COUNTERING CIRCUMVENTION OF TARGETED SANCTIONS: LEGAL CHALLENGES IN THE EU, THE US AND THE UK

This PhD Thesis investigates the legal challenges posed by targeted sanctions, with a particular focus on the phenomenon of circumvention. Targeted sanctions—especially asset freezing measures against designated persons—are widely used to address international security threats, but they lack a dedicated legal framework at the international level. This regulatory gap risks making unilateral sanctions de facto comprehensive, not targeted, but rather punitive and dispropotionate decisions, which undermine their intended precision. The Thesis conducts a comparative legal analysis of sanctioning practices in the EU, the UK, and the US to assess how different jurisdictions respond to circumvention. It examines two anti-circumvention strategies: first, the use of designations against secondary or derivative targets (e.g., alleged facilitators of evasive practices, such as family members) and, second, enforcement mechanisms. The comparative analysis ultimately offers guidance on how to ensure that sanctions remain targeted, proportionate, decisions. It proposes recommendations on sanctions design and enforcement tools, with the view of countering evasion without undermining the targeted nature of sanctions.