EU sanctions packages against Russia. He has previously worked as a foreign news editor in Estonia and has completed his military service in the Cyber Command of the Estonian Defense Forces.

Acknowledgements

The author wishes to acknowledge the generous support of the Baltic-American Freedom Foundation, which made the author’s visiting fellowship – and research for this report – at CEPA possible.

CEPA is a nonpartisan, nonprofit, public policy institution. All opinions expressed are those of the author(s) alone and may not represent those of the institutions they represent or the Center for European Policy Analysis. CEPA maintains a strict intellectual independence policy across all its projects and publications.

  1. citation
  2. Mills, Claire. “Sanctions against Russia: What Has Changed in 2025?” House of Commons Library, September 22, 2025. https://commonslibrary.parliament.uk/research-briefings/cbp-10342/.
  3. However, the US issued a general license to allow the sale of Russian oil and petroleum products, due to the turmoil in global oil markets as a result of the Iran war.
  4. Vohra, Anchal. “New EU Sanctions on Russia ‘Unprecedented.’” dw.com. Deutsche Welle, July 18, 2025. https://www.dw.com/en/new-eu-sanctions-on-russia-unprecedented/a-73330761.
  5. Payments to Russia for Fossil Fuels. “Russia Fossil Tracker – Payments to Russia for Fossil Fuels since 24 February 2022,” April 14, 2026. https://www.russiafossiltracker.com/.
  6. Cranny-Evans, Sam. “Brothers in Arms: Assessing North Korea’s Contribution to Russia’s War in Ukraine.” Rusi.org, May 6, 2025. https://www.rusi.org/explore-our-research/publications/commentary/brothers-arms-assessing-north-koreas-contribution-russias-war-ukraine.https://www.rusi.org/explore-our-research/publications/commentary/brothers-arms-assessing-north-koreas-contribution-russias-war-ukraine
  7. In December 2025 and March 2026, the US relieved some sanctions in place against Belarus in exchange for the release of political prisoners, notably on its flag carrier Belavia and the fertilizer industry (a key export commodity for the country). Other restrictions, including all of the restrictions imposed by the EU have stayed in place.
  8. Geranmayeh, Ellie, and Manuel Lafont Rapnouli. “Meeting the Challenge of Secondary Sanctions.” ECFR, June 25, 2019. https://ecfr.eu/publication/meeting_the_challenge_of_secondary_sanctions/.
  9. Ayres, Graham, and Lyndi Tsering. “China’s Facilitation of Sanctions and Export Control Evasion.” U.S.-China Economic and Security Review Commission Staff Research Report. U.S.-China Economic and Security Review Commission Staff Research Report, November 14, 2025. https://www.uscc.gov/sites/default/files/2025-11/Chinas_Facilitation_of_Sanctions_and_Export_Control_Evasion.pdf
  10. So-called ’annex IV listings’, referring to annex IV of Council Regulation 833/2014.
  11. European Union. “COUNCIL REGULATION (EU) No 833/2014 of 31 July 2014 Concerning Restrictive Measures in View of Russia’s Actions Destabilising the Situation in Ukraine,” July 31, 2014.
  12. Full-fledged financial sanctions in the framework of the restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine (Council Regulation 269/2014).
  13. United States Department of State. “New Measures Targeting Third-Country Enablers Supporting Russia’s Military-Industrial Base – United States Department of State,” October 30, 2024. https://2021-2025.state.gov/new-measures-targeting-third-country-enablers-supporting-russias-military-industrial-base/.
  14. US Department of Commerce Bureau of Industry and Security. “Department of Commerce Announces Additional Export Restrictions to Counter Russian Aggression,” June 11, 2024. https://www.bis.gov/node/20501.
  15. Ayres, Graham, and Lyndi Tsering. “China’s Facilitation of Sanctions and Export Control Evasion.” U.S.-China Economic and Security Review Commission Staff Research Report. U.S.-China Economic and Security Review Commission Staff Research Report, November 14, 2025. https://www.uscc.gov/sites/default/files/2025-11/Chinas_Facilitation_of_Sanctions_and_Export_Control_Evasion.pdf.
  16. “Investigating Address-Only Entries on the BIS Entity List.” Sayari, May 16, 2025. https://sayari.com/resources/blg-investigating-address-only-entries-on-bis-entity-list/.
  17.  Allison, Olivia, and Gonzalo Saiz Eruasquin. “Track and Disrupt: How to Counter Sanctions-Evasion Networks.” Rusi.org, November 10, 2023. https://www.rusi.org/explore-our-research/publications/commentary/track-and-disrupt-how-counter-sanctions-evasion-networks; Alecci, Scilla. “Russia Secretly Bought Western Tech to Protect Nuclear Subs.” International Consortium of Investigative Journalists, October 23, 2025. https://www.icij.org/investigations/russia-archive/russia-secretly-acquired-western-technology-to-protect-its-nuclear-submarine-fleet/; US Department of Commerce Bureau of Industry and Security. “Commerce Cuts off Russian Procurement Network Evading Export Controls,” December 13, 2022. https://www.bis.gov/press-release/commerce-cuts-russian-procurement-network-evading-export-controls.
  18. The EU’s ban on transit of high-tech components to third countries through Russia could be viewed as one, as it has banned trade between the EU and certain third countries by means of the quickest and cheapest trade route (transit via Russia). Another such measure is the requirement for EU exporters selling sensitive technology abroad to contractually prohibit their re-export to Russia.
