Is the EU’s Global Human Rights Sanctions Regime (GHRSR) as effective as it could be? Although sanctions have become the EU’s go-to policy tool, they often miss the mark in achieving what they set out to. With a primary focus on Russia, attention has slipped away from other regions of concern. The EU’s human rights sanctions, while an important signal, lack strategic targeting and should be reassessed if the EU hopes to seriously mitigate human rights violations around the globe.

The EU marked three years of its Global Human Rights Sanctions Regime (GHRSR) in December 2023. The union has increasingly relied on sanctions to achieve its goals under its Common Foreign and Security Policy, and there is even a prevailing perception that sanctions have become the go-to policy option instead of a tool of last resort. But in the field of democracy support, the EU’s use of restrictive measures has not been widespread and has lacked a strategic vision. Most EU sanctions in the last three years have related to a single case, Russia, which accounts for two-thirds of all measures under the GHRSR. This is in marked contrast to the few measures adopted to counter democratic backsliding in other parts of the world.

The EU has been reluctant to impose sanctions on individuals or entities from strategic partners or friendly countries and has not always targeted those with the most assets to freeze in the EU. As a regional and emerging global leader in the use of sanctions, the EU needs to revise its approach and become more assertive by accompanying its democracy policies with tools that can make a real difference.

In the two years since Russia’s full-scale invasion of Ukraine, sanctions have been the most notable part of the EU’s response to the war. However, this approach has been accompanied by calls from civil society and lawmakers for the EU to deploy even more sanctions. Yet, the key question is not whether the total number of sanctioned entities is large enough but whether sanctions are effective in relation to the EU’s policy goals and political objectives. EU member states have now agreed to keep the GHRSR in place until at least December 2026; over this period, the EU needs to do more to use its sanctions effectively, consistently, and strategically.

The evolution of EU human rights sanctions

After some initial reluctance, in December 2020 the EU followed like-minded partners in the US, Canada, and the UK and adopted the GHRSR, also known as Magnitsky sanctions after the 2016 US Global Magnitsky Act. At the time, the EU announced that it would use the GHRSR against states and non-state actors for serious human rights violations and abuses worldwide, no matter where they occurred. Putting human rights at the centre of EU foreign policy and deploying all available policy instruments to protect and promote human rights are steps consistent with the EU’s treaties and its 2012 Strategic Framework and Action Plan on Human Rights and Democracy.

In recent years, the number of EU sanctions has increased in parallel to the rise in conflicts and human rights violations in many countries. In 2023 and 2024, for example, the EU adopted new measures against Guatemala, Haiti, Moldova, Niger, and Sudan. More generally, sanctions have evolved over the last decade from a purely geographic instrument to a mix of country-specific and so-called horizontal measures, with different frameworks that focus on human rights, cybersecurity, and chemical weapons. Horizontal sanctions enable the EU to impose restrictive measures on offenders irrespective of their country of origin and the place in which they violate human rights or international law. The GHRSR is one of these horizontal regimes, which allow the EU to act in a way that is supposedly politically less sensitive.

When the GHRSR was adopted, there was no shortage of sceptics who argued that the framework offered no added value for the EU. The union is already the second most active imposer of sanctions globally, with more than 40 country-specific sets of sanctions, at least 17 of which have human rights or democracy as their main component. Yet, with a dedicated sanctions regime for human rights, there is now an increased expectation that the EU will use the framework strategically and with a whole-of-government approach.

After a slow start in 2021 and no new measures in 2022, the EU made more use of the GHRSR in 2023, when it prioritised specific thematic areas, such as gender-based and sexual violence. Analyses of the EU’s implementation of the GHRSR have focused on various aspects of the regime, such as its engagement with civil society organisations (CSOs), the specific human rights violations mentioned in EU public statements, and the EU’s championing of gender-based rights.

The EU has been at the forefront of protecting gender-based rights by using the GHRSR to identify those who isolate women and girls by depriving them of access to education or justice, or who use sexual violence as a weapon of war. The EU has also been one of the first jurisdictions to deploy sanctions against the use of facial-recognition technology by Russia’s repressive government to crack down on dissent. While these uses of the framework are welcome, the EU’s ability to replicate this type of measure in other countries will provide a test of how strategically the EU uses its human rights sanctions.

