Lobbying sanctions? How private actors respond to EU restrictive measures

Sanctions against third states have become a frequent tool in European Union (EU) external relations. Financial and economic sanctions interrupt trade and incur distributive consequences in EU member states and among their domestic actors. Recent scholarship therefore investigates the extent to which domestic, private actors such as firms comply with restrictive measures. Yet, we know strikingly little about how private actors respond to EU policy-making on sanctions prior to their eventual adoption and implementation. Do they lobby EU decision-makers? Are they in contact with their national governments regarding restrictive measures? Do they influence the design of EU sanctions? These gaps in scholarly research stand in stark contrast to the abundant work on firms’ lobbying in other areas of EU policy-making such as trade policy. This paper fills this void and reports findings from a new survey with business groups on EU sanctions.