  19. U.S. Department of the Treasury. “Treasury Disrupts Russia’s Sanctions Evasion Schemes.” U.S. Department of the Treasury, January 15, 2025. https://home.treasury.gov/news/press-releases/jy2785.
  20. Sezer, Can, Nevzat Devranoglu, and Dmitry Zhdannikov. “Exclusive: Turkish-Russian Trade Hit by Fresh US Sanctions Threat.” Reuters, February 19, 2024. https://www.reuters.com/markets/turkish-russian-trade-hit-by-fresh-us-sanctions-threat-2024-02-19/; Reuters. “Exclusive: Banking Bottleneck Causing Six-Month Delays for Russia-China Payments, Sources Say.” Reuters, April 4, 2024. https://www.reuters.com/business/finance/banking-bottleneck-causing-six-month-delays-russia-china-payments-sources-say-2024-04-04/
  21. U.S. Department of the Treasury. “Treasury Sanctions Cryptocurrency Exchange and Network Enabling Sanctions Evasion and Cyber Criminals,” August 14, 2025. https://home.treasury.gov/news/press-releases/sb0225; Chainalysis. “International Action Dismantles Notorious Russian Crypto Exchange Garantex – Chainalysis,” March 10, 2025. https://www.chainalysis.com/blog/russian-exchange-garantex-dismantled/.
  22. Trmlabs.com. “Russia Leveraging Kyrgyzstan’s Crypto Ecosystem to Evade Sanctions | TRM Blog,” 2025. https://www.trmlabs.com/resources/blog/russia-leveraging-kyrgyzstans-crypto-ecosystem-to-evade-sanctions; Ernist Nurmatov, Merhat Sharipzhan, and RFE/RL’s Kyrgyz Service. “State Silence Fuels Fears Kyrgyz Crypto Boom Busting Russia Sanctions.” RadioFreeEurope/RadioLiberty. RFE/RL, July 13, 2025. https://www.rferl.org/a/kyrgyzstan-grinex-crypto-currency-russia-sanctions-evasion/33470887.html.
  23. Centre for Research on Energy and Clean Air. “Financing Putin’s War on Europe: Fossil Fuel Imports from Russia during the Invasion of Ukraine,” n.d. https://energyandcleanair.org/financing-putins-war/.
  24. Pipeline imports of Russian oil into the EU are not under sanctions.
  25. Roslund, Riku, and Jyri Hänninen. “MOT Paljasti, Kuinka Venäjä Piilottaa Varjolaivojen Omistajat – Ulkoministeri Valtonen: ”Jättimäinen Ongelma”.” Yle Uutiset, March 3, 2025. https://yle.fi/a/74-20146422.
  26. Hilgenstock, Benjamin, Oleksii Hrybanovskii, Anatoliy Kravtsev, Borys Dodonov, Yuliia Pavytska, and Nataliia Shapoval. “Assessing Russia’s Shadow Fleet: Initial Build-Up, Links to the Global Shadow Fleet, and Future Prospects,” 2024. https://kse.ua/wp-content/uploads/2024/06/Global-Shadow-Fleet-June-2024.pdf.
  27. “Sanctions Update: EU and UK Tighten Restrictions on Russian Oil and Provision of Software to Russia.” Latham & Watkins LLP, August 18, 2025. https://www.lw.com/admin/upload/SiteAttachments/Sanctions-Update-EU-and-UK-Tighten-Restrictions-on-Russian-Oil-and-Provision-of-Software-to-Russia.pdf; Partsvania, Vakhtang. “Closing the ‘Back Door’: EU Intensifies Fight against Oil Sanctions Evasion – Riddle Russia.” Riddle Russia, July 24, 2025. https://ridl.io/closing-the-back-door-eu-intensifies-fight-against-oil-sanctions-evasion/.
  28. Harvey, Robert, and Julia Payne. “What Are the EU’s New Rules on Banning Fuel Imports Made from Russian Crude?” Reuters, October 16, 2025. https://www.reuters.com/sustainability/boards-policy-regulation/eu-publishes-rules-ban-close-back-door-russian-oil-2025-10-16/.
  29. Chen Aizhu, Li Yap, and Florence Tan. “How Sanctions Made a Showpiece Chinese Refinery’s Western Partners Run for the Exits.” Reuters, November 27, 2025. https://www.reuters.com/business/energy/how-sanctions-made-showpiece-chinese-refinerys-western-partners-run-exits-2025-11-26/.
  30. Reuters Staff. “Russian Urals Oil Price Tops Brent for First Time in Indian Market, Traders Say.” Reuters, March 6, 2026. https://www.reuters.com/business/energy/russian-urals-oil-price-tops-brent-first-time-indian-market-traders-say-2026-03-06/; Sharma, Rakesh, and Yongchang Chin. “Russia Oil Offered to India at Deep Discount after US Sanctions.” Bloomberg.com. Bloomberg, November 24, 2025. https://www.bloomberg.com/news/articles/2025-11-24/russian-oil-offered-to-india-at-deep-discount-after-us-sanctions; Reuters Staff. “Russia’s Urals Oil Price Discount Widens to 23% in November, Central Bank Says.” Reuters, November 27, 2025. https://www.reuters.com/business/energy/russias-urals-oil-price-discount-widens-23-november-central-bank-says-2025-11-27/.
  31. Re:Russia. “Oil Prices Have Fallen: Next Year, Russia Is Very Likely to Have to Live with Oil Prices in the Range of $40–45 per Barrel,” August 12, 2025. https://re-russia.net/en/analytics/0368/.
  32. Goodley, Simon. “Russia Earned €6bn from Fossil Fuel Exports since Start of Iran War, Data Suggests.” the Guardian. The Guardian, March 12, 2026. https://www.theguardian.com/world/2026/mar/12/russia-fossil-fuels-revenue-us-israel-war-iran-data.
  33. Сергей Вакуленко. “Бенефициар войны. Какие выгоды получает Россия от закрытия Ормузского пролива.” Carnegieendowment.org, March 27, 2026. https://carnegieendowment.org/ru/russia-eurasia/politika/2026/03/russia-oil-iran-war-consequences.
  34. Contrary to foreign policy decisions (as is the case with adopting sanctions), energy policy remains a policy pillar in which decisions are taken with qualified majority voting (QMV). Recent EU decisions to phase-out of Russian energy imports within the REPowerEU framework indicate that significant decisions can be taken without the unanimous support of member states, but unless all member states agree otherwise, sanctions will remain an area where decisions will continue to be taken unanimously.

