Russia (Non) Sanctions Matrix

There are multiple databases or ‘trackers’ of Russia sanctions. They are important for compliance purposes and assessing the effect of sanctions. What is lacking is an accessible summary of sanctions that could be, but have not been, imposed on Russia. Such a resource could be a repository of ideas for Western governments to draw upon, but also a demonstration of how far short the current regime falls of a ‘maximum pressure’ approach towards Russia.

The Russia (Non) Sanctions Matrix, which is available below, documents the non-adopted sanctions against Russia. Specifically, it outlines:

• Measures that could be adopted, grouped into those affecting Russia’s economy, military or diplomacy;
• Impact that they would likely have (high, medium or low);
• Ease of enacting such measures (high, medium or low);
• Ease of enforcing such measures (high, medium or low); and
• Trade-offs inherent in such measures (certain, potential or debatable).

Each of these classifications is based on my own assessment and is less than scientifically rigorous. However, the Explanation of Categories section below explains what I mean by each of the four categories (impact, ease of enacting, ease of enforcing and unintended consequences). The Background section below provides additional information about the measures listed, including suggestions for further reading.

The matrix is not developed with any specific sanctioning state in mind. The impact of sanctions is discussed on the assumption that they are adopted multilaterally by the existing sanctioning coalition, including G7 economies and other aligned states. This is the first iteration of this matrix, and any ideas for improvement are welcome.

MATRIX

Measure	Impact	Ease of enacting	Ease of enforcing	Trade-offs
Targeting Russian Economy
Transfer of central bank reserves to Ukraine	High	Medium	High	Debatable: reduced attractiveness of Western currencies
Ban on correspondent banking for all Russian banks	High	High	High	Certain: difficulty of processing all Russia-related transactions, including energy-related ones, unless licences are granted
Sanctions on all major Russian energy companies	High	High	Medium	Debatable: higher energy prices for customers in countries imposing the sanctions
Ban on indirect or indirect purchases of Russian energy	High	High	Medium	Debatable: higher energy prices for customers in countries imposing the sanctions
Reducing the oil price cap	Medium	Medium	Low	Potential: reduced availability of Russian oil and higher oil prices
Directing payments for Russian oil to an escrow account	High	Medium	Low	Potential: reduced availability of Russian oil and higher oil prices
Secondary sanctions on buyers of Russian goods	High	Medium	Low	Certain: negative impact on trade with affected countries
Tax on operating in Russia	Medium	High	High	Potential: incentive to sell business under market value to oligarchs
Targeting Russian Military
Entry bans against all Russian army and defence personnel	Medium	High	High	None
Targeting Russian Diplomacy
Expulsion from the FATF	Low	Low	High	Debatable: undermining the FATF’s message that it encompasses major non-Western economies
Entry bans against all Russian diplomats	Low	High	High	None

EXPLANATION OF CATEGORIES

Category	Comment
Impact	Impact refers to the likely capacity of the measure concerned to affect Russia’s economy, military or diplomacy in the foreseeable future. Here, impact refers to the added value compared to existing sanctions. For example, a ban on correspondent banking services to all Russian banks would expand the already existing ban on such services for some Russian banks, rather than instituting a completely new form of sanctions. While separate, impact is connected to the ease of enforcement; measures that are exceedingly difficult to enforce are less likely to be impactful.
Ease of enacting	Ease of enacting refers to the presence of legal or institutional barriers impeding the imposition of the measure concerned. How significant these barriers are can be contested. For example, potential transfer of Russian central currency reserves to Ukraine has prompted debates as to whether it is precluded by the law of sovereign immunities. Ease of enacting does not refer to purely political obstacles to the adoption of the measures concerned.
Ease of enforcing	Ease of enforcing refers to the practical aspect of implementing sanctions, specifically the additional resources and/or capabilities that would be necessary to give effect to the measures concerned.
Trade-offs	Trade-offs refers to what would often be described as unintended consequences of sanctions. ‘Trade-offs’ is a more accurate term because these consequences may not be unanticipated or unintended, but are a predictable cost of adopting sanctions.

