Whisper “Trickbot” or “Conti,” and cybersecurity experts will be spooked. These are pieces of malware and ransomware used by a gang of Russia-based hackers to sneak into computer servers and demand at least $800 million from Western corporations, hospitals, and government agencies. In February and September, Britain and the United States imposed joint sanctions on 18 members of the hacker syndicate behind the attacks. In doing so, Washington and London dealt a blow not just to the hackers but also to Moscow: The Trickbot-Conti gang has supported the invasion of Ukraine and probably received directions from Russian security services. The sanctions ban the syndicate’s members from traveling to the United States or Britain and freeze their assets in these countries. But there’s a catch: The European Union has not imposed sanctions, leaving the hackers free to operate in the bloc.
This apparent flaw is not an administrative glitch. Since Britain left the EU in 2020, London and Brussels have made sanctions decisions completely separately, and there is no formal mechanism to ensure alignment between British and European measures. This has resulted in regulatory divergences—a polite way to say sanctions loopholes—that Moscow and other malicious actors can exploit. The Trickbot-Conti gang is only one example of such exploitation, but it highlights the fact that restarting British-EU collaboration on sanctions is long overdue. Increased cooperation would be a quick and cheap way for Britain and the EU to close glaring sanctions loopholes and deal a blow to the Kremlin.
Ask any Western official, and they will tell you that collaboration on Russia sanctions among G-7 countries is going hunky dory. On paper, this may be true. In the first days of Russia’s invasion of Ukraine, Western countries including Britain, the United States, and the 27 members of the EU jointly froze around half of Russia’s $640 billion in foreign-exchange reserves. The joint G-7-EU price cap on Russian oil exports is another example of Western sanctions cooperation. Yet the reality is that such coordination is the exception, not the norm. In particular, there is little cooperation between Britain and the EU on targeting Kremlin-linked businesspeople and illicit groups helping the Russian war machine.
Of course, there are reasons for this: The British government likes to claim that it is no longer a haven for wealthy Russians, but British law still makes it harder than in the EU to place someone under sanctions. Yet this obstacle is not insurmountable, and there are at least three reasons why greater alignment on Russia sanctions would be a positive development. The first is obvious: Joint British-EU designations would boost the effectiveness of sanctions. With common designations, individuals and companies engaged in illicit activities would be barred from traveling to, and operating from, both Britain and the EU—magnifying the impact of Western sanctions and possibly compelling other like-minded allies, such as Canada, Australia, and Japan, to impose similar measures on the same murky people or firms.
Formalized information sharing between Britain and the EU’s member states would also help to detect sanctions evasion schemes. Joint British-EU designations would prove especially useful to clamp down on those illegal networks that smuggle semiconductors for the Russian military in breach of Western export controls. Many of the firms that engage in such behavior are based in China, Turkey, or the United Arab Emirates, but others are found in Britain and the EU. Earlier this month, Washington blacklisted 49 entities that were shipping semiconductors to Moscow, including three companies operating from Britain, Finland, and Germany. From this perspective, joint measures to tackle sanctions evasion make sense. What’s more, Britain and EU member France are among the few countries that have the intelligence capabilities to detect companies dodging sanctions.
The second reason has to do with the private sector. Many of the Western firms that chose to stay in Russia after the invasion of Ukraine face a tricky situation. Beyond the controls that Moscow has imposed to complicate exits, many multinationals report that the difficulties of navigating different sanctions regimes further complicate exit strategies. Of course, this argument may be disingenuous: It could well be that some private firms have chosen to stay in Russia and are using sanctions divergence as an excuse to deflect criticism. Greater alignment between British and EU sanctions legislation would make this talking point moot and possibly help some firms to leave the Russian market.
A third factor is that pan-European collaboration on sanctions would be a useful preemptive measure for Europeans to take if a Republican president were to upend U.S. sanctions policy on Russia from 2025. The risk is far from hypothetical: Many Republican candidates, including former U.S. President Donald Trump, Florida Gov. Ron DeSantis, and the entrepreneur Vivek Ramaswamy have no qualms suggesting that supporting Ukraine against Russia does not make sense for the United States. The election of any of these candidates would therefore spell trouble for Western sanctions policy toward Russia. If Europeans are serious about their long-term commitment to Ukraine, building a united British-European front on sanctions would be a great idea to start preparing for a potential change of heart toward Moscow in Washington.
Just because a policy proposal makes sense on paper does not mean that it will work out well in practice. Excellent proposals are often too complex, costly, or unpopular to implement. The good news is that greater sanctions collaboration would probably avoid these pitfalls. First, it would be simple to implement. Both sides used to work together before Brexit, and the administrators to adopt and implement sanctions are already in place on both sides. An additional bonus is that London’s well-staffed, top-notch sanctions teams are the envy of their European counterparts.
Second, little or no money is needed to restart cooperation on Russia-related sanctions. After sanctions are adopted, it is up to private firms to implement the measures and cover the costs of compliance. On the government side, the amounts at stake to design and implement sanctions programs are therefore minimal and do not entail lengthy budget negotiations. In addition, both sides have no money to make in the field: Sanctions probably represent one of the few areas where Britain and the EU, which have become fierce economic competitors since Brexit, have no firms to promote in a bid to create jobs and raise fiscal revenues.
Third, public interest in sanctions technicalities is low, limiting the risk of a political backlash. Few people outside experts care about the nitty-gritty of sanctions, let alone whether they are joint or unilateral measures. In addition, there is a broad pan-European consensus on the need to confront Russia. According to a Bruegel poll from early 2023, support for sanctions policies has held steady since February 2022; despite Russian claims to the contrary, majorities or pluralities in all European countries but one support economic and financial sanctions. As a result of these two factors, greater British-EU sanctions collaboration would most likely be uncontroversial. To put it more bluntly: Very few people beyond the affected individuals and firms—and, of course, the Kremlin—would care about joint British-EU sanctions.
Sanctions represent a key tool for Western countries to weigh on Russia’s ability to wage war against Ukraine. As a result, ensuring the effectiveness and predictability of these measures should be a priority for allies, not least to ensure greater compliance and buy-in from the private sector. This, in a nutshell, is why greater British-EU collaboration on sanctions would make perfect sense. Of course, it would not be a silver bullet to change Moscow’s calculus in Ukraine. But every little bit helps, and greater collaboration on sanctions could also represent a low-hanging fruit to revive political relations across the channel.
