Context specific and structural changes in EU restrictive measures adopted in reaction to Russia’s aggression on Ukraine

Since February 2022, the outbreak of the war in Ukraine has changed the Union under many respects. This article intends to capture the recent developments of the sanctioning practice in response to Russia’s aggression, illustrating important changes in the design, implementation and enforcement of EU restrictive measures. More precisely, a few distinctive aspects will be highlighted with the view to assess whether restrictive measures are subject to ‘context specific’ or ‘structural’ changes. The former are intrinsically linked to the geopolitical circumstances of the war in Ukraine (and will unlikely to be used in other contexts); while the latter have an impact on the EU sanctioning practicetout court. Accordingly, it is argued that the war in Ukraine will, to a certain extent, permanently change how restrictive measures are designed, implemented and enforced at the EU and national level.