BACKGROUND

Targeting Russian Economy

• Transfer of Russian central bank reserves to Ukraine. Discussions about transferring Russia’s central bank reserves to Ukraine began soon after their coordinated freezing in February 2022. The amount frozen across G7 economies is approximately US$300 billion. This is less than the amount that Russia owes in reparations to Ukraine, giving rise to the argument that these assets should be used in satisfaction of that obligation.
  • Impact. The impact of a transfer would be high due to formally depriving Russia of US$300 billion in foreign currency reserves and making that amount available to Ukraine.
  • Ease of enacting. The principal legal obstacle to the transfer is the law of sovereign immunities, which ordinarily protect state property from seizure. Despite some disagreement, the weight of authority increasingly points to the legality of a transfer effected to satisfy Russia’s existing, and uncontroversial, obligation to pay reparations to Ukraine (see recommended reading below). Russia’s options to sue, if any, are very limited. An additional, institutional challenge of effecting the transfer stems from the location of most of Russia’s frozen state assets (over US$200 billion) in Belgium, potentially requiring a unanimous EU decision for the transfer. Overall, the main challenges are either political or related to the (debatable) trade-offs that the transfer would entail (see below), meaning the ease of enacting these measures is moderate.
  • Ease of enforcing. The transfer would affect assets that have already been identified and remain frozen, meaning that the ease of enforcing (or implementation) is high. The main implementation challenge would involve designing appropriate arrangements for the disbursement of transferred funds.
  • Trade-offs. Much of the debate has focused on the potential consequences of the transfer for the global financial system, namely whether the international appeal of storing funds in EUR/USD/GBP/JPY and other relevant currencies could suffer as a result of a perceived threat of expropriation. These trade-offs are debatable given the subdued reaction of the markets to the freezing of Russia’s central bank reserves, the magnitude of Russia’s breaches of international law that the transfer is intended to address, and the negative consequences of failing to deliver on the G7 promise to ensure reparations to Ukraine.
    • Recommended reading:
      • Anton Moiseienko, ‘Frozen Russian State Assets: The Key to Enforcing the Largest Financial Debt of Our Times?’, Verfassungsblog, April 20225 (a general overview);
      • Philippa Webb, ‘Legal options for confiscation of Russian state assets to support the reconstruction of Ukraine’, European Parliament, February 2024 (a detailed analysis of the legal issues involved, including sovereign immunities).

• Ban on correspondent banking for all Russian banks. One of the focal points for financial sanctions in 2022 was the disconnection of Russian banks from the SWIFT payment network. Not all banks were disconnected; and the SWIFT ban in and of itself does not preclude Russian banks from accessing the global financial system via correspondent accounts in Western banks.  Since the full-scale invasion, several sanctions packages targeted correspondent banking transactions involving Russian banks, including the US designation of over 50 small- and medium-sized banks in November 2024. The European Commission is proposing a full transaction ban on another 22 Russian banks as part of its 18^th sanctions package. Still, these sanctions fall short of a complete ban on correspondent banking for all Russian banks, as highlighted in FAQs published by US Treasury in November 2024 (‘[t]here remain a number of non-sanctioned Russian banks, subsidiaries of foreign banks, and money service businesses’).
  • Impact. A complete correspondent banking ban would entirely isolate the Russian banking sector from the global financial system. Therefore, despite the fact that most Russian banks are already cut off from foreign correspondent banking services, this measure would be systemically important and therefore likely produce high impact.
  • Ease of enacting. Such a ban would constitute an expansion of already existing measures, and therefore the ease of enacting is high.
  • Ease of enforcing. Financial institutions in sanctioning countries already have to comply with a ban on transacting with most Russian banks, and therefore this measure would only constitute a limited expansion of the existing regime. The ease of enforcing is therefore high.
  • Trade-offs. The absence of a comprehensive ban on correspondent banking services to all Russian banks is the product of a policy choice to preserve a financial link to Russia, in particular to process energy-related payments. It is certain that, unless licences are granted to allow certain transactions to proceed, this ban would affect energy trade with Russia.
  • Recommended reading: Christine Abely, The Russia Sanctions (Cambridge University Press, 2023), Chapter 3 (overview of financial sanctions imposed on Russia, which have been expanded since the time of writing but largely retain the same approach).

