In the aftermath of the EU’s decision to include a human rights and democracy clause in all its external agreements academic effort has been devoted to understanding the EU’s behaviour in implementing the clause. The literature assessing the use of the clause has mainly followed the principles set out in the wider sanction-literature mostly remaining within the parameters of a rational choice perspective. Explanations vary around the claim that a strategic interest of the EU governs the choice of implementing a sanction in general, or the human rights and democracy clause in particular. This paper explores the extent to which the human rights and democracy clause is implemented towards ACP states and give an account for existing theoretical explanations for the variance. Furthermore, it will add nuances to the status quo understanding of the EU’s arbitrary use of sanctions towards third states assessing the explanatory strength of the EU’s strategic interest in target countries and the extent to which this interest governs the choice of implementation of a sanction.