Coinciding with the paralysis of the UN Security Council (UNSC) in recent years, nations are increasingly launching their own ‘autonomous’ regimes, like the UK, Australia, Canada, and New Zealand. These, and organisations like the European Union (EU), backfill some of the lacking supranational leadership. Nevertheless, inefficiencies arising from variations between imposers leaves demand for a replacement overarching body to direct Western sanctions. 

Given the dominance of the US and EU, perhaps there is no need for one? US sanctions de-facto direct the Western alliance, with many global firms to automatically complying with US prohibitions. Simultaneously, the EU bloc imposes half of its sanctions for its own foreign policy aims, separate to the half it derives from the UN. Nevertheless, these two do not comprise the full breadth of ‘allied’ states, and inconsistencies remain. 

Efforts have been made to harmonise listings, however, it remains the case that EU designations are not necessarily found on OFAC lists, and vice versa. The UK has implemented legislation to ‘fast track’ designations made by allied countries but neither this nor Britain’s Strategic Partnership with OFAC compares to a binding, formalised, pact. Existing arrangements lack codified resource sharing, hampering the cohesion and effectiveness of western sanctions due to the absence of a top-down and joined up approach.

Allied countries could commit to imposing a nominated nation’s sanctions as a solution. Unfortunately, a misalignment of interests makes this impractical. It is hard to see the UK signing away sovereignty on sanctions to the EU less than a decade after Brexit. Further, few countries would likely sign away their foreign policy autonomy to another country like the US without having a meaningful seat at the table or veto power, which limits sovereignty. Simultaneously, countries like the US may not want to devote resource to directing sanctions imposition outside their borders when they are already so extraterritorial. Finally, even if a set of countries did sign up for the convenience of enacting, enforcement and intelligence collaboration could significantly vary according to individual states’ priorities. 

Utilising an existing body which a range of EU, G7 and G7+ states already participate in could be a realistic solution. This must should address current shortfalls, particularly around resourcing. Therefore, the future of Western sanctions alignment on major global threats should be found in a well-funded organisation whose members are aligned in their objectives. With so few candidates for this role, it would not be surprising if the North Atlantic Treaty Organisation (NATO) is increasingly touted as a future sanctions sending body. 

NATO as a sanctions sending body could define Western-allied sanctions imposition. Sanctions are a vital tool in security and foreign policy but, as the case of Russia shows, their dispersal across different states has led to criticism of ‘scattergun’ approaches. This model brings five additional European countries (including some where circumvention has historically been a problem) around the table in a meaningful way. At the same time, this centralisation encompasses a broader set of nations who support using sanctions in response to global crises. NATO’s core members include Canada, the UK, the USA, and a number of EU members, as well as ‘partnered’ countries, like Australia, the Republic of Korea, Japan, and New Zealand. Proponents of this model therefore suggest that such supranational coordination would be even more effective than current efforts at the G7 level. 

Where enforcement is required, support for members with resource: human, financial, and intelligence, contributed from across its membership, would be a compelling advantage. NATO currently collaborates with domestic law enforcement agencies across its membership, providing much needed expertise and resource support. Expanding the organisation’s remit to include sanctions would allow enforcement action to depend less on individual economies whose entire GDP can often be dwarfed by the resource available to NATO. 

The infrastructure already exists for NATO to take a leading role in the imposition of Western sanctions. The third joint Declaration on EU-NATO cooperation (2023) places NATO at the heart of European security matters, with EU efforts as ‘complementary’. This is infrastructure found within the shared history of NATO where in 1949 NATO members established a coordination committee for the implementation of export controls. 

As the importance of sanctions increases to avert armed conflict and human rights abuses, the Western alliance may soon find itself opting again to centralise and delegate powers.