• Sanctions on all major Russian energy companies. The West’s policy towards Russia’s energy supplies has been a balancing act. Its two competing drivers are the desire to reduce the Kremlin’s revenues while minimising the rise in energy prices for the population either in the states imposing the sanctions or globally. While some major Russian energy companies, such as Gazprom and Rosneft, were sanctioned after the full-scale invasion, the only sanctions imposed on Novatek, Russia’s largest private exporter of liquified natural gas (LNG) to the EU, was the prohibition on raising funds in US capital markets. This ensures continued supply of Russian LNG to Europe, resulting in an estimated €228 billion of income since the start of full-scale invasion. Sanctions on all major Russian energy companies would cut off this source of income for Russia.
  • Impact. As mentioned above, energy trade continues to generate hundreds of billions of dollars for the Russian economy, including from the EU. The impact of the sanctioning coalition ensuring that all major Russian energy companies are sanctioned would therefore be high.
  • Ease of enacting. There are no significant legal or institutional constraints to the imposition of such sanctions. As mentioned previously, a number of major Russian energy companies are already sanctioned. The ease of enacting is therefore high.
  • Ease of enforcing. The ease of enforcement is medium due to the potential for sanctions evasion via the use of non-sanctioned intermediaries.
  • Trade-offs. The implications of such measures are contested. The EU launched the REPowerEU initiative in May 2022 to phase out all imports of Russian gas by the end of 2017. Some economic analyses suggest that even an immediate halt of Russian LNG supplies would not significantly affect the EU’s market (see below). Therefore, it is debatable whether such measures will lead to higher energy prices for customers in countries imposing the sanctions.
  • Recommended reading:
    • Vitaly Shevchenko, ‘How the West is helping Russia to fund its war on Ukraine’, BBC, May 2025 (a brief overview of key issues);
    • Katja Yafimava et al, ‘EU sanctions on Russian LNG: choices and consequences’, Oxford Institute of Energy Studies, July 2024 (a detailed analysis of EU stance vis-à-vis Russian LNG supplies);
    • Lukas Barner et al, ‘Is Russian gas still needed in the European Union? Model-based analysis of long-term scenarios’, Energy Strategy Reviews, March 2025 (economic analysis suggesting that the EU can satisfy its gas needs without Russian LNG supplies)

• Ban on indirect or direct purchases of Russian energy. This is, in essence, an alternative way to achieve the same result as that discussed above, via a focus on commodities (Russian energy supplies) rather than suppliers (Russian energy companies). These two approaches are not mutually exclusive and can be used in a complementary fashion. If properly enforced, a ban on indirect or direct purchases of Russian energy will forestall purchases of Russian energy via third countries, which is a concern in connection with the oil price cap (see below).
  • The analysis of impact, ease of enacting, ease of enforcing, trade-offs and recommended reading is the same as for sanctioning all major Russian energy companies, discussed above.

• Reducing the oil price cap. The oil price cap is the sanctioning coalition’s compromise solution to the challenge of limiting Russia’s oil revenues without constricting global supply and driving up prices. Members of the sanctioning coalition do not import Russian crude oil or refined petroleum themselves. However, they allow logistics companies and financial institutions within their jurisdiction to facilitate Russian oil supplies to third countries so long as the price paid is below the cap, currently set at US$60 per barrel (as of June 2025). The Ukraine/US Yermak Mc-Faul Group has advocated a lower price cap since 2023 on the basis that Russian domestic oil extraction only costs US$5-10 per barrel. Ukraine’s president Volodymyr Zelensky called for the price cap of US$30 per barrel in June 2025. The G7 meeting in Canada reached no agreement on any reductions in the price cap. The European Commission formally proposed lowering the price cap to US$45 per barrel in June 2025, but then reportedly postponed these plans because of the instability in the Middle East.
  • Impact. Oil sales continue to generate hundreds of billions of dollars for Russia, including an estimated US$189 billion in 2024 and US$185 billion in 2023. The impact of a significant reduction of this amount would therefore be high.
  • Ease of enacting. There are no significant legal or institutional constraints to the imposition of such sanctions, and so the ease of enacting is high.
  • Ease of enforcing. Enforcing the oil cap has proven difficult to date. Third countries, including China and India, remain willing to purchase Russian oil above the price cap. Russia’s ‘shadow fleet’ of uninsured, and often uninsurable, vessels enables the sale of Russian crude oil without the involvement of Western logistics companies or financial institutions. Meanwhile, Western countries’ continued purchases of petroleum refined in third countries from Russian crude oil feeds the market demand. The ease of enforcing is therefore low.
  • Trade-offs. As explained above, the principal reason for the imposition of the oil price cap, as opposed to a complete ban on Russian oil sales, is minimising the risk of reduced availability of Russian oil and higher oil prices. This is a potential concern.
  • Recommended reading:
    • Centre for Research on Energy and Clean Air, ‘Russia Fossil Tracker’.
    • Yermak-McFaul Group, ‘The International Working Group on Russian Sanctions Calls for Introducing a Low Price Cap on Russian Oil Products’, February 2023.

