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 matrix documents non-adopted sanctions against Russia, outlining: measures that could be adopted; their likely impact (high, medium or low); ease of enacting (high, medium or low); ease of enforcing (high, medium or low); and trade-offs inherent in such measures (certain, potential or debatable). The matrix is not developed with any specific sanctioning state in mind; impact is assessed on the assumption of multilateral adoption by the existing sanctioning coalition, including G7 economies and other aligned states.
Ratings: High Medium Low Trade-offs: Certain Potential Debatable None
| Measure | Impact | Ease of enacting | Ease of enforcing | Trade-offs | Background |
|---|---|---|---|---|---|
| TARGETING RUSSIAN ECONOMY | |||||
| Transfer of central bank reserves to Ukraine | High | Medium | High | Debatable |
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 — less than the amount Russia owes in reparations to Ukraine, giving rise to the argument that these assets should be used in satisfaction of that obligation. Impact: High — formally depriving Russia of US$300 billion in foreign currency reserves and making that amount available to Ukraine. Ease of enacting: Medium — the principal legal obstacle is the law of sovereign immunities. Despite some disagreement, the weight of authority increasingly points to the legality of a transfer effected to satisfy Russia’s obligation to pay reparations. The main challenges are either political or related to debatable trade-offs. An additional institutional challenge stems from over US$200 billion being held in Belgium, potentially requiring a unanimous EU decision. Ease of enforcing: High — the assets have already been identified and remain frozen. The main implementation challenge would involve designing arrangements for the disbursement of transferred funds. Trade-offs: Debatable — debate has focused on whether the international appeal of storing funds in EUR/USD/GBP/JPY could suffer as a result of a perceived threat of expropriation. These trade-offs are debatable given the subdued reaction of markets to the freezing of reserves and the magnitude of Russia’s breaches of international law. Recommended reading: Anton Moiseienko, ‘Frozen Russian State Assets: The Key to Enforcing the Largest Financial Debt of Our Times?’, Verfassungsblog, April 2025; Philippa Webb, ‘Legal options for confiscation of Russian state assets to support the reconstruction of Ukraine’, European Parliament, February 2024. |
| Ban on correspondent banking for all Russian banks | High | High | High | Certain |
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; the SWIFT ban does not preclude Russian banks from accessing the global financial system via correspondent accounts in Western banks. Several sanctions packages targeted correspondent banking transactions, including the US designation of over 50 small- and medium-sized banks in November 2024. Still, a complete ban on correspondent banking for all Russian banks has not been achieved. Impact: High — a complete ban would entirely isolate the Russian banking sector from the global financial system. Despite most Russian banks already being cut off, this measure would be systemically important. Ease of enacting: High — such a ban would constitute an expansion of already existing measures. Ease of enforcing: High — financial institutions already comply with a ban on transacting with most Russian banks; this would constitute a limited expansion of the existing regime. Trade-offs: Certain — the absence of a comprehensive ban is the product of a policy choice to preserve a financial link to Russia, in particular to process energy-related payments. Unless licences are granted, this ban would certainly affect energy trade with Russia. Recommended reading: Christine Abely, The Russia Sanctions (Cambridge University Press, 2023), Chapter 3. |
| Sanctions on all major Russian energy companies | High | High | Medium | Debatable |
The West’s policy towards Russia’s energy supplies has been a balancing act between reducing Kremlin revenues and minimising energy price rises. While some major 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 LNG to the EU — was a prohibition on raising funds in US capital markets. This has ensured continued supply of Russian LNG to Europe, resulting in an estimated €228 billion of income since the start of the full-scale invasion. Impact: High — energy trade continues to generate hundreds of billions of dollars for the Russian economy, including from the EU. Ease of enacting: High — there are no significant legal or institutional constraints; a number of major Russian energy companies are already sanctioned. Ease of enforcing: Medium — due to the potential for sanctions evasion via non-sanctioned intermediaries. Trade-offs: Debatable — the EU’s REPowerEU initiative aims to phase out Russian gas imports. Some economic analyses suggest that even an immediate halt of Russian LNG supplies would not significantly affect the EU’s market. It is therefore debatable whether such measures will lead to higher energy prices. Recommended reading: Vitaly Shevchenko, ‘How the West is helping Russia to fund its war on Ukraine’, BBC, May 2025; Katja Yafimava et al, ‘EU sanctions on Russian LNG: choices and consequences’, Oxford Institute of Energy Studies, July 2024; Lukas Barner et al, ‘Is Russian gas still needed in the European Union?’, Energy Strategy Reviews, March 2025. |
| Ban on direct or indirect purchases of Russian energy | High | High | Medium | Debatable |
This is an alternative way to achieve the same result as sanctioning all major Russian energy companies, 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 direct or indirect purchases of Russian energy will forestall purchases via third countries — a concern in connection with the oil price cap. 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 (see above). |
| Reducing the oil price cap | Medium | Medium | Low | Potential |
The oil price cap is the sanctioning coalition’s compromise solution to limiting Russia’s oil revenues without constricting global supply. Coalition members allow logistics companies and financial institutions to facilitate Russian oil supplies to third countries so long as the price paid is below the cap, then set at US$60 per barrel (as of June 2025). President Zelensky called for a cap of US$30 per barrel in June 2025. The G7 meeting in Canada reached no agreement on reductions. The European Commission formally proposed lowering the cap to US$45 per barrel but then reportedly postponed these plans due to instability in the Middle East. Impact: Medium — oil sales generate an estimated US$189 billion in 2024 and US$185 billion in 2023 for Russia. A significant reduction would be impactful, but is rated medium given enforcement difficulties. Ease of enacting: Medium — there are no significant legal or institutional constraints, but the cap requires coalition-wide agreement including from states that have not yet matched EU/UK reductions. Ease of enforcing: Low — third countries including China and India remain willing to purchase above the cap. Russia’s ‘shadow fleet’ enables sales without Western logistics companies or financial institutions. Western purchases of petroleum refined from Russian crude also feed market demand. Trade-offs: Potential — the principal reason for the cap rather than a complete ban is minimising the risk of reduced availability of Russian oil and higher global oil prices. 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 | High | Medium | Low | Potential |
