• UN sanctions are under increasing scrutiny as a result of heightened tensions among Security Council member states. In this Q&A, Crisis Group expert Maya Ungar explains why some governments are pushing to scale back these punitive measures as others fight to preserve their core elements

What is happening?

The UN Security Council’s readiness to impose economic sanctions, which peaked in the immediate post-Cold War era, has declined since then and could shrink even more in the year ahead. Article 41 of the UN Charter allows the Council to apply measures other than armed force to enforce its decisions, and sanctions are the chief measure it has employed for that purpose. Having invoked sanctions only twice during the decades-long deadlock of the Cold War, the collapse of the Soviet Union ushered in sweeping change. Eleven new sanctions regimes were established in the 1990s, including against Iraq, Rwanda and the former Yugoslavia. But then the momentum stalled, with only four new regimes having been set up over the last decade.

Increasing rivalry among the veto-wielding permanent members of the Council has inhibited the introduction of fresh sanctions, while the Council’s elected members have also been slamming on the brakes. Sanctions sceptics are set to gain further influence in 2025, when the Council’s composition will change, with Pakistan due to take the seat vacated by Japan. Given Islamabad’s close ties to Beijing and its tendency to question UN interference in matters that it considers the domain of sovereign states, Pakistan is expected to vote with China and Russia in many sanctions cases. That shift could mean that the U.S. and its allies will struggle to get the nine votes necessary to keep contentious sanctions regimes alive, unless they are willing to compromise more on the texts.

The pendulum has been swinging in this direction for some time. The UN now oversees fourteen active sanctions regimes, featuring to differing degrees arms embargoes, travel bans, assets freezes and other restrictions. There is a huge variety in this battery of measures and the scope of their targets, which range from jihadist groups and criminal gangs to nations suffering armed conflict. But UN sanctions are often not as successful as their supporters would desire, and experts on sanctions find that the regimes are rarely effective consistently.

Council members have long harboured qualms about the effectiveness and unintended consequences of sanctions.

Council members have long harboured qualms about the effectiveness and unintended consequences of sanctions. But in recent years, China, Russia and the Council’s three African members (the A3) have sought to narrow or dismantle existing sanctions regimes and – with the exception of those introduced for Haiti in 2022 – avoid the creation of new ones. This change is primarily a consequence of rising geopolitical tensions among China, Russia and Western powers, but a growing willingness among African Council members to challenge the imposition of sanctions on their continent has also played a part. In contrast, the bulk of other Council members, including the U.S., the UK and France, still argue in favour of sanctions as a means of putting pressure on recalcitrant governments, signalling international disapproval and reducing the flow of arms and funds to conflict parties. 

Agreements on maintaining and updating sanctions are likely to be difficult in the future, with contentious measures such as the UN arms embargoes on South Sudan and Libya (both set to expire in May 2025) at particular threat of closure. These moves appear to mark the decline of yet another arena for international cooperation. At a time when other approaches aimed at quelling conflict – including mediation and peacekeeping – are also under rising pressure, the multilateral system’s ability to speak with one voice on matters of peace and security stands at risk of further erosion.

Why the surge in scepticism?

Sanctions face several kinds of criticism. First, the most influential states among the sceptics, Russia and China, often decry UN sanctions that they do not like as instruments of Western power. There is no doubt that the heyday of UN sanctions coincided with the post-Cold War peak of U.S. influence at the UN, and Western states still drive a great deal of the sanctions diplomacy in New York. Indeed, Britain, France and the U.S. are the penholders (diplomatic leads) on twelve of the fourteen active regimes. Secondly, in some instances – as in the case of economic measures against North Korea – Beijing and Moscow claim that UN sanctions complicate their efforts to reduce tensions with designated countries and result in collateral harm to civilians.

Thirdly, a number of sceptics (including Russia, China and some of the Council members from the so-called Global South) see sanctions as an infringement upon sovereignty. Some of the detractors, including Chinese and Russian officials, tend to draw a theoretical distinction between UN sanctions – which they deem the only legitimate form of economic coercion – and “unilateral coercive measures” introduced by individual states, which they say run afoul of international principles of non-interference. In practice, however, they tend to regard the distinction between the two as somewhat blurred, suggesting that even sanctions blessed by the Council may impinge on sovereign rights. Similar misgivings are espoused by African diplomats, who are often aggrieved that Western counterparts on the Council do not consult them properly regarding the effects of UN sanctions on targeted countries and regions in Africa. They argue that African regional organisations should be in the driver’s seat as regards multilateral engagement with each country. UN sanctions, they add, should be seen as part of that larger strategy. This stance reflects the A3’s growing confidence and readiness to shape Council debates concerning the continent.