Another indicator of the EU’s successful and strategic use of sanctions is its ability to identify and target networks that support repression, human rights violations, or corruption. The US government has used its Global Magnitsky Sanctions Programme, through which it has focused most of its anti-corruption efforts, to target large corrupt networks. A deep understanding of the political economy of a given country or context is crucial for making well-informed and impactful policy choices. Such a comprehensive approach will help the EU to scale up the impact of its policies.

The role of sanctions in protecting human rights

Although sanctions might seem to have become the EU’s go-to policy tool, an evaluation of the GHRSR to date shows that the regime falls short as a strategic instrument. The EU has overwhelmingly focused its use of the GHRSR on one country – Russia – where it lacks complementary policy instruments. Following Russia’s 2014 annexation of Crimea, the EU suspended high-level political and human rights dialogues with Moscow. After Russia’s 2022 invasion of Ukraine, the EU suspended all policy dialogues with and funding for Russia and massively curtailed its trade with the country. Sanctioning Russian individuals and entities almost seems like a convenience in the current geopolitical context.

Sanctions are best used when combined strategically with other instruments as part of a broad policy toolbox. Sanctions also have a rhetorical value in accompanying public condemnations of human rights violations by highlighting the consequences of the perpetrators’ actions and showing support for human rights defenders and affected communities.

The 93 sanctions issued under the GHRSR to date comprise 72 individuals and 21 entities from 12 countries (see figure 1). Of these measures, two-thirds have targeted individuals or entities that come from or have a link to Russia. In the absence of an EU country-specific sanctions regime to address human rights violations committed by Russia, the GHRSR framework has come in handy. At the same time, it seems short-sighted and lacking in strategic thinking to use this instrument to focus so overwhelmingly on one country.

Figure 1: Total number of sanctions under the GHRSR by country

Source: Author’s analysis based on EU restrictive measures issued from 2021 to 2024.

In regional terms, the EU has not used the GHRSR at all in Latin America and has used it very sparingly in other regions, with the fewest sanctions imposed on countries in the Middle East and North Africa, followed by Africa and the Asia-Pacific (see figure 2). Within Eastern Europe and Central Asia, the EU’s choice to focus heavily on Russia while overlooking the rest of the region, which has a very poor record of protecting human rights, seems unbalanced. An exception in this regard is Belarus, for which the EU has had a dedicated human rights sanctions framework since 2006. After the country’s fraudulent 2020 presidential election and subsequent crackdown on dissent, the EU added several hundred Belarusian entities and individuals to this list.

Figure 2: Regional breakdown of sanctions under the GHRSR

Source: Author’s analysis based on EU restrictive measures issued from 2021 to 2024.

Since the GHRSR was launched, serious human rights violations have been on the rise in many parts of the world. In 2023, Freedom House marked the 17th consecutive year of a global decline in freedom. Meanwhile, locally affected communities, CSOs, and parliamentarians have called on the EU to use its sanctions framework to respond to this uptick in serious human rights abuses.

Can sanctions be detached from politics?

The EU’s selective use of sanctions in response to human rights violations and democratic backsliding leaves the GHRSR vulnerable to familiar accusations of double standards. Sanctions are widely perceived as one of the EU’s most consequential policy instruments, and in the absence of accountability or justice mechanisms in the countries concerned, the EU needs to ensure that it deploys its sanctions with rigour and flexibility.

The horizontal nature of the GHRSR alleviates some concerns about politicised decision-making on sanctions. Unlike traditional country-specific measures, where decisions are driven by EU member states, horizontal sanctions are based on centralised decision-making between the EU Council and the EU foreign policy high representative. This approach should ease tensions over sensitive sanctions and ensure more geographic coverage.

Sanctions can have severe consequences on those targeted, not least because being on a sanctions list affects an individual’s financial situation. It is also politically and economically stigmatising for those who wish to access international financial markets or high-level politics. In the Democratic Republic of the Congo and South Africa, for example, US sanctions resulted in senior politicians leaving office and contributed to a loss of political influence for those sanctioned.

