Three years, sixteen packages
By the third anniversary the sanctions regime had become an institution rather than a series of decisions, and institutions behave differently from decisions.
Around the third anniversary a further European package was adopted, and by this point the process had a settled character worth describing.
What had become routine
Regular packages, prepared by a machinery that now exists permanently: analysts tracking trade flows, lawyers drafting listings that will survive challenge in court, and diplomats managing the unanimity requirement.
That is what an institution looks like. A decision requires political energy each time; an institution runs on process, and process is far more durable than attention.
The shadow fleet
The dominant enforcement subject by 2025 was the fleet of ageing tankers operating outside the price cap arrangements — often with opaque ownership, uncertain insurance and switched-off tracking.
The response combined vessel-by-vessel listing, port access restrictions, pressure on flag registries and on the service providers involved. It also raised a genuine environmental argument: an uninsured forty-year-old tanker in the Baltic is a hazard to every coastal state regardless of politics.
The legal discipline
Listings are challenged in court, and a proportion are annulled for insufficient evidence. That is not a failure of the regime. A sanctions system whose listings survive judicial review is more powerful than one that lists freely and loses cases, because the surviving listings are unarguable.
My reading at three years
The forecast that unanimity would collapse has now been wrong for three years running. It may still fail. But the record so far is of a coalition that has kept agreeing, sixteen times, under repeated pressure to stop.
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