The post Transatlantic Action: Sanctioning Third-Country Enablers of Russia’s War Economy appeared first on CEPA.

Europe’s Defense Factories: More Urgency Please

2026-04-24 03:09:09

Europe’s new €1.5bn ($1.8bn) defense industry program has a line item nobody expected. Factories built to produce counter-drone weapons can now claim EU money to protect themselves from unmanned aerial vehicles (UAVs). The Commission adopted the work program on 30 March, but the policy consequences will be harder to agree on.

The European Defense Industry Program (EDIP) covers propellant powders, electronic fuses, gallium nitride semiconductors for radar and electronic warfare, and guided-munition assembly lines. Commissioner Andrius Kubilius said the work program offers “immediate opportunities.”

In the Brussels vocabulary, “immediate” means deliveries from 2028 and lines uncertified before 2033.

The new framework combines two functions Brussels used to handle separately. First, a standing governance architecture for crisis-time industrial coordination, including security-of-supply guarantees, accelerated permitting, priority access to inputs, and multinational procurement structures.

Second, direct co-financing of physical production capacity. More than €700m for industrial reinforcement through tooling, filling plants, production lines, and conversion of existing civilian heavy industry for defense production.

Page 10 of the work program, in the first call for energetic components, offers recipients up to €500,000 per project to physically protect production sites. The EU will help pay for the machines, while the shells come from national budgets and loans.

Alongside it sits the much larger Security Action for Europe (SAFE), a €150bn facility through which Brussels lends to member states for procurement. Nineteen of the 27 EU states submitted plans, and demand immediately exceeded the budget.

While SAFE finances buying, the industrial program finances building, and writes the European-content rules.

The European Defense Industry Program is expected to run for three to five years, with a hard completion deadline of December 31, 2033. It is built for medium-term resilience, not for the threat on Europe’s eastern flank, which is measured in months.

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US European Command’s General Alexus Grynkewich told the Senate Armed Services Committee in March that European allies should be ready to lead the defense of the continent by 2035. Money is no longer the greatest constraint; the lack of production capacity is. Even on brownfield sites, the timeline is slow.

German Foreign Minister Johann Wadephul warned in February that Berlin’s air defense stocks were running critically low. Russian shell and drone production is at wartime tempo. It’s not hard to work out the risks.

Brussels’ eligibility rules cap non-EU components at 35% and require design authority to sit inside the EU or an associated country. That currently means Norway. The UK, home to BAE Systems, Rolls-Royce, and Thales UK, is not currently eligible for grants. The May 2025 UK-EU Security and Defense Partnership opens a path to UK involvement in SAFE-financed procurement, but no industrial-program association has followed.

Turkey, the second-largest NATO army and a rising drone and ammunition producer, is also excluded, while Washington has publicly criticised EDIP’s ‘Buy European’ preference rules and warned of retaliation.

Poland illustrates the tougher problem. Warsaw runs the most aggressive acquisition cycle in the EU, but its flagship purchases (K2 tanks, F-35s, HIMARS, Apaches, and other missile systems and warships) are loan-financed national deals that bypass the EU’s central system. Poland’s interest in Brussels lies in ammunition, drones, and air defense subsystems, where European content is high.

Warsaw’s approach is rational for Warsaw. It is also a warning. If other frontline states copy it, the industrial program becomes a subsidy for the niches while continental rearmament is bought in Washington, Seoul, and London.

Uptake will not be symmetric. Hungary’s Fidesz government repeatedly blocked or diluted EU Ukraine-related defence measures before its April defeat, while incoming Prime Minister Péter Magyar has signalled constructive engagement with Brussels, he also echoed his predecessor’s demand for Ukraine to reopen the Druzhba oil pipeline.

Oil started flowing again on April 23, but Magyar’s stance is a signal that the Central European drag on EU Ukraine policy may not completely disappear. Slovakia has at times taken similar positions.

The program’s reach in its first years will be set by the willing capitals, not the complete 27.

The 2026–2027 work program earmarks €296m for a dedicated Ukraine Support Instrument, including joint filling plants, drone production, and a direct award to Ukraine’s Brave1 innovation fund.

The combat-tested systems Brave1 has put in the hands of Ukrainian frontline units are exactly what the new EU track is meant to scale. The integration logic is sound: Ukrainian battlefield innovation paired with European manufacturing depth.

The intellectual property side remains unresolved, however. Who owns what when an EU-funded Ukrainian design moves into a European production line? Until that is settled, this is a serious pilot, not a strategic transformation.

The downside scenario writes itself. Undersubscribed calls, procurement structures announced and never formed, and national programs running in parallel instead of through Brussels. Together, these would leave Europe’s defense-industrial base where it started: 27 national silos pretending to be one market.

The line item for drone protection in the work program was not a metaphor. It describes a real expectation that the factories Brussels is now subsidizing will, in their lifetime, be targets in a war Europe is not yet organized to fight.

The machines may arrive, the workers may be trained, and the shells may be made, but without the logistics to move them and the will to use them, factories will produce boxes, not battlefield effect.

The architecture has been built, and the calls are open, but, unfortunately, spending is not a strategy, and capacity is not capability.

A March 2026 Politico-Cluster17 survey of nearly 7,000 voters across six EU countries found 86% agree that Europe must develop its own defense capabilities, and 87% would accept higher economic costs for strategic self-reliance.

European electors understand what’s needed, and Brussels is introducing many sensible measures. What it can’t do, however, is force capitals to get moving. Nor can it ensure, if the factories are actually built, that Europe will know what to do with them.

Miro Sedlák is an Associate Research Fellow at the Institute for Central Europe and a security and defense studies doctoral candidate at the Armed Forces Academy of Gen. M. R. Štefánikin Slovakia.

Europe’s Edge is CEPA’s online journal covering critical topics on the foreign policy docket across Europe and North America. All opinions expressed on Europe’s Edge are those of the author alone and may not represent those of the institutions they represent or the Center for European Policy Analysis. CEPA maintains a strict intellectual independence policy across all its projects and publications.

Comprehensive Report

War Without End: Deterring Russia’s Shadow War

By Sam Greene, David Kagan, Mathieu Boulègue & more…

Either Europe will continue allowing Russia’s shadow war to set the terms of escalation, or it will act now to prevent a larger war.

March 31, 2026
Learn More
Europe's Edge
CEPA’s online journal covering critical topics on the foreign policy docket across Europe and North America.
Read More

The post Europe’s Defense Factories: More Urgency Please appeared first on CEPA.

Make Europe’s Defenses Great Again

2026-04-24 01:44:22

Europe is spending more on defense than at any point in its modern history. NATO’s European members have raised budgets, launched new procurement programs, and accelerated rearmament.

But the real question isn’t how much money is being spent, it’s whether that money is building real capability. Defense readiness does not come from budget execution alone; it comes from direction, speed, and technological superiority.

The geopolitical reality is sobering: The United States remains an indispensable ally, but it is no longer the automatic backbone of European security. Washington’s strategic focus is shifting, to put it mildly. The US defense industrial base is stretched, and some might say buckling.

