Restrictive measures: the challenges in front of the EU. Report on schemes employed to circumvent sanctions.

While international sanctions are frequently debated in terms of their political effectiveness, less attention is given to the mechanisms that support their enforcement. In the current European context, economic operators are required to prevent goods, funds, and services from reaching sanctioned entities or states. However, this responsibility is challenged by the elusive and adaptive nature of sanctions evasion, which often involves complex corporate structures, offshore entities, and opaque ownership arrangements. With enforcement still in its early stages for many operators, understanding of evasion tactics remains limited. The private sector has increasingly called for greater transparency, clearer guidance, and real-world examples to support the development of effective compliance measures. Responding to this gap, the report offers one of the first overviews of sanctions circumvention cases under investigation by law enforcement authorities, highlighting their main features and the need for more robust enforcement practices.