EU audit finds uneven Russia sanctions enforcement lets goods reach Moscow

Uneven enforcement across member states

The European Court of Auditors published a report on Tuesday, 10 November 2026, saying that differences between EU member states in applying trade sanctions against Russia are weakening their effect and making them easier to bypass. The auditors acknowledge that the European Commission has worked to set up the framework and coordinate implementation, but unclear legal rules, divergent national practices and uneven use of information-exchange tools still affect uniform application. Customs authorities in the 27 member states apply different criteria when authorising exports, requesting documents or interpreting exceptions. That gap lets companies choose the countries with the least strict controls for their trade.

Shipments stopped by one state and cleared by another

The auditors found cases where goods cleared for export to Russia by one member state were later blocked by another. In one case, Polish authorities intercepted a shipment previously authorised by Italy and returned it to Italy, where it was accepted again and sent to Russia through an Italian port. The report also found gaps in detection. Bulgaria has recorded no violation since 2022 involving goods from other countries exported outside the EU through its territory.

Routes through third countries

The report says Russia has partly offset the impact of the measures by diverting imports through third countries, including Turkey, Armenia, Kazakhstan, Kyrgyzstan, Serbia and the United Arab Emirates. Sudden temporary spikes in EU exports to those countries were followed by a sharp rise in exports from them to Russia and Belarus. The evasion chains are moving quickly toward Southeast Asia, with Thailand and Malaysia named. According to research cited in the report, up to 44% of goods exported to Russia were originally made by subsidiaries of Western companies located outside the EU, which keeps their formal origin outside the bloc.

Weapons analysed from 2024 and 2025 that were found in Ukraine still contained Western components. Parts coming directly from the EU made up only 4%, or 8 of 202 identified components.

2021253

202558

2021

253 billion euros

2025

58 billion euros

Data from the article text

Trade collapse and its limits

EU trade with Russia fell from 253 billion euros in 2021 to 58 billion euros in 2025, a decline of more than three quarters. The EU dropped from Russia's first trading partner to its third, and in 2025 it accounted for about 10% of Russia's goods trade. The auditors estimated that, as of July 2026, export restrictions and bans had an economic impact of 49 billion euros, equal to 56% of EU exports to Russia before 2022. The estimated impact on imports was about 110 billion euros, or 75% of the pre-war value. The analysed flows cover 2022 to the end of 2025 and exclude energy and financial services.

Exports49

Imports110

Exports

49 billion euros

Imports

110 billion euros

Data from the article text

Recommendations and the sanctions track record

The auditors recommend that the Commission carry out an in-depth analysis to determine whether member states apply and monitor the EU trade sanctions uniformly. They also call for customs authorities to have access to the central information-exchange systems and for better monitoring and assessment of effectiveness, with proposed criteria and regular evaluations. The EU has adopted 21 sanctions packages since the invasion of Ukraine, and more than 4,500 individuals and organisations are subject to sanctions. The 22nd package was approved in October 2026, and the auditors say the gaps they found weaken the bloc's united front.