Europeans must be able to secure their own continent to reinforce and reshape NATO. That requires European-owned intelligence, command‑and‑control and communications systems, a European air and missile defense architecture, resilient European cyber and space capabilities, and shared logistics, as well as ammunition production. Without these strategic enablers, Europe remains dependent, vulnerable, and politically exposed.

This is why Europeans in NATO must spend their money in a way that makes them strategically autonomous, industrially capable, and technologically leading. The goal of Europe First is a European pillar strong enough to carry its share of the burden and to do so with confidence.

The moment is unusually favorable: Europe can build a counterweight to US military power with American investors and American capital, because the demand for defense innovation, dual‑use technologies, and resilient supply chains is transatlantic. Strategic necessity and market logic point in the same direction.

Technology is the decisive factor. Modern warfare is software‑driven, networked, and brutally fast. The side that equips its frontline forces more rapidly with drones, AI, sensors, robotics, and digital communications wins.

Europe has the talent, the companies, and the research networks; what it lacks is a mechanism to turn innovation into deployable capability at speed. Today, procurement cycles often last longer than a full technology cycle. That is strategically reckless and economically wasteful.

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Europe needs an Innovation and Enabler Quota, starting now. At least 10% of all European defense procurement spending should be dedicated to disruptive technologies and to the strategic enablers that underpin European sovereignty. This quota should grow annually, reaching 30% by 2030.

These funds must support both sides of the equation: drones and autonomous systems, AI‑enabled command systems, hypersonic and deep‑strike capabilities, and, equally, satellite‑based intelligence and secure digital communications, integrated air defense, and shared European logistics and ammunition systems. Technology and enablers are inseparable. Together, they form the backbone of a sovereign European defense economy.

But innovation requires speed. That is why the Innovation and Enabler Quota must be executed through a fast‑track lane, a dedicated mechanism with its own agency, budget, and personnel.

It must operate outside the slow, traditional procurement rules that delay even basic acquisitions. Fast track means months instead of years, prototypes instead of PowerPoint, spiral development instead of monolithic mega‑projects, and close cooperation with start‑ups, scale‑ups, and civilian tech companies.

Europe can only lead technologically if it brings the pace of the civilian tech world into its defense sector.

A modern defense economy cannot be built by government ministries and bureaucracies alone; it requires a “Team Europe” approach, a strategic alliance of governments, armed forces, industry, finance, and research.

This approach lowers investment barriers, strengthens public acceptance of the defense sector, and keeps industrial value creation in Europe. Europeans must act as anchor investors in their own security, not as bystanders.

Europe will not become defense‑ready simply because it spends more money. It will become defense‑ready when it spends strategically on sovereignty, on technology, and on speed. 

Nico Lange is the founder and director of IRIS (Institute for Risk-Analysis and International Security) and a Senior Fellow at CEPA.

Europe’s Edge is CEPA’s online journal covering critical topics on the foreign policy docket across Europe and North America. All opinions expressed on Europe’s Edge are those of the author alone and may not represent those of the institutions they represent or the Center for European Policy Analysis. CEPA maintains a strict intellectual independence policy across all its projects and publications.

Comprehensive Report

War Without End: Deterring Russia’s Shadow War

By Sam Greene, David Kagan, Mathieu Boulègue & more…

Either Europe will continue allowing Russia’s shadow war to set the terms of escalation, or it will act now to prevent a larger war.

March 31, 2026
Learn More
Europe's Edge
CEPA’s online journal covering critical topics on the foreign policy docket across Europe and North America.
Read More

The post Make Europe’s Defenses Great Again appeared first on CEPA.

Dr. Kathleen Hicks, Ambassador Robert C. O’Brien, and Dr. Kiana Aran Join CEPA’s International Leadership Council

2026-04-24 00:00:00

Washington, DC, April 23, 2026 – Today, the Center for European Policy Analysis (CEPA) is pleased to announce that Dr. Kathleen Hicks, Ambassador Robert C. O’Brien, and Dr. Kiana Aran have joined the organization as the newest members of its International Leadership Council (ILC). 

Together, they bring decades of distinguished experience in national security, defense policy, and emerging technologies to CEPA’s high-level advisory group of global thought leaders and decision-makers, co-chaired by Annegret Kramp-Karrenbauer, former Minister of Defence of the Federal Republic of Germany, and H.R. McMaster, former US National Security Advisor and Lieutenant General (Ret.) in the United States Army. 

McMaster and Kramp-Karrenbauer said: “The addition of Dr. Hicks, Ambassador O’Brien, and Dr. Aran will help CEPA identify opportunities for transatlantic cooperation that extend beyond traditional defense to include the development and application of technologies critical to preserving peace and promoting prosperity.” 

CEPA’s President and CEO, Dr. Alina Polyakova, said: “We are honored to welcome three extraordinary leaders to CEPA’s International Leadership Council. Dr. Hicks and Ambassador O’Brien bring unparalleled experience at the highest levels of US national security, while Dr. Aran represents the cutting edge of biotechnology innovation that is increasingly central to transatlantic competitiveness. Together, they strengthen CEPA’s capacity to lead on the issues that matter most — from deterrence and defense to the strategic technologies shaping our future.” 

Dr. Kathleen Hicks served as the 35th United States Deputy Secretary of Defense and previously held other senior defense roles, including Principal Deputy Under Secretary of Defense for Policy and Deputy Under Secretary of Defense for Strategy, Plans, and Forces. She currently holds appointments at the Chicago Council on Global Affairs, the Harvard Kennedy School’s Belfer Center for Science and International Affairs, and Johns Hopkins University’s Kissinger Center for Global Affairs. 

Dr. Hicks said: “Effective deterrence and defense depend on the strength of the transatlantic bond. CEPA plays an essential role in forging that unity — bringing together the leaders, ideas, and strategies needed to meet the security challenges of this era. I look forward to contributing to that mission and am delighted to join CEPA’s Advisory Group to help guide its critical work on the future of technology and defense innovation.” 

Ambassador Robert C. O’Brien served as the 27th United States National Security Advisor and previously as the Special Presidential Envoy for Hostage Affairs with the personal rank of ambassador. He is the Co-founder and Chairman of American Global Strategies. 

