Phoenix 24
An instrument never used before hangs in the balance: it could penalize entire countries accused of helping Moscow sidestep sanctions.
Copenhagen, August 2025
For nearly two years, the European Union has kept in reserve a last-resort option designed to target states that facilitate the circumvention of sanctions imposed on Russia. Known as the Anti-Circumvention Tool, it has remained dormant until now. At the informal gathering of EU defense ministers in Copenhagen, the issue resurfaced with unusual force. After eighteen rounds of unprecedented sanctions, the pressure to escalate has put this mechanism firmly back on the table.
According to internal Council papers, the tool could be applied to strategic sectors such as oil, gas, finance, cryptocurrencies, and the Russian shadow fleet used to evade price caps. These sectors are widely considered pillars of the Kremlin’s war economy, and sanctioning their facilitators would carry significant diplomatic consequences.
The measure, however, requires unanimous approval from all twenty-seven member states, which is itself a difficult hurdle. Evidence of circumvention involving countries with cordial ties to Moscow has been mounting, with attention focused on China, India, the United Arab Emirates, Turkey, Uzbekistan, and Vietnam. Turning the mechanism against entire states would mean entering uncharted territory in European diplomacy, where retaliation and unintended repercussions cannot be excluded.
The Anti-Circumvention Tool was created in 2023 as leverage for extreme cases, but it has never been prioritized. That calculation is shifting as Russia intensifies its strikes and as European infrastructure and political cohesion come under greater strain. What once seemed theoretical now appears increasingly plausible.
The Danish presidency of the Council circulated a four-page discussion paper outlining possible applications. The very existence of this document shows how seriously the matter is being considered. High Representative Kaja Kallas, on arrival at the meeting, emphasized that “pressure is the only thing that works” in containing Moscow, a remark that reflects the mood of hawkish capitals calling for tougher action.
Sanctions have already reached historic proportions. Since the beginning of the war, the EU has imposed restrictions covering technology exports, energy flows, banking access, aviation, shipping, and luxury goods. Even so, loopholes remain. Officials admit that enforcement has often lagged behind ambition, and the Anti-Circumvention Tool was conceived precisely to close systemic gaps.
Should it be activated, the EU would be signaling readiness to move beyond traditional listings of individuals and companies, extending coercion to states accused of undermining the sanctions regime. The implications would be far-reaching. Beyond economic disruption, such a move would represent a major escalation of the Union’s willingness to use sanctions as geopolitical leverage.
Outside Europe, the debate is watched with caution. In Washington, policymakers see possible activation as a sign of renewed transatlantic unity. In Asia, by contrast, the idea raises concerns about energy markets and supply chains. For countries identified as potential targets, the step would crystallize tensions that so far have been contained through diplomatic ambiguity.
The stakes are high. Some member states argue that deploying the tool would strengthen the credibility of sanctions and prevent Russia from rebuilding its war machine. Others warn that the cost of confronting large economies or key trading partners could harm European interests elsewhere. The unanimity rule means each capital has veto power, ensuring consensus will not come easily.
If the tool is activated, it could mark a decisive shift by deterring pro-Kremlin behavior and reinforcing the integrity of Europe’s sanctions framework. Conversely, a breakdown in consensus could paralyze the initiative and expose the limits of EU cohesion. In a bifurcation scenario, U.S. pressure to expand similar mechanisms worldwide could redefine the reach of secondary sanctions far beyond Europe.
Facts that do not bend.
Hechos que no se doblan.