Recent events have also served to fuel opposition to sanctions. Since Russia’s all-out invasion of Ukraine, Moscow has become much more willing to disrupt UN sanctions regimes that harm its friends’ interests. Moscow privately threatened to veto the 2023 renewal of Council sanctions on Al-Shabaab, the Islamist insurgency in Somalia, unless the UK agreed to delete a brief in-text reference to Eritrea. Russia had not objected strongly to the same reference to Eritrea before – such wording had appeared in the resolution each year since 2009 – but it changed its mind once Asmara began aligning with Moscow in General Assembly votes on the war in Ukraine.

Russia has also been keen to undercut UN sanctions that shed light on its own misdeeds. In August 2023, Russia single-handedly blocked the renewal of UN sanctions on Mali, arguing that the Malian government had requested the lifting of these measures. Western diplomats, however, interpreted the Russian move as retaliation against the UN panel monitoring the sanctions’ implementation, which had documented cases where the Russian private military company Wagner was involved in conflict-related sexual violence. In March, Russia also blocked the mandate renewal of the panel monitoring sanctions on North Korea, partly to pre-empt criticism of its use of North Korean weapons in Ukraine and partly as a signal of support to Pyongyang.

The division between supporters and opponents of sanctions on the Security Council is not always as rigid or clear-cut as it may first appear.

That said, the division between supporters and opponents of sanctions on the Security Council is not always as rigid or clear-cut as it may first appear. Western diplomats are quick to chide Moscow for leniency toward its favoured countries, although diplomats from the so-called Global South point out that Washington, London and Paris are guilty of meting out the same preferential treatment. Nobody believes, for instance, that Washington would allow penalties to be imposed on Israel for failing to comply with two recent Security Council resolutions calling for a ceasefire in Gaza, even though several UN member states would back such a move. UN watchers with long memories also recall that the UK, after helping to draft the arms embargo on Sierra Leone, was accused of breaking it in 1998, when a British firm was caught supplying weapons to rebel forces in violation of the restrictions.

Meanwhile, even the supposed sceptics are not consistent in their opposition. China, Russia and the A3 are regularly the most critical of UN sanctions, but in some cases, they give their backing. China and Russia, for example, generally support sanctions targeting jihadist groups, and they mostly follow the lead of African states on issues related to their continent (the African Union (AU) has at times been willing to impose sanctions on its own members). Pakistan is likely to be similarly supportive of sanctions in these areas.

On the Security Council, African members often vote with China and Russia on sanctions debates related to the continent, though they do not always share those powers’ viewpoints. African diplomats tend to oppose specific provisions, particularly arms embargoes, that in their opinion impede military efforts to protect civilians. The A3 frequently, though not always, backs calls from affected states to water down or eliminate these provisions. Some Council members grumble that the A3 blindly parrot these negotiating positions out of a sense of regional solidarity. But the A3’s rejection of Mali’s pleas to terminate sanctions in August 2023, and Ghana’s decision to split with the A3 in June 2022 to renew the Council’s arms embargo on South Sudan, show that the neighbourhood is far from unanimous in turning its back on UN sanctions.

Overall, however, these nuances in member states’ stances are increasingly cited by UN watchers as exceptions to a trend of greater confrontation between Western states and their adversaries and critics on the issue. Even when China and Russia do back new sanctions, they tend to do so with mixed motives. Beijing pushed for creating a new Haiti sanctions regime in 2022 – the Council’s first in more than five years – which targeted affiliates of criminal gangs. But China’s endorsement was less about a shift in how it views the merits of UN sanctions and more about advancing its own priorities. Haiti is one of the few countries that maintains diplomatic relations with Taiwan, and it is an open secret that gangs in the Caribbean nation obtain weaponry from Florida. Beijing likely saw UN sanctions as a way to cause headaches for both Port-au-Prince and Washington without sparking serious diplomatic backlash, especially in light of U.S. support for these measures.