Amb. O’Brien said: “I am delighted to join this group of leaders committed to allied security. I believe that the transatlantic alliance can return to being the cornerstone of global security, and work to strengthen that partnership has never been more vital. I am proud to join the International Leadership Council and to contribute to the effort to keep Europe and America united in the face of shared threats to Western security.” 

Dr. Kiana Aran is a globally recognized biotechnology innovator, entrepreneur, and professor at the University of California, San Diego. Her pioneering work at the intersection of biology and technology has earned international acclaim and established her as a leading force shaping the next generation of the biotech ecosystem. 

Dr. Aran said: “The race to lead in biotechnology and other critical technologies will be won or lost based on how well the United States and Europe work together. I am excited to join CEPA’s International Leadership Council and to help ensure that the transatlantic alliance remains at the forefront of innovation in an era of intensifying competition.” 

For media inquiries, please contact [email protected].

The post Dr. Kathleen Hicks, Ambassador Robert C. O’Brien, and Dr. Kiana Aran Join CEPA’s International Leadership Council appeared first on CEPA.

Orbán Lost But Populism is Still Winning

2026-04-23 21:53:44

Viktor Orbán has conceded defeat. Leaders from Brussels to Kyiv are celebrating. Sixteen years of institutional disruption: of blocked sanctions, strangled Ukraine aid, democratic backsliding conducted from inside the EU’s own walls, and a Budapest government that functioned, in practice, as Moscow’s most reliable asset inside the Western alliance. It has ended not in Brussels, but by Hungarian voters.

Ursula von der Leyen declared that Hungary had chosen Europe, and European officials exhaled.

They shouldn’t.

Orbán’s defeat is not a vindication. It is a window. One that is already closing.

What Orbán demonstrated is that a single government inside the EU can hold the entire Western alliance hostage. Not through military force. Through procedure. For years, and with increasing frequency, he used the EU’s own unanimity rules as a weapon, denying Europe the one thing that great power competition now demands above all else: the ability to act.

In the balmy days of the early 2010s, that was manageable. Now it’s not. Europe is no longer operating in a permissive international environment where strategic drift is affordable. An economic giant that cannot convert its weight into coherent strategic decisions is not a power that can counter Moscow’s aggression or even Washington’s contempt.

Europe must act as though Orbán won.

Across the continent, the structural conditions that enabled Orbán remain in place. And are deepening. Populist parties now lead opinion polls across Europe’s three largest economies. In Germany, the AfD has moved from a protest movement to the country’s dominant political force. In France, the National Rally has rebranded itself as the common-sense party of sovereignty. Across the Channel, Nigel Farage’s Reform leads the polls and is close to real political power.

And populists already in power, in countries like Slovakia and in Bulgaria, where a populist, Kremlin-friendly government has just won a majority, may pose a similar threat to joint decision-making.

Populism across the continent is deeply rooted in the erosion of prosperity that defined the post-war order and has radically accelerated since the financial crisis of 2007-8. Since 2000, 14 EU member states, including Germany, France, and Italy, have fallen in global GDP per capita rankings. Real income levels have declined, and the middle class has been squeezed across the majority of European countries.

Growth has occurred, but it is uneven. Four in five people across the OECD feel income disparities in their country are too large. Stagnant wages, intergenerational inequalities, and institutions that sometimes answer legitimate grievances with technocratic indifference have created the space that populists moved into. Traditional patriotism, anti-immigration sentiment, cultural conservatism, and anger at the decline of the “left behind” have boosted backing for populist parties, often hostile to the continent’s strategic unity. 

When prosperity erodes, and institutions don’t respond, the space for alternatives opens up. Vladimir Putin did not make Viktor Orbán, Robert Fico, or Nigel Farage. Nor is Orbán’s defeat a full repudiation of populism’s fundamentals. Péter Magyar, for example, shares some of Orbán’s nationalist analysis, while promising an end to corruption and overt obsequiousness toward Russia.

In the 12 months before Orbán’s defeat, Brussels had finally woken up to the strategic danger posed by its own governance, the legacy of a bygone geopolitical era. European capitals were forced to improvise to bypass Budapest, restructuring aid packages outside normal budget rules, recharacterizing defense spending to bypass unanimity requirements, and deploying obscure emergency legal mechanisms to unlock the funds Orbán was blocking. It worked. Just.

The EU must not pause the processes that Budapest forced upon it. Institutional improvisation will not work for a National Rally-led France or with a pro-Moscow AfD in power in Berlin.

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The Commission and leading member states should finally and decisively act on unanimity.

Firstly, Europe must end the veto trap in foreign and security policy. The requirement for unanimity on sanctions and critical security decisions was designed for a bloc of trusted trading partners; it has become a strategic vulnerability. As French President Emmanuel Macron’s decade-long push for a Sovereign Europe has emphasized, strategic paralysis is becoming the inevitable price of the national veto.

Mario Draghi’s 2024 report on European Competitiveness correctly framed this issue as an existential necessity: the EU cannot maintain its relevance in a world where adversaries act in hours while Brussels waits years for consensus. Moving to Qualified Majority Voting (QMV) for security decisions is now a strategic requirement. (This system requires 15 of the 27 members to agree on decisions, and together they must represent 65% of the bloc’s population.)

The mechanisms for change already exist. The EU can use the Passerelle Clause to extend Qualified Majority Voting into key areas of foreign and security policy, even if doing so requires initial unanimity, and shift the operational burden of sanctions to instruments such as those under Article 215 TFEU, which makes it harder for a single state to stall implementation. The point is simple: Europe already has the tools to reduce veto power, but under current political conditions, it has been unable to use them.

Secondly, complete what SAFE has started. Security Action for Europe has begun pooling defense procurement across member states, starting by mobilizing €150bn ($176bn) in joint loans. It is the most significant step towards European strategic autonomy in a generation. But any participating government can still block the deployment of jointly procured assets under the same rules that gave Orbán his veto. This also should be removed. Europe’s military capacity must be developed as a unified instrument and not a 27-way debate.

Third, Hungary and Article 7. The European Union’s ultimate disciplinary tool is designed to strip a member state of its voting rights if it violates the Union’s core values of democracy and the rule of law. A file was opened in 2018 on Orbán’s government, which stalled it by exploiting a pact with other populist governments, most notably in Poland. Brussels must not only force a conclusion of the current process with Magyar, but use this momentum to move the determination of a breach to Qualified Majority Voting as proposed by the European Parliament three years ago.

