Sanctions Enforcement and Asset Seizure: Legal Principles and Challenges

04.09.2026

How can sanctions be enforced effectively across borders while respecting due process, proportionality and fundamental rights?

This question framed a panel chaired by ELI Vice-President Sir Geoffrey Vos on 4 September, which also provided an opportunity to discuss ELI’s ongoing project on Guiding Principles on Seizing and Confiscating Sanctioned Assets. The project seeks to bring greater clarity and effectiveness to a field involving complex questions of seizure, confiscation and cross-border enforcement.

Burkhard Hess examined private international law and cross-border enforcement, including jurisdiction, recognition and cooperation between national authorities. Lorenzo Salazar, President of the Council of Europe Committee on Crime Problems, approached sanctions enforcement from the perspective of criminal law, asset recovery and international cooperation.

Gabrielė Juodkaitė-Granskienė, Chairperson of the Criminal Cases Division of the Supreme Court of Lithuania, addressed due process, procedural safeguards and the judicial task of balancing effective enforcement with fundamental rights. Agnès Carlier, Vice-President of the French National Chamber of Justice Commissioners, focused on enforcement in practice, including identifying and locating assets and the practical obstacles encountered in executing measures against them.

The discussion brought together private international law, criminal justice, judicial and enforcement perspectives to examine where greater coordination and legal certainty are needed and how the ELI project can contribute.