How are the sceptics trying to reshape UN sanctions regimes?

Even if China, Russia and the A3 harbour a shared mistrust of UN sanctions, they generally aim to weaken and limit UN regimes rather than erase them altogether. Russia’s veto over monitoring sanctions on Mali and North Korea was and remains an unusual move. More often than not, sanctions sceptics deploy subtler tactics, including watering down Council sanctions, withholding support for related Council resolutions, and interfering with their implementation and monitoring.

When it comes to diluting existing sanctions by removing arms embargoes, the A3 have had mixed success. In 2022, the A3 – backed by China and Russia – persuaded Western members of the Council to lift the requirement that the Congolese armed forces notify the UN when moving weaponry around the country. By contrast, China, Russia and the A3 (backed in 2024 by Guyana, which votes with the A3 on most African issues) have repeatedly tried and failed to dissuade the Council from renewing the UN arms embargo on South Sudan.

Sanctions sceptics who are unhappy with the outcome of negotiations on a resolution now commonly abstain on the resulting text. Abstention allows them to signal their dissatisfaction with a sanctions regime without obstructing it altogether. It may also flag a warning to others on the Council that a regime could break down in the future unless it is modified. China, Russia, the A3 and Guyana also all abstained in May on a resolution extending UN sanctions on Libya. In the cases of both South Sudan and Libya, the nine other members of the Council voted in favour – the minimum number of votes required for a resolution to pass. Pakistan’s arrival on the Council could flip the balance in 2025 votes.

“Sunset clauses” … create the need for renewal of a previously open-ended mandate.

The A3, China and Russia also favour introducing more “sunset clauses” into Council sanctions resolutions, which create the need for renewal of a previously open-ended mandate. Again, the results of this approach have been mixed. In 2023, the A3 and United Arab Emirates (which sat on the Council member in 2022-2023) persuaded other Council members to agree to a sunset clause on the Sudan sanctions regime; the sanctions will be up for renewal for the first time in September, although the war in Sudan has made monitoring nearly impossible. By contrast, the U.S. and its allies shut down a Russian proposal in March to put the currently open-ended sanctions against North Korea up for renewal as well.

Even when a sanctions regime is already in place, Council members still have the means to undercut its enforcement through diplomacy in New York. One way is to hinder monitoring and reporting of violations. Since the 1990s, the Council has often established independent Panels of Experts – made up of specialists on issues such as arms flows and finance – to track implementation of sanctions. These panels, which report to the Council’s respective committees for most sanctions regimes, often produce impressive quantities of information on breaches, including those linked to Council members.

Council members, however, can hamper the panels’ work by placing “holds” on the appointment of particular specialists, meaning that the position is left vacant. Press reports suggest that in 2021, Russia had concurrent holds on nominees for panels dealing with the Central African Republic (CAR), the Democratic Republic of Congo, South Sudan and Somalia.

Can reforms help reduce these divides?

Given the prevailing anti-sanctions mood among several Council members, diplomats from countries that still broadly support the use of these measures have looked for ways to improve them and bridge the gaps in opinion. Though progress has been arduous, they have had some success in pursuing cross-cutting reforms to UN sanctions regimes that may eventually help reduce tensions in the Council. In 2022, the U.S. and Ireland championed a ground-breaking Security Council resolution establishing humanitarian carve-outs for all sanctions regimes that include asset freezes. These carve-outs affirm that providing humanitarian aid, or the goods and services aid workers need to deliver it, is not a violation of the Council’s asset freeze measures. In July, diplomats agreed to another reform, adopting a new resolution that clarified the Council’s rules on the complex process of “delisting” individuals who are under UN sanctions and resurrected an Informal Working Group on General Sanctions. Russia and China backed both of these resolutions, signalling their willingness to fine-tune the use of sanctions even as they bristle at their application in certain settings.

Another reform that has gained traction in the Council is the use of “benchmarks” in sanctions regimes. These indicators and targets, which often measure a country’s progress toward certain political or security goals, are meant to provide Council members with a yardstick for easing or altering sanctions. They also provide sanctioned entities with a path to follow if they want their sanctions eased. Five of the UN’s fourteen active sanctions regimes now include benchmarks.