Finally, the EU should vigorously enforce breaches of Article 4(3) of the EU Treaties, which obligates member states to demonstrate “sincere cooperation”. Steps are being taken in this direction, with the Commission’s proposal for the next long-term budget strengthening the link between access to EU funds and compliance with common obligations.

Paris, not Budapest, is Europe’s real test.

This moment is now less than 12 months away. France goes to the polls for its presidential election, and the National Rally, with its long-term ties to Moscow, under either Jordan Bardella or Marine Le Pen, will make its most serious bid for the Elysée yet. The structural conditions, economic stagnation, migrant anxiety, and institutional distrust are more favorable to the French populist right than at any point in the Fifth Republic’s history.

If Brussels has not completed QMV reform, tightened its rule-of-law, and anchored a unified European defense procurement structure before that election, it may face the same vulnerabilities it faced with Orbán, but at the scale of France, a founding member, a nuclear weapons power, and a permanent member of the UN Security Council.

The Kremlin has not been sitting idly waiting for a European fracture. It is openly pursued through the continent’s populist parties.

Under current structures. Any captured capital will suffice. 

In that world, the inability to act is not an administrative inconvenience. It is an invitation.

Maksym Beznosiuk is a strategy and security analyst and writer whose work focuses on Russia, Ukraine, and international security. He is an Associate Fellow at GLOBSEC.

William Dixon is a Senior Associate Fellow of the Royal United Services Institute and an Associate Fellow at GLOBSEC. He specializes in cyber and international security issues. 

Europe’s Edge is CEPA’s online journal covering critical topics on the foreign policy docket across Europe and North America. All opinions expressed on Europe’s Edge are those of the author alone and may not represent those of the institutions they represent or the Center for European Policy Analysis. CEPA maintains a strict intellectual independence policy across all its projects and publications.

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The post Orbán Lost But Populism is Still Winning appeared first on CEPA.

Mapping the Spread of Child Safety Rules

2026-04-23 02:00:00

Introduction

Since Australia introduced a social media ban for under-16s in late 2025, governments around the world have begun enacting or considering strict age verification requirements or age limits for children.

Online child safety represents a common concern. But bans or restrictions generate heated debate.

Supporters contend they are needed to protect children from dangerous abuse. Young people online can be exposed to bullying, adult content, hate speech, and grooming or other exploitative and abusive behaviors. In Europe, 75% of surveyed citizens agree that governments should set minimum ages for social media. In the US, juries have found social media companies liable for harming young users with addictive design features that contributed to mental health distress.

Critics counter that the bans threaten freedom of expression and privacy and are ineffective at protecting youth. In March 2026, 371 privacy and security experts released an open letter raising concerns over how to enforce social media bans effectively and securely. UNICEF argues that social media can help young people access their rights — including to self-expression, privacy, and access to information — and advocates for safety by design and digital literacy.

Australian eSafety Commission Julie Inman Grant conceded that the country’s social media age restriction has been difficult to enforce and has yet to result in decreased harm — or in keeping kids offline.

Around the globe, governments are taking different approaches. Some are introducing mandatory age verification systems. Others are strengthening parental consent and control. Others focus, instead, on digital literacy programs or enforcing rules targeting specific platforms.

In order to chart the debate, CEPA has created a map to help situate the steps a range of countries — and the EU — are taking in the effort to address this challenge.

*This information is not exhaustive, but a representative selection of cases in a highly dynamic policy context.

Countries

Africa

Egypt

Egypt’s House of Representatives has announced plans to draft legislation restricting young people’s social media use. In a context in which the Internet is heavily controlled, President Abdel-Fattah el-Sissi speaks about social media age restrictions as a way to combat “digital chaos.” Whether the legislation will include an age restriction — or when the legislation will be introduced — remains unknown.

Kenya

Kenya’s Communications Authority released child safety guidelines last year encouraging mobile operators, broadcasters, and app and content providers to impose age restrictions. At the same time, the guidelines also emphasize the importance of children’s right to access information and freely express themselves.

South Africa

Some sources have reported that government officials are considering restricting access to major platforms such as TikTok and Instagram, but there have yet to be any formal announcements or legislative proposals.

Americas

Brazil

Brazil enacted the Digital Statute of the Child and Adolescent in September 2025. It requires social media companies to set up parental controls and age verification techniques to ensure that under-18s cannot access inappropriate content. The law blocks tech firms from using minors’ data for targeted advertising, but does not establish a social media age limit. It took effect in March 2026.

Canada

Canadian officials are considering a social media ban for under-14s, but no legislation has been passed or introduced. Canada passed a law in 2025 making it illegal to make pornographic material available to anyone under 18.

Ecuador

Ecuador’s National Assembly is considering a proposal to ban social media for children under 15. The proposal, introduced by ruling party legislator Katherine Pacheco in February 2026, would fine non-compliant platforms up to 5% of their local annual revenue. Exceptions would apply to educational platforms and certified child-safe versions with parental controls.

Trinidad and Tobago

Prime Minister Kamla Persad-Bissessar said the government is considering limiting social media access for young people under 12 years old. The announcement came after Roman Catholic Archbishop Charles Jason Gordon called for laws to protect children online.

United States of America

Although no federal legislation restricting social media access exists, Members of Congress have introduced several bills. For instance, the Kids Online Safety Act would require platforms to strengthen privacy settings for children and provide under-18s with additional safety and wellbeing options. The Kids Off Social Media Act would limit children under 13 from creating social media accounts.

Several states have put forward legislation. In February 2026, California Governor Gavin Newsom spoke in favor of restricting social media use for under-16s, and a bipartisan group of California lawmakers introduced legislation calling for a minimum age to create a social media account. In Virginia, a new law took effect on January 1, 2026, that requires social media platforms to verify that users are at least 16 years old and limit under-16s to one hour of social media use per day

In mid-2025, Nebraska Governor Jim Pillen signed a package of bills aimed at protecting children’s personal information online, giving parents greater control over account settings, and requiring social media design features to be made less addictive. Starting in the middle of 2026, under-18s will require parental consent to create a social media account.

