The EU’s structure is the feature that most affects how its sanctions work in practice: the measures are adopted centrally and enforced nationally.
Adoption and implementation
A restrictive measure is agreed by unanimity in the Council, expressed as a decision under the common foreign and security policy and, for the parts that bind private parties, as a directly applicable regulation. The regulation applies identically across the union.
Enforcement does not. Each member state designates national competent authorities, sets its own penalties, and licences under its own procedures. The result is a single prohibition with twenty-seven enforcement regimes behind it, and the practical consequence — differences in penalty severity, investigative capacity and licensing practice between member states — is a documented feature of the system rather than a defect in any one state’s implementation.
Owned or controlled
Like the UK, the EU catches entities owned or controlled by designated persons, and the Commission has published guidance on how control is assessed. The ownership threshold used as a presumption is fifty per cent, but control is a separate and independent test.