On 18 December, the European Union finally approved the long-awaited 12th package of sanctions.

It focuses primarily on ensuring the effective functioning of previously imposed restrictions on Russia, aiming to make the existing sanctions more efficient.

Read more in the article by Transparency International Ukraine's legal adviser, Natalia Sichevliuk – Punishment without unity: are anti-Russian restrictions and bans in Ukraine and West synchronised?

Russia is still the most sanctioned country, including not only restrictions on Russia as a state, such as limitations on trade or diplomatic relations with the aggressor but also personal sanctions against individuals and entities supporting the war against Ukraine.

Tere have been reports of asset seisures of sanctioned individuals, bans on their entry into Western countries, and the freezing of financial transactions for over two years.

Sanctions are primarily political rather than legal measures, aimed at changing the behaviour of sanctioned individuals. Both Europe and the United States aimed to influence Russian enterprises and oligarchs through sanctions from the beginning, expecting a change in their behaviour, an impact on the leadership of Russia, including Putin personally, and a halt to the war.

All restrictions ought to be lifted after such changes, returning the frozen assets to their owners.

The possibility of transferring frozen Russian property to Ukraine, however, while discussed, was not the main goal of Ukraine's international partners' sanctions policy.

The situation seems to be changing, partly due to the realisation that the behaviour of the sanctioned Russians has not been improving.

Only in Ukraine have sanctions have become a mechanism for confiscating Russian property. A similar mechanism has also been developed in Canada.

In terms of the number of Russians and Russian companies subject to sanctions, Ukraine leads Western partners by a few thousand, making the difference negligible. It decided, however, not only to compare the quantity of sanctions but also to check whether they are synchronised in content.

It turns out they are not.

For example, sanctions were not applied to seven Russians in Western countries whose assets were confiscated in Ukraine by court decisions.

Attention should also be drawn to Ukraine's own shortcomings: it has not imposed sanctions on some important Kremlin figures, even though restrictions have already been imposed in the West, and these individuals are well-known in Ukraine.

Ukraine has not imposed sanctions on Andrii Kliuiev, Andrii Portnov, and Volodymyr Sivkovych.

The 12th sanctions package approved on 18 December added over 60 individuals and over 80 companies. It includes, among other things, a ban on the direct or indirect import and purchase or transfer of diamonds from Russia. It also specifies that EU exporters, on a contractual basis, will prohibit the re-export of secret goods and technologies to the aggressor country when making agreements with third countries.

There are many other prohibitions, such as the transit of all military goods across Russia, or the ban on Russian citizens owning, controlling, or holding any positions in legal entities providing cryptocurrency services.

The military leadership of Russia is also included in the sanction lists.

Thus, both in Ukraine and in its partner countries, there is currently no centralised mechanism for anti-Russian sanctions.

Presumably, this situation is a consequence of insufficient communication between national and international bodies working in the field of sanctions enforcement.

As a result, there is a risk of losing the ability to arrest or confiscate Russian property.