Florida Governor Ron DeSantis signed into law a prohibition on under-14s creating social media accounts on most platforms. In Utah, the Minor Protection in Social Media Act is held up in court. A Texas law seeking to require app stores to verify users’ ages and require parental consent for app purchases was blocked by a federal judge in late 2025. A similar rule was signed into law by Alabama Governor Kay Ivey this month.

Social media companies are also facing lawsuits about child safety. In March 2026, a California jury found Meta and YouTube negligent in their deliberate design of addictive platforms for children, and another in New Mexico ruled that Meta failed to protect children from sexual exploitation. TikTok and Snap settled before the California trial. More than 40 state attorneys general have filed similar lawsuits against Meta, and a federal trial representing school districts is set to begin in June of this year.

Asia

China

China launched its “minor mode” setting last year, which increases parental control over their children’s online activities. Minor mode includes recommended usage limits by age, blocks non-essential apps between 10:00 p.m. and 6:00 a.m., and issues reminders to take a break from the device every 30 minutes. Minor mode also includes the option to block messages from strangers or specific users and allows parents to customize the default restrictions.

China requires platforms to recommend age-appropriate content and implement content filters for children. The Chinese authorities already heavily censor the Internet, so child safety efforts in China are pursued in this restrictive context.

India

Indian officials are debating a social media ban for children under 16. The Ministry of Finance’s annual Economic Survey included social media age restrictions as an area of concern. In mid-February 2026, Indian Technology Minister Ashwini Vaishnaw confirmed that the government is having conversations with tech companies about age-related social media restrictions.

Several Indian states are considering action. In Andhra Pradesh, Chief Minister N. Chandrababu Naidu stated that a rule banning children under 13 from accessing social media will be introduced in the next 90 days. Goan Tourism and IT Minister Rohan Khaunte announced that the state is looking into the feasibility of a social media ban. In Karnataka, Chief Minister Siddaramaiah spoke about a social media ban for children under 16 — although no details about enforcement were provided.

Indonesia

Starting in March 2026, the Indonesian government has restricted children under 16 from accessing social media. The limitations do not represent a complete ban; restrictions depend on specific platforms’ level of risk. Children under-16 can no longer use YouTube, TikTok, Facebook, Instagram, Threads, X, Roblox, or livestreaming platform Bigo Live — all deemed high-risk by the government. Low-risk platforms are accessible to children aged 13 and up. Platforms will be required to gradually comply starting on March 28, 2026.

Kazakhstan

Kazakhstan, which has a tightly controlled Internet, is considering a proposed amendment that would ban under-16s from creating social media accounts, except for messenger apps. The amendment has not yet become law.

Malaysia

Malaysia’s Online Safety Act, passed in 2025, bans youth under 16 years old from creating social media accounts.

Pakistan

Senators Syed Masroor Ahsan and Sarmad Ali introduced legislation in 2025 that would prohibit under-16s from using social media. After significant pushback, the senators withdrew the bill and promised revisions, including lowering the minimum age to 13 or 14. A new bill has not yet been proposed.

The Philippines

The government has introduced a bill blocking under-18s from using social media and requiring platforms to verify users’ ages. But it has yet to become law.

Singapore

Singapore’s Infocomm Media Development Authority released a new code of practice in 2025 requiring app stores to implement age verification systems before users can download apps meant for adults, such as dating apps. The code applies to Apple, Google, Huawei, Samsung, and Microsoft’s app stores. Google has announced several age verification measures that apply across the company’s products, including YouTube. Instagram has restricted features for those under 18. 

Tajikistan

Dilnoza Ahmadzoda, an MP in Tajikistan, introduced a proposal to ban social media access for under-14s in late 2025. The Internet in Tajikistan is already heavily censored, and many media outlets and social media platforms are blocked in the country.

United Arab Emirates

The UAE’s Child Digital Safety Law requires platforms to implement age verification systems that differ based on the platform’s level of risk and potential impact on children. Platforms have until January 1, 2027, to comply.

Vietnam

Vietnam’s Internet is heavily censored. Vietnam began requiring parents in 2024 to register their under-16’s social media accounts and supervise what they share online. In early 2026, Vietnam’s ruling party issued a directive that requires social media firms to implement identity checks and age restrictions for minors.

Europe

Austria

Austria agreed on a social media ban for under-14s in March 2026. The government expects to have a draft proposal in June 2026.

Belgium

After the country’s Superior Health Council released a report in December 2025 on the impact of social media on young people’s wellbeing, Belgium announced it would consider implementing social media age restrictions. At the same time, the Belgian government declined to sign a declaration of support for a “digital age of majority” in late 2025. All other European Union countries signed, except for Estonia.

Bulgaria

Bulgaria does not have legislation establishing a minimum age for social media access, but will be required to comply with EU regulation.

Croatia

Croatia does not have legislation establishing a minimum age for social media access but will be required to comply with EU regulation.

Cyprus

Cyprus does not have legislation establishing a minimum age for social media access but will be required to comply with EU regulation.

Czech Republic

Czech Prime Minister Andrej Babiš and Vice Prime Minister Karel Havlíček have both spoken in favor of a proposed social media ban for under-15s.

Denmark

Danish Prime Minister Mette Frederiksen spoke in favor of the social media ban for under-15s in late 2025. If the proposed agreement is adopted, parents would be able to override the rule and allow children between 13 and 15 to have a social media account. The plan could become law as soon as mid-2026.

Estonia

Estonia has pushed back on the EU’s plans to restrict young people’s social media access. It declined to sign a declaration of support for a “digital age of majority.” Instead, the government promotes digital education for young people.

European Union

The European Parliament approved a resolution in 2025 by a 483-92 vote recommending a minimum age of 16 for social media use. Parents would be free to give consent to their children between 13 and 15 to access social media. But the resolution is non-binding.

The European Commission has also released guidelines for online child protection under the Digital Services Act. Among other measures, the guidelines call for modifying recommendation algorithms and setting minors’ accounts to private automatically. It is also piloting an age verification mechanism in several member states.

European Commission President Ursula von der Leyen has appointed an expert group to advise on whether to ban social media for children, with the aim of coming up with recommendations by summer 2026.

In March 2026, the European Parliament failed to renew a temporary law allowing social media companies to scan content on their platforms for child sexual abuse material over data privacy concerns.

Finland

Finland’s Prime Minister Petteri Orpo has spoken out in favor of a social media ban for young people under 15, but legislation has yet to be proposed.

