On 9 October, three weeks after signing the first major Russia oil sanctions in two years, Donald Trump agreed with Vladimir Putin to bring Russian diesel back to world markets. The US Treasury suspended its sanctions on that trade until April 2027 the same day. In the two days before, Russian strikes had killed more than 80 Ukrainian civilians.
Europe answered on 12 October with its largest sanctions package yet: nearly 1,600 new listings, almost all in Russia’s military-industrial complex. Its core, says Ukraine’s sanctions envoy Vladyslav Vlasiuk, is Russia’s missile program and the electronics inside it, from capacitors to semiconductors. Six in ten listings came from Ukrainian proposals, and Brussels adopted them within weeks.
That is the right reflex, and proof that Europe can move fast when it chooses. But the package names companies and people one by one. On the measures that cut whole sectors, the ones that would hurt Moscow most, Europe still waits for Washington.
It waits for Trump to decide whether to enforce the Graham Act he signed in September. It waits for him to decide whether to lean on Hungary and Slovakia or let them off. It waits for the G7 to rule on tanker services before touching its own ships. Europe keeps asking the Trump administration to decide things it is perfectly able to decide itself.
If the EU is serious about ending a war on its own continent, it does not need a miracle from Washington. It needs to pull the levers already in its hands. Here they are.
Strip Russian weapons of European parts
1. Fix export-control enforcement on dual-use goods. It is unacceptable that the newest Russian drones and missiles contain not only Chinese parts but American and European ones. The "War and Sanctions" portal logs what turns up. The EU should find and close the enforcement gaps in its own dual-use export law. Choking the supply to Russia's war industry serves Ukraine and Europe alike.
Cut Russia's energy money
2. Force Hungary and Slovakia off Russian oil. The EU banned Russian oil imports in 2022, with temporary exemptions for landlocked states: Czechia, Slovakia, Hungary. Czechia has since diversified and dropped Russian oil entirely. Slovakia and Hungary can do the same; the Czech case proves it is a question of will, not feasibility. Ending the exemptions would also make good on REPowerEU's central promise, phasing out Russian energy. The gas-import ban is already decided. Oil is the gap that remains.
3. Close the Greek and Maltese tanker loophole. Up to 40% of Russia's seaborne oil travels on European tankers, Greek and Maltese. The EU has banned maritime services for Russian oil since 2022, with one exception: cargoes sold below the price cap. This spring the Council discussed scrapping that exception, which would have meant a full ban, then made any change conditional on coordination with the G7. Once again, Europe is asking Washington to act for it. The EU should overcome Greek and Maltese resistance and ban every maritime service for Russian oil: transport, insurance, and the rest.
4. Stop the shadow fleet in European waters. Russia ships oil to India, China, and Türkiye through a shadow fleet of aging, often uninsured tankers. Europe can check their insurance and turn away any that lack EU or G7 cover, especially in the North Sea and the Baltic, where any spill would be an ecological disaster, and an uninsured operator would not pay for it.
Patrols in territorial waters and exclusive economic zones have to be reinforced. Russia also uses these ships for espionage, sabotage, and damage to undersea infrastructure. Strengthen NATO's Baltic Sentry. Consider adding a maritime operation by the UK-led Joint Expeditionary Force or the Coalition of the Willing across the North and Baltic Seas and the Skagerrak, before the Danish straits. If the Russian Baltic Fleet escalates, Europe should be ready for confrontation. Moscow should hear that it is not feared and that it will be stopped. At sea, it is weaker than even NATO's Baltic Sea states alone, never mind NATO's European members together.
5. Scrap the Lingen nuclear-fuel deal. In July, Lower Saxony approved a plan for the French state company Framatome to make nuclear fuel jointly with Rosatom, Russia's builder of nuclear weapons, at Lingen. It is dressed up as serving REPowerEU, since the venture lets Hungary, Slovakia, and Bulgaria buy fuel from a Franco-Russian joint operation instead of straight from Rosatom.
This is nonsense. Ukraine was once wholly dependent on Russian nuclear fuel and diversified fast; Finland and Czechia have done the same. Hungary, Slovakia, and Bulgaria can follow. Stretching the dependence out and hiding it behind a French partner is the opposite of what REPowerEU is for. Lower Saxony's own environment minister called the deal "grundfalsch," fundamentally wrong.
Fund Ukraine from Russia's own money
6. Build a Ukraine Fund from frozen Russian assets. Supporting Ukraine will cost more next year, not less, so it is time to get serious about Russia's frozen assets. Not confiscation, which European capitals still resist, and not a simple transfer to Kyiv, which amounts to the same thing, but a dedicated EU-run Ukraine Fund that could invest these assets and use them better than they are used now. ICUV has set it all out in a policy paper.
Isolate Russia further
7. Adopt the Graham-bill sanctions. Sanction every Russian state company (majority or controlling state stake) and every Russian oligarch who has not taken a public anti-war stand. Forbes counts 155 Russian billionaires.
8. Cut every Russian and Belarusian bank off SWIFT. Russia still has 301 operating banks, yet only 103 Russian banks and financial institutions sit under the EU's transaction ban, and just a handful of Belarusian ones. Gazprombank, which the US Treasury says pays Russia's soldiers, is still not on the EU list. Stop listing banks one by one: disconnect the entire Russian and Belarusian banking systems and put them under a full transaction ban, with narrow exceptions for food, medicine, and humanitarian trade.
9. End land transit to and from Russia, Kaliningrad included. Stop all overland freight, rail and road, between the EU and Russia. Baltic ports should carry no Russian trade at all, not just grain. Halt the gas transit to Kaliningrad through Lithuania's pipelines, too; let it arrive by sea, where Russia already runs an LNG terminal. Winters are mild now, so the real effect is mostly higher costs, and even that is worth doing.
10. Ban visas for Russian (ex-)servicemen and their families. The EU's 21st sanctions package laid the legal basis in July and then set no start date. Bring it into force, and extend it to the families.
Deliver accountability
11. Launch the Tribunal for the Crime of Aggression and the Claims Commission. Speed up the creation of, and accession to, the tribunal for the crime of aggression against Ukraine, and the convention establishing a Claims Commission.
The point
Europe cannot escape this burden. A Russian victory, even a partial one such as a peace on Moscow's terms, would cost it far more than helping Ukraine to a partial victory of its own, a peace along the line of contact. If Europe wants the war to end, it has to lead, alongside Ukraine, instead of waiting on a miracle from the Trump administration. The tools are already in its hands.
Dmytro Shulga
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