Global Human Rights Defence

2021 EU Human Rights Sanctions Targets

Source: Getty

Author: Elia Duran-Smith

Department: Europe


On 10 December, in observation of the United Nations’ Human Rights Day (which marks the date of the adoption of the 1948 Universal Declaration of Human Rights), the European Union’s (EU) High Representative for Foreign Affairs Josep Borrell outlined the steps taken by the EU to live up to its foundational principle of protecting and promoting human rights around the world in the 2020s. He noted that the EU will provide over €1.5 billion to civil society organisations and human rights defenders from 2021-2027. This supplements the EU’s new thematic human rights sanctions regime. In 2021, the EU launched its first sanctions under this new regime named the EU Global Human Rights Sanctions Regime (GHRSR). This article breaks down who has been targeted since the new sanctions regime was adopted and the kinds of sanctions levied against them.


The first sanctions levied under the GHRSR were against 4 Russian state officials “responsible for serious human rights violations, including arbitrary arrests and detentions, as well as widespread and systematic repression of freedom of peaceful assembly and of association, and freedom of opinion and expression in Russia”. This was particularly a response to their roles in the “arbitrary arrest, prosecution and sentencing” of leading opposition politician and anti-corruption activist Alexei Navalny and the repression of the widespread protests against his treatment. These include the Head of the Investigative Committee, Alexander Bastrykin, Prosecutor-General Igor Krasnov, the Head of the National Guard, Viktor Zolotov, and Head of the Federal Prison Service Alexander Kalashnikov. The sanctions included a travel ban, asset freeze and the prohibition of EU citizens and entities making funds available to these individuals.


In response to the military coup on 1 February and subsequent repression of peaceful demonstrations, the EU placed travel bans and asset freezes on 11 individuals involved in March 2021. This primarily included members of the Tatmadaw (the highest ranks of the Myanmar Armed Forces), including its Commander-in-Chief and Deputy-Commander-in-Chief. The Chairperson of the Union Election Commission responsible for cancelling the 2020 elections was also targeted. These individuals have been barred from receiving funds from EU citizens and corporations.

In a second round of sanctions, the EU also targeted 10 individuals who the European Council stated were implicated in the military junta’s human rights violations. Two corporations controlled by the junta and which provide it with revenue were also subjected to sanctions. 

On 21 June 2021, the European Council placed sanctions on a further 8 individuals and 3 economic entities, as well as the War Veterans Organisation (WVO), for their role in the coup and the subsequent repression of protests. The individuals targeted included ministers and deputy ministers, and the attorney general for “undermining democracy and the rule of law and for serious human rights violations in the country”. The economic entities and the WVO are all state-owned or controlled by the Tatmadaw and have supported its operations. 

Overall, 43 individuals and 6 entities have been subject to the EU’s sanctions, which include asset freezes, denial of financial support from EU citizens and companies, and a ban on travel into or through EU territory. Additionally, the EU has established an arms and equipment embargo to the military junta, an export ban on dual-use goods that may be used by military and border guard police, and export restrictions on equipment for monitoring communications that could be used to repress free speech in Myanmar. It is also prohibited for EU member states to conduct military training or cooperation with the Tatmadaw. 


The EU has imposed sanctions on Belarus since October 2020, following what were widely seen by the international community as fraudulent presidential elections and the crackdown and torture of dissidents across the country who protested against them. In December 2021, the EU sanctioned a further 17 individuals and 11 entities linked to human rights violations in Belarus. This brings the number of sanctions targets to 183 individuals and 26 entities, which have been subject to asset freezes and travel bans barring them from entering or transiting through EU territory. EU citizens and companies have been banned from supplying funds to these individuals and entities. Individuals targeted include prominent figures in the Lukashenko regime, senior members of the country’s Supreme Court and the State Control Committee, alongside propaganda outlets, which have been embroiled in repressing Belarusian civil society, democratic opposition, and independent media. 

Moreover, in connection to the crisis reportedly orchestrated by the regime at its borders with EU states like Poland, Lithuania, and Latvia, the EU has sanctioned corporations, tour operators and hotel groups that have helped facilitate the illegal border crossings. One of the corporations sanctioned includes the state-owned airline Belavia, which has instructed employees not to protest against any election results or suppressions of political opposition. 

Responding to this crisis, Borrell has said, “the European Union will not tolerate the orchestrated and politically motivated instrumentalisation of human beings by the Lukashenko regime. This cynical strategy of exploiting vulnerable people is an abhorrent attempt to deflect attention from the regime’s continued disregard for international law, fundamental freedoms and human rights in Belarus”. 

However, the EU’s sanctions approach has been met with criticism from Svetlana Tikhanovskaya-the opposition leader living in exile in Lithuania, who has been reported as the legitimate winner of the 2020 Belarusian presidential elections. She said the sanctions did not go far enough, adding, “I understand that the fifth package [of EU sanctions] that is going to be imposed will be only about the migrant crisis. But I have to say that the migrant crisis cannot be discussed in separation from the political crisis [within Belarus]”. She has called for more robust sanctions that also recognise the millions of Belarusians “suffering because of this dictatorship”.