However, an analysis of the level of seniority of those sanctioned under the GHRSR raises questions about whether the EU has used the regime to its full potential and what the EU’s strategic calculus is when using this instrument. Of all the individuals the EU has sanctioned to date, 58% were mid-ranking officials below the level of deputy minister and only 36% were high-level officials, including ministers, deputy ministers, prison directors, and prosecutors general (see figure 3). The EU should deploy its sanctions with economic considerations in mind, such as whether the individuals targeted have assets or economic interests in the EU.

Figure 3: Seniority of individuals sanctioned under the GHRSR

Source: Author’s analysis based on EU restrictive measures issued from 2021 to 2024.

Whether any of the individuals sanctioned under the GHRSR have such assets is not publicly known. Remarkably, the only EU sanctions framework for which there is public information about frozen assets is the set of sanctions against Russian individuals and entities involved in undermining Ukraine’s territorial integrity. Tracing and publishing assets frozen across the EU under the GHRSR would increase transparency and make the tool more impactful.

With draft EU legislation to harmonise the criminalisation of sanctions evasion in the works, the union has a real potential not only to enforce its sanctions more effectively but also to use the proceeds of some frozen assets for reparations in affected communities. By carefully targeting perpetrators who may hold assets in the EU and understanding the operations of such individuals’ supporting networks, the EU could make its use of the GHRSR more effective.

The EU is not the only jurisdiction that suffers from blind spots in its use of sanctions. The US, for example, has not used its Global Magnitsky Sanctions Programme vis-à-vis countries it lists among its security partners.

Towards a more strategic EU sanctions regime

In December 2023, EU member states renewed the GHRSR for another three years, and it is likely to stay for much longer. The EU will need to maintain its credibility when using sanctions for human rights protection and become more assertive in deploying its full range of foreign policy tools.

There is wide scope for the EU to make better use of sanctions to support its human rights policies globally. The EU needs to be more strategic in its deployment of the GHRSR in places where sanctions can complement other policy instruments; where sanctions could be a real tool of last resort, even with strategic partners; and where the EU can use leverage to achieve progress in protecting human rights.

In reviewing the GHRSR, four key issues stand out that warrant the EU’s attention: impartiality, impact, networks, and coordination.

Firstly, in using sanctions to deter human rights violations and condemn serious acts of misconduct, the EU should deploy the GHRSR with flexibility and rigour and without fear or favour. Serious human rights abuses should not go unnoticed but should receive equal condemnation irrespective of the EU’s strategic relationships with the countries concerned. Ties such as energy, trade, or transport links should not prevent the EU from using its most powerful instrument to protect human rights. It is in the EU’s strategic interest to conduct business with countries that adhere to international human rights standards.

Secondly, the EU should draw clearer lines and become more assertive in its strategic use of the GHRSR. While the EU should not underestimate how important it is for victims of human rights violations to see sanctions used symbolically against the perpetrators, the EU should act strategically to identify the targets where its sanctions will have the most effect economically, politically, or diplomatically.

Thirdly, the EU should identify patronage networks and proactively share information about the assets that have been frozen in the EU. These are further crucial steps towards making the GHRSR a more strategic policy tool.

Finally, the EU’s continued coordination with like-minded partners in the US, the UK, Canada, and Australia will add to the strategic use of this framework. Joint condemnation of serious human rights violations sends a more powerful signal than separate declarations; but more importantly, freezing assets in coordination with other key economies will have a more detrimental effect on the perpetrators of human rights abuses.


Tinatin Tsertsvadze is the Associate Director at the Open Society Foundations. She is responsible for EU sanctions policies, and also has thematic expertise human rights, civil society space, Eastern Europe and Central Asia. Prior to joining Open Society, she worked for the International Partnership for Human Rights, focusing on Eastern Europe, Russia and Central Asia as an Advocacy Director and Gender Adviser for five years. She worked at FRIDE, between 2010 – 2014, as Central Asia programme manager and conducted research and advocacy on EU policies towards Central Asia and the South Caucasus. She co-managed 50-member network of Brussels-based HRDN network between 2016-2019. Prior to that Tinatin worked for the European Socialist Party, assisting in the 2009 European Parliament Election campaign. She also served one year as the Brussels director for European Institutions at AEGEE. She has a master’s degree in public administration (specialising in European Studies) from the Georgian University.


This publication was produced with the financial support of the European Union. Its contents are the sole responsibility of the authors and do not necessarily reflect the views of the European Union.