• Directing payments for Russian oil to an escrow account. The fundamental problem presented by Russian oil sanctions – namely, the need to constrict the Kremlin’s revenue streams while avoiding a spike in global oil prices – is reminiscent of the challenge the US faced in imposing sanctions against Iran in the 2000s. One solution was to allow other countries to buy Iranian oil but require for sale proceeds to be deposited in escrow accounts outside Iran that could only be used to fund humanitarian spending, such as food and medicine supplies. This preserved some incentives for Iran to sell oil and for other countries to buy it while denying Tehran the ability to use the proceeds for its military programmes. Some have argued for a similar approach to be taken to Russia.
  • Impact. Due to the income generated by Russian oil sales, as discussed above, the impact of this measure would be high.
  • Ease of enacting. This scheme can only work if banks involved in non-compliant transactions face the risk of being shut out of the US financial system; therefore, buy-in by the US administration is indispensable for this to be feasible. Current political obstacles aside, there are no substantial legal or institutional impediments to the establishment of such a scheme. It would however also require that Russia decide it is economically advantageous to continue selling oil to third countries under these restrictive conditions. Therefore, the ease of enacting is medium.
  • Ease of enforcing. The enforcement of these restrictions would require ongoing monitoring of Russian oil sales around the world, similar to the oil price cap. The ease of enforcing is therefore low.
  • Trade-offs. Like other restrictions on Russian oil sales, this proposal entails the risk of a potential reduction in Russian oil supplies and therefore increased prices.
  • Recommended reading:
    • Eddie Fishman’s X thread from 5 June 2025 (an outline of the idea, also explained in greater detail in Fishman’s 2025 book Chokepoints).
    • Tom Keatinge, ‘Tapped Out: It is Time to Revisit Oil Sanctions on Russia’, RUSI, May 2025 (another summary of the idea).

• Secondary sanctions on buyers of Russian products. Sanctions on various categories of Russian goods, including the oil price cap for Russian crude oil, have resulted in a displacement of those Russian exports to third countries. Imposing sanctions on third-country purchasers, such as refineries buying Russian crude oil, is one possible response to this displacement. The Blumenthal-Graham sanctions bill tabled in US Congress – a and now seemingly abandoned – features an extreme example of this approach by proposing to authorise 500% tariffs on countries whose businesses purchase sanctioned Russian goods.
  • Impact. The impact of such secondary sanctions depends on how vigorously they would be imposed, and what categories of sanctioned Russian goods they would primarily address. It is, however, possible for such sanctions to have high impact.
  • Ease of enacting. The imposition of such sanctions would need to be considered in light of applicable trade treaties, which normally allow some leeway for national security-motivated action. The ease of enacting is therefore medium.
  • Ease of enforcing. The effective enforcement of such secondary sanctions would require the identification of transactions involving sanctioned Russian goods in third countries. This poses a significant monitoring challenge, and the ease of enforcing is therefore low.
  • Trade-offs. If used on any meaningful scale, sanctions are certain to negatively affect trade with the countries of targeted businesses.

• Tax on operating in Russia. The aftermath of Russia’s full-scale invasion of Ukraine saw hundreds of foreign businesses leave Russia, whether due to sanctions or for reputational or other reasons. Still, there remain multiple Western businesses operating in Russia. Proposals have been made to impose a tax on their operations to generate funds that can be spent for Ukraine’s benefit.
  • Impact. This measure would reduce the appeal of operating in Russia while generating additional funds for Ukraine’s benefit. However, given the limited scale of Western business presence in Russia at the moment, the impact of this measure would likely be medium.
  • Ease of enacting. The introduction of the tax would need to be reconciled with existing double taxation treaties. Notably, in 2023 Russia unilaterally suspended such treaties with 38 states that had imposed sanctions against Russia, including the UK, US, Australia, etc. This will likely facilitate the adoption of taxation measures that could otherwise be in tension with such treaties. The ease of enacting is therefore high.
  • Ease of enforcing. The tax would be collected by the home state of the company concerned. The ease of enforcing is high.
  • Trade-offs. There is evidence of some companies withdrawing from Russia having to do so by selling off their assets below market value to well-connected Russians. This is a potential risk inherent in any further measures incentivising withdrawal, such as the tax at hand.
  • Recommended reading:
    • Yale School of Management, ‘Over 1,000 Companies Have Curtailed Operations in Russia—But Some Remain’ (a periodically updated tracker of Western businesses in Russia).
    • B4Ukraine, ‘Corporate Enablers of Russia’s War in Ukraine: A Closer Look at Multinational Taxes and Revenue in Russia in 2023’, January 2025 (analysis of multinational companies’ tax contributions to the Russian budget).
    • Institute of Legislative Ideas, Razom and B4Ukraine, ‘Continued Operations Sanctions Toll’, January 2025 (proposal for a tax on continued operations in Russia).

