European Court of Auditors reports on European Commission role in Russia trade sanctions enforcement

11 November 2026

The European Court of Auditors (ECA) has published its report on how the European Commission supports and monitors member states’ enforcement of EU trade sanctions against Russia. The ECA is the EU’s independent external auditor, which checks how EU funds are spent and assesses whether EU policies and programmes achieve their aims. The audit covered restrictions on non-energy goods under Regulation (EU) No 833/2014 from February 2022 to the end of 2025.

The ECA found that the European Commission had made strong coordination efforts and that EU-Russia trade had fallen sharply. However, the ECA said that vague legal terms, uneven use of information-sharing systems and gaps in monitoring limit the sanctions’ impact. It also found that member states apply customs controls differently. This creates a risk of “forum-shopping”, where businesses choose customs points or licensing offices in member states with weaker controls.

The ECA made 4 recommendations to the Commission:

• Improve the regulatory framework by avoiding vague terms in proposals and guidance, and by reducing problems caused by differences between customs and sanctions terminology (target: 2027).

• Analyse how member states enforce trade sanctions, including how to align customs controls and post-clearance audits, and how they manage trade sanctions licences and check those issued by other member states (target: 2027).

• Encourage member states to make full use of information-sharing systems by reviewing sanctions risk information forms in the Customs Risk Management System, promoting use of the Sanctions Information Exchange Repository, and giving customs authorities access to central systems (target: 2028).

• Improve monitoring by integrating data collection, analysis and compliance tracking, and by proposing criteria to assess the sanctions’ effectiveness and carrying out regular assessments (target: 2028).