France

The French National Assembly passed a bill in 2026 to ban social media for under-15s by a vote of 130-21. The Senate is expected to vote on the bill and — if passed — enforcement is planned for September 2026. At the AI Impact Summit in New Delhi in February 2026, President Emmanuel Macron threw his support behind the proposal and referred to the group of countries planning to implement social media bans as a “new ‘coalition of the willing.’”

Germany

Members of German Chancellor Friedrich Merz’s party have spoken in favor of a social media ban for under-16s, but no draft bills have been proposed.

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Greece

In April, Greece proposed a draft bill to prohibit under-15s from using social media. If passed, it will come into effect in January 2027. The Ministry of Digital Governance would use the state-built Kids Wallet app, introduced last year, to enforce the ban.

Hungary

Hungary does not have legislation establishing a minimum age for social media access but will be required to comply with EU regulation.

Iceland

Iceland’s Minister of Education and Children, Inga Sæland, supports a social media age limit of 15 and has said that legislative proposals are at the “drawing board stage.” Former deputy MP Skúli Bragi Geirdal submitted a resolution to establish a social media age requirement of 15 or 16 in late 2025, but the resolution did not become law. Iceland signed an EU declaration in support of a “digital age of majority.”

Ireland

Ireland’s Minister for Communications, Patrick O’Donovan, intends to propose a new social media age verification system and said children’s online safety will be a focus of Ireland’s EU Presidency, which will begin in July 2026.

Italy

The Italian government has introduced a bill that would restrict social media use for children under 15, including restrictions on child influencers. A 2018 law requires under-14s to have parental consent to access social media. A class action lawsuit filed by the Italian Parents’ Movement (MOIGE) aims to limit social media use by children under 14 and force the platforms to strengthen age-verification policies.

Latvia

Latvia does not have legislation establishing a minimum age for social media access but will be required to comply with EU regulation.

Liechtenstein

Liechtenstein does not have legislation establishing a minimum age for social media access but may be required to comply with EU regulation as a member of the European Economic Area.

Lithuania

Lithuania does not have legislation establishing a minimum age for social media access but will be required to comply with EU regulation.

Luxembourg

The Luxembourg parliament debated a social media age restriction in late January 2026, but the government would prefer EU-wide rules. Luxembourg’s Justice Minister, Elisabeth Margue, said that the country may move forward with national policy if the EU fails to act.

Malta

Malta’s Prime Minister, Robert Abela, announced that under-13s will soon be subject to social media restrictions. The soon-to-be-introduced regulations may later be extended to older age groups.

Montenegro

Two parliament members introduced a bill to ban social media use for children under 13 and to require parental consent for children between 13 and 16. The bill would also ban sexualized and deep-fake content featuring children.

Netherlands

The Dutch government is pushing to raise the minimum social media age to 15 across Europe, but the country does not have its own age restriction law.

Norway

Norway is holding a public consultation to gather feedback on a potential new law to prohibit social media access for under-15s. Norway signed a declaration in support of a “digital age of majority,” along with most EU countries.

Poland

Poland’s governing Civic Coalition is drafting a law to ban social media for under-15s. Poland plans to update its mObywatel digital ID app to allow for age verification that would enable social media age restrictions.

Portugal

Portugal has proposed legislation that would require parental permission for under-16s to use social media.

Romania

Romania’s Digital Adulthood Law, approved by the Senate and still under consideration by the Chamber of Deputies, would prohibit children under 16 from accessing social media without parental consent. If passed, parents will also be empowered to suspend their children’s accounts.

Russia

Russian parliamentarian Andrei Svintsov’s call for restricting social media for under-14s received little support, and Anton Gorelkin, first deputy chairman of Russia’s State Duma information policy committee, said parliament is not developing a social media ban for children.

Russia’s information environment is heavily censored, and the government has banned or restricted platforms such as Roblox, Snapchat, Facebook, Instagram, WhatsApp, and YouTube.

Slovakia

Slovakia does not have legislation establishing a minimum age for social media access but will be required to comply with EU regulation.

Slovenia

The government is drafting legislation to ban children under-15 years old from using social media.

Spain

Spain’s Prime Minister Pedro Sanchez plans to prohibit social media use for children under 16 years of age.

Sweden

Sweden does not have legislation establishing a minimum age for social media access but will be required to comply with EU regulation.

Switzerland

After Australia’s age restrictions took effect, Swiss officials began considering a similar ban. But the Swiss Federal Commission for Children and Youth Affairs came out against the ban, arguing it could violate the UN Convention on the Rights of the Child to access information and education.

Turkey

Turkey’s ruling party submitted a draft law limiting social media access for under-15s in the wake of a parliamentary report recommending age restrictions.

United Kingdom

The UK’s 2023 Online Safety Act obliges websites that host adult content to conduct age verification of users. In addition, the UK government opened a consultation to explore a social media ban for young people under-16. Some 60 Labour MPs have signed an open letter advocating for the legislation.

Oceania

Australia

Australia became the first country to implement a comprehensive social media ban in December 2025. The Online Safety Amendment Bill blocks under-16s from making accounts on social media apps, including TikTok, Instagram, YouTube, Snapchat, X, and Facebook. Under-16s who already have social media accounts are not permitted to keep them. Parents cannot overrule the ban. Since coming into force, social media companies have deactivated more than 4.5 million accounts. Tech companies that fail to comply face fines and penalties.

Fiji

While some Fijian officials have spoken about adopting a law similar to Australia’s under-16 ban, no draft legislation has been proposed.

New Zealand

New Zealand’s government introduced a bill to restrict social media access for under-16s in late 2025, modeled on Australia’s. But the bill is still being debated and has not yet become law.

Jenna Presta is the Senior Program Officer for the Tech Policy Program at the Center for European Policy Analysis.

Maria-Doriana Gheorghe and Victoria Paketci provided research. Maria-Doriana and Victoria are both interns with the Tech Policy Program. Victoria is a master’s student at Georgetown University, and Maria-Doriana is completing a master’s in international governance and diplomacy at Sciences Po in Paris.

Bandwidth is CEPA’s online journal dedicated to advancing transatlantic cooperation on tech policy. All opinions expressed on Bandwidth are those of the author alone and may not represent those of the institutions they represent or the Center for European Policy Analysis. CEPA maintains a strict intellectual independence policy across all its projects and publications.

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