Time is yet to tell whether this new sanctions regime will leave a lasting impact on the state of human rights across the world, but it appears to be that the GHRSR has allowed the EU to rapidly respond to human rights abusers in issuing multiple rounds of sanctions against actors in countries like Myanmar and Belarus. However, it has come under fire for too pointedly targeting specific events of human rights violations rather than ongoing, pervasive suppression. 


[1] For further information on the GHSR, please refer to our previous article named “How the new thematic EU sanctions regime works” on

[2] Global Human Rights Sanctions Regime: EU sanctions four people responsible for serious human rights violations in Russia’, 2021

[3] ‘Myanmar/Burma: EU sanctions 11 people over the recent military coup and ensuing repression’, 2021

[4] ‘Myanmar/Burma: EU imposes sanctions on 10 individuals and two military-controlled companies over the February military coup and subsequent repression’, 2021

[5] ‘Myanmar/Burma: third round of EU sanctions over the military coup and subsequent repression’, 2021

[6] ‘Myanmar/Burma: third round of EU sanctions over the military coup and subsequent repression’, 2021

[7] ‘Myanmar/Burma: third round of EU sanctions over the military coup and subsequent repression’, 2021

[8] ‘Belarus: EU adopts 5th package of sanctions over continued human rights abuses and the instrumentalisation of migrants’, 2021

[9] ‘Belarus: EU adopts 5th package of sanctions over continued human rights abuses and the instrumentalisation of migrants’, 2021

[10] Radio Free Europe/Radio Liberty, 2021

[11]  ‘Belarus: EU adopts 5th package of sanctions over continued human rights abuses and the instrumentalisation of migrants’, 2021

[12] Vock, 2021

[13]  Vock, 2021


‘Belarus: EU adopts 5th package of sanctions over continued human rights abuses and the instrumentalisation of migrants’. (2021, December 2). European Council. 

Borrell, J. (2021, December 10). Human Rights Day: Declaration by the High Representative Josep Borrell on behalf of the European Union. European Council. 

‘Global Human Rights Sanctions Regime: EU sanctions four people responsible for serious human rights violations in Russia’. (2021, March 2). European Council.

‘Myanmar/Burma: EU imposes sanctions on 10 individuals and two military-controlled companies over the February military coup and subsequent repression’. (2021, April 19). European Council.

‘Myanmar/Burma: EU sanctions 11 people over the recent military coup and ensuing repression’ (2021, March 22). European Council.

‘Myanmar/Burma: third round of EU sanctions over the military coup and subsequent repression’. (2021, June 21). European Council.

Radio Free Europe/Radio Liberty. (2021, November 30). ‘EU Readies More Belarus Sanctions Over Migrant Crisis, Document Reveals’.

Vock, I. (2021, November 17). ‘Exclusive: Svetlana Tikhanovskaya calls for tougher EU sanctions on Belarus’. The New Statesman.

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Coordinator - Tibet Team

Mandakini graduated with honours from the Geneva Academy of International Humanitarian Law and Human Rights. Her team analyses the human rights violations faced by Tibetans through a legal lens.

Kenza Mena
Team Coordinator -China

Kenza Mena has expertise in international criminal law since she is currently pursuing a last-year Master’s degree in International Criminal Justice at Paris II Panthéon-Assas and obtained with honors cum laude an LLM in International and Transnational Criminal Law from the University of Amsterdam. She also holds a Bachelor’s degree in French and Anglo-American law. 

Since September 2021, she has been the coordinator of Team China at GHRD, a country where violations of human rights, even international crimes, are frequently perpetrated by representatives of the State. Within Team China, awareness is also raised on discrimination that Chinese women and minorities in the country and, more generally, Chinese people around the world are facing.

Kenza believes that the primary key step to tackle atrocities perpetrated around the world is advocacy and promotion of human rights.

Aimilina Sarafi
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Aimilina Sarafi holds a Bachelor’s degree cum laude in International Relations and Organisations from Leiden University and is currently pursuing a Double Legal Master’s degree (LLM) in Public International Law and International Criminal Law at the University of Amsterdam.
She is an active advocate for the human rights of all peoples in her community and is passionate about creating a better world for future generations. Aimilina is the coordinator for the GHRD team of Pakistan, in which human rights violations of minority communities in Pakistan are investigated and legally evaluated based on international human rights legal standards.
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Alessandro Cosmo
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Alessandro Cosmo obtained his B.A. with Honors from Leiden University College where he studied International Law with a minor in Social and Business Entrepreneurship. He is currently pursuing an LL.M. in Public International Law at Utrecht University with a specialization in Conflict and Security. 
As GHRD’s E.U. Youth Ambassador, Alessandro’s two main focuses are to broaden the Defence’s reach within E.U. institutions and political parties, as well as mediate relations between human rights organizations abroad seeking European funding. 
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