Questions and answers on new EU sanctions framework countering threats posed by migrant smuggling, trafficking in human beings, and organised crime

What is the aim of today's proposals?

The Commission and the High Representative are proposing a new horizontal sanctions regime, targeting certain serious illicit conduct. Sanctions would apply if such conduct originated from outside the EU and poses a serious threat to the values of the Union, the security of the Union and its Member States, or to international security. The aim of the proposals is to tackle the threats posed by migrant smuggling, trafficking in human beings, trafficking and other illicit activities related to drugs, illicit manufacture and trafficking of firearms, and money laundering. With this new sanctions regime, the EU will be able to freeze the assets of individuals and entities involved in such activities and restrict the entry of listed individuals into the EU. 

Why now?

In the face of global challenges related to migration and security, Europe must react in a decisive manner. Organised crime networks engaged in migrant smuggling, human trafficking, or other forms of organised crime pose a serious threat to our security, our economy, and the rule of law. The proposed sanctions regime was announced by President von der Leyen in the 2025 State of the Union.  

Which forms of organised crimes are addressed by these proposals? 

The proposals target migrant smugglers and traffickers given that today, too many people still cross the EU's borders illegally, lured by false promises made by smugglers and traffickers. Smugglers make millions in profits while putting people at risk when attempting dangerous journeys to reach the EU illegally. This is why new measures are needed to disrupt the business model of smugglers, restrict their movements, and cut off their profits. 

At the same time, breaking the business model of migrant smugglers and human traffickers requires a holistic approach. This is why it is necessary to look at the wider organised networks within which migrant smugglers and human traffickers often operate. In addition to targeting migrant smuggling and human trafficking, the proposals also target the illicit manufacture and trafficking of firearms, money laundering, and conduct related to trafficking of illicit drugs.

How will the new sanctions regime enhance existing EU action against organised crime?  

Criminal law proceedings and sanctions differ in scope and application. Sanctions are a Union tool in pursuit of its Common Foreign and Security Policy objectives. Sanctions are different in nature and separate from criminal law tools, and do not in any way replace criminal law. The new sanctions regime will be complementary to EU criminal law tools, for example on migrant smuggling, which is currently under negotiation in the Council, the revised framework on trafficking in human beings, or the modernised legislative framework against organised crime, which the Commission is currently working on. The new framework is without prejudice to criminal investigations or judicial proceedings. Its aim is to close loopholes by targeting migrant smugglers and human traffickers to freeze their assets, restrict their ability to move around, and cut off their profits.

The new sanctions framework aims to disrupt and deter certain conduct originating outside the Union that poses a serious threat to the values of the EU, its security or to international security. The measures imposed through sanctions are temporary and reversible. The goal is to disrupt and deter specific conduct that threatens EU or international security.

Will the proposals affect NGOs that carry out humanitarian work, for example in relation to migrants? Are the activities of NGOs exempted from sanctions? 

The proposals focus on illicit actions or policies originating outside the EU, which, due to their widespread, systematic or organised nature, pose a serious threat to the values of the Union, the security of the Union and its Member States, or to international security. 

It targets people and entities that are responsible for, contribute, support, or benefit financially from migrant smuggling, trafficking in human beings, and organised crime. It does not target migrants, asylum seekers, or persons in need of international protection. 

The proposals clarify that the restrictive measures will be without prejudice to any legitimate activities including humanitarian assistance provided in line with international law, support to victims of human trafficking, and to the provision of the basic human needs of migrants. 

Will these new sanctions apply also to third countries?    

Migrant smuggling, trafficking and other forms of organised crime are global challenges undermining societies and threatening the rule of law. The proposed measures do not target any specific country or region but rather target individuals and entities around the globe. The new measures provide the EU with an additional horizontal tool to address particularly serious forms of organised crime. This builds on the already existing cooperation with partner countries to step up the global fight against migrant smuggling and prevent dangerous journeys, including through the reinforced Global Alliance. The Commission will also continue to step up cooperation with interested partner countries in the fight against organised crime. 

Will these new restrictive measures be extra-territorial? 

As is the case for all EU sanctions regimes, EU sanctions do not apply extra-territorially. This means that only operators with touchpoints in the EU are bound to comply with EU sanctions. 

Are judicial safeguards respected?  

EU sanctions are adopted by the Council on the basis of clear legal criteria and robust evidence. Listed persons have the right to request a review of their listing by the Council and to challenge restrictive measures before the EU Courts.

What are the next steps?  

The proposals will be now discussed and reviewed by the Council. As with any sanction regime, its adoption by the Council requires unanimity.