The fundamental problem presented by Russian oil sanctions — constricting Kremlin 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 sale proceeds to be deposited in escrow accounts outside Iran, usable only for humanitarian spending. Some have argued for a similar approach to Russia. Impact: High — due to the income generated by Russian oil sales. Ease of enacting: Medium — this scheme can only work if banks involved in non-compliant transactions face the risk of being shut out of the US financial system; US administration buy-in is therefore indispensable. Current political obstacles aside, there are no substantial legal or institutional impediments. It would also require Russia to decide it is economically advantageous to continue selling under these restrictive conditions. Ease of enforcing: Low — enforcement would require ongoing monitoring of Russian oil sales around the world, similar to the oil price cap. Trade-offs: Potential — 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 and his 2025 book Chokepoints; Tom Keatinge, ‘Tapped Out: It is Time to Revisit Oil Sanctions on Russia’, RUSI, May 2025. |
| Secondary sanctions on buyers of Russian goods | High | Medium | Low | Certain |
Sanctions on various categories of Russian goods have resulted in a displacement of those 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 — at the time of writing seemingly abandoned — features an extreme example of this approach, proposing to authorise 500% tariffs on countries whose businesses purchase sanctioned Russian goods. Impact: High — the impact depends on how vigorously such sanctions are imposed and what categories of sanctioned Russian goods they primarily address. It is possible for such sanctions to have high impact. Ease of enacting: Medium — 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. Ease of enforcing: Low — effective enforcement would require the identification of transactions involving sanctioned Russian goods in third countries, posing a significant monitoring challenge. Trade-offs: Certain — if used on any meaningful scale, such sanctions are certain to negatively affect trade with the countries of targeted businesses. |
| Tax on operating in Russia | Medium | High | High | Potential |
Hundreds of foreign businesses left Russia following the full-scale invasion, whether due to sanctions or for reputational or other reasons. Still, multiple Western businesses remain 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: Medium — 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, the impact would likely be medium. Ease of enacting: High — 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 and Australia. This will likely facilitate adoption of taxation measures that could otherwise be in tension with such treaties. Ease of enforcing: High — the tax would be collected by the home state of the company concerned. Trade-offs: Potential — there is evidence of some companies withdrawing from Russia having to sell their assets below market value to well-connected Russians. This is a potential risk inherent in any measures incentivising withdrawal. Recommended reading: Yale School of Management, ‘Over 1,000 Companies Have Curtailed Operations in Russia — But Some Remain’; B4Ukraine, ‘Corporate Enablers of Russia’s War in Ukraine’, January 2025; Institute of Legislative Ideas, Razom and B4Ukraine, ‘Continued Operations Sanctions Toll’, January 2025. |
| TARGETING RUSSIAN MILITARY | |||||
| Entry bans against all Russian army and defence personnel | Medium | High | High | None |
Over the past three years, Russia has invested substantial effort into expanding its military recruitment, including through salaries and sign-up bonuses. Blanket travel sanctions on all servicepersons and defence officials could undermine the effectiveness of this recruitment drive. A more limited version 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: Medium — 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. Ease of enacting: High — governments typically have very broad powers in the domain of immigration and border controls. Ease of enforcing: High — while enforcement of entry bans is not foolproof (e.g. those with resources may be able to procure forged documents), generally speaking the ease of enforcing is high. Trade-offs: None — 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 generate a significant additional compliance burden on financial institutions. |
| TARGETING RUSSIAN DIPLOMACY | |||||
| Expulsion from the FATF | Low | Low | High | Debatable |
The Financial Action Task Force (FATF) is an intergovernmental organisation that sets anti-money laundering, counter-terrorist financing and counter-proliferation financing standards. Russia joined the FATF in 2003 but was suspended, rather than expelled, in 2023. Russia’s expulsion would recognise its persistent unwillingness to return to compliance with its international obligations and acknowledge the ongoing financial crime risks it poses, including through its provision of resources to North Korea. Impact: Low — the impact of expulsion at this stage would be primarily symbolic. Ease of enacting: Low — the decision to expel Russia can only be taken by consensus within the FATF. Ease of enforcing: High — Russia’s expulsion from the FATF does not require any monitoring or implementation. Trade-offs: Debatable — 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. However, such views need to be considered in the context of Russia’s expulsion constituting a response to egregious and ongoing violations of international law that directly undermine the FATF’s mission. |
| Entry bans against all Russian diplomats | Low | High | High | None |
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 own 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: Low — entry bans can to some extent undermine the desirability of continued diplomatic service in Russia, but the likely impact is 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 (see above). |
Source: Anton Moiseienko, ‘Russia (Non) Sanctions Matrix’, Economic Crime Law, 23 June 2025. Classifications and assessments are the author’s own. This version was published in June 2025 and formatted in May 2026.
Economic Crime Law 