EU restrictive measures against natural and legal persons: from counterterrorist to third country sanctions

The use of targeted sanctions has dramatically increased. The EU runs 29 different sanctions regimes, mainly geographically defined but also including two counterterrorist regimes. These measures are under great judicial pressure: more than 250 natural and legal persons have challenged their listings. In several high profile cases, the EU courts struck down sanctions based on UN lists, autonomous EU sanctions, counterterrorist sanctions and sanctions against third country regimes, triggering significant reforms in EU listing procedures. This article sets out the different regimes and addresses questions such as: what standard of judicial review should the EU courts apply? What is the relevance of the case law on counterterrorist sanctions for third country sanctions? Can the EU courts acknowledge procedural improvements in the UN context? Are EU sanctions preventive measures? Are they suitable to achieve their own objective of changing behaviour?