Inserting benchmarks into UN sanctions resolutions is likely to become standard practice as a way to keep Council members – and affected governments – from rejecting the regimes outright. Recently, Council members agreed to include a range of benchmarks in the Haiti sanctions, such as progress in judicial capacity building, to serve as a roadmap for easing the measures. This provision was in part an acknowledgement of the fact that many Haitians have little trust in the Security Council due to the scandals that tainted the last UN peacekeeping mission to the country. The hope is that greater transparency in the conditions for imposing and lifting sanctions will help boost their legitimacy.

[A] gradual shift in UN practice is the increasing use of designations targeting non-state actors rather than governments.

Another gradual shift in UN practice is the increasing use of designations targeting non-state actors rather than governments. Diplomats differ as to the reason for this change, with some regarding it as a reflection of the realities of modern conflict while others see it as a response to lobbying by affected governments, backed by friends on the Council. In one instance in 2023, the Council lifted the arms embargo on Somalia and imposed it instead on Al-Shabaab and other terrorist groups, the result of reporting by the Secretary-General on progress on benchmarks as well as constructive discussions between the penholder (the UK) and the Somali government. Similarly, the arms embargo on CAR was unanimously lifted in July and replaced by restrictive measures on armed groups and associated individuals after lobbying by the government. Diplomats expected the negotiations to be contentious, given the difficult parleying that has plagued the last few renewals. But France, serving as the penholder, introduced a draft text proposing the lifting, likely due to its warming relations with CAR.

The Council’s recently resurrected Informal Working Group will offer diplomats a dedicated space to discuss additional reforms to UN sanctions. The group is mandated to cover a wide range of overarching issues but not to negotiate on any individual sanctions. One immediate focus may be bridging divides among the Council’s African members. The Working Group could develop regular interactions with the AU Peace and Security Council’s newly created Sanctions Sub-Committee – which will support the AU’s decisions in this area and by extension those of the A3 – on the goals of sanctions, as well as the terms for adapting and easing them. Diplomats also indicate that the Working Group could be a useful means of encouraging benchmarking as a cross-cutting practice in UN sanctions regimes.

It may nevertheless be difficult to isolate this forum from the politics shaping other sanctions debates. China and Russia have already signalled that they want to use the Working Group to discuss the humanitarian impact of UN sanctions, which diplomats suggest may be a pretext for challenging specific measures.

What are the future prospects for UN sanctions?

Future clashes between the Security Council’s sanctions sceptics and supporters appear inevitable. Given the geopolitical tensions impinging on much of the Council’s work, it seems implausible that the U.S. and other Western powers will regularly find common ground with China and Russia over the use of sanctions in the near term, even with forums like the Informal Working Group in place.

Council members that back sanctions still believe these measures can help shape the calculations of parties engaged in armed conflict by isolating groups and individuals fanning the flames, reducing flows of money and weapons to war zones and providing incentives for parties to come to the table. As Crisis Group has previously argued, the UN arms embargo in South Sudan, while imperfect, resulted in some legitimate weapons dealers bypassing the country while also preventing the rearming of rival groups. Crisis Group has also previously noted that the 2009 arms embargo on North Korea led to the seizure of some weapons en route to the country, though these sanctions did not stop development of the nuclear program. Even so, the diversity of sanctions and their targets as well as the daunting challenges posed by conflict-affected zones mean that successful enforcement is far from assured. There is also little doubt that UN sanctions have at times obstructed peace efforts and caused humanitarian harm. The UN’s comprehensive sanctions on Iraq in the 1990s, for example, had devastating consequences for the population, increasing levels of hunger, malnutrition and disease. The resulting outcry resulted in the Council introducing reforms to make all UN sanctions targeted, in an attempt to prevent any repeat of these ill effects.

The reforms now under way or up for debate may help allay some of the weaknesses that UN sanctions regimes have exhibited. They might also curb the resistance of sceptical states. But they are unlikely to guarantee that sanctions are effective wherever they are introduced, and will do little to mend the discord in international relations that has helped make these and other multilateral measures so controversial. The weakening of yet another mode of global cooperation in peace and security is a symptom of a more general breakdown in trust, whether among geopolitical rivals like Russia, China and Western powers or, to a lesser extent, between countries of the Global South and richer nations. Sanctions are not consistently effective, but their disintegration without a better alternative on the horizon bodes poorly for the Council’s ability to maintain peace and security.

@International Crisis Group (ICG)