Targeting Russian Military

• Entry bans against all Russian army and defence personnel. Over the past three years, Russia has invested substantial effort into expanding its military recruitment, including through salaries and sign-up bonuses. One factor that could undermine the effectiveness of this recruitment drive is the imposition of blanket travel sanctions on all servicepersons in the Russian army and all Russian defence officials. A more limited version of this proposal has been put forward by the Baltics, Nordics and Poland, calling on the EU to ban Schengen travel for Russian soldiers who have taken part in hostilities against Ukraine.
  • Impact. While it is unlikely that this measure will have a decisive effect on the economic incentives for would-be soldiers in underdeveloped parts of Russia, it can counteract Russia’s incentive drive at least to some degree. Its likely impact is therefore medium.
  • Ease of enacting. Governments typically have very broad powers in the domain of immigration and border controls. The ease of enacting is therefore high.
  • Ease of enforcing. While the enforcement of entry bans is not foolproof (e.g. those with resources or connections may be able to procure forged documents), generally speaking the ease of enforcing is high.
  • Trade-offs. There are no trade-offs of note in the imposition of entry bans as described above. By contrast, the use of financial sanctions against tens of thousands of additional targets would have generated a significant additional compliance burden on financial institutions, and  is therefore unlikely to be a feasible proposition for now.

Targeting Russian Diplomacy

• Expulsion from the FATF. The Financial Action Task Force (FATF) is an intergovernmental organisation that sets anti-money laundering, counter-terrorist financing and counter-proliferation financing standards. Its operations are therefore central to safeguarding the international financial system against criminal infiltration or exploitation. Russia joined the FATF in 2003 but was suspended, rather than expelled, two decades later, in 2023. Russia’s expulsion from the FATF would recognise its persistent unwillingness to return to compliance with its international obligations, as well as acknowledging the ongoing financial crime risks that Russia poses, including through its provision of resources to North Korea.
  • Impact. The impact of expulsion at this stage would be primarily symbolic and can therefore be described as low.
  • Ease of enacting. The decision to expel Russia can only be taken by consensus within the FATF, which accounts for low ease of enacting.
  • Ease of enforcing. Russia’s expulsion from the FATF does not require any monitoring or implementation, and the ease of enforcing is therefore high.
  • Trade-offs. Over the past two decades, the FATF has consistently sought to expand its membership beyond its original OECD base. Russia’s expulsion would be presented by some as reneging on that commitment and reverting to a Western-centric paradigm. However, such views need to be considered in their proper context of Russia’s potential expulsion constituting a response to egregious and ongoing violations of international law, many of which directly undermine the FATF’s mission of safeguarding the global financial system from criminal exploitation.

• Entry bans against all Russian diplomats. Similar to entry bans on all Russian army and defence personnel, entry bans could also be imposed on all Russian diplomats. Contrary to popular misconception, diplomatic status only conveys diplomatic privileges and immunities vis-à-vis the state of accreditation (i.e. the state to which the diplomat is posted), leaving other states free to impose their sanctions on other countries’ diplomats. Entry bans against all members of the Russian diplomatic corps can serve as a further condemnation of Russia’s actions and its diplomats’ role in enabling them.
  • Impact. In more practical terms, entry bans can to some extent undermine the desirability of continued diplomatic service in Russia. However, the likely impact of this measure is likely to be low.
  • The analysis of ease of enacting, ease of enforcing, and trade-offs is the same as for entry bans against all Russian army and defence personnel, discussed above.