Daniel Tannebaum Talks Russia Sanctions

Summary

Bloomberg Talks: Daniel Tannebaum Talks Russia Sanctions

Date: October 1, 2025
Host: Bloomberg Radio Host (Stephen)
Guest: Daniel Tannenbaum, Global Anti Financial Crime Practice Leader, Oliver Wyman
Theme: The status and effectiveness of Western sanctions on Russia, enforcement challenges, and the shifting geopolitical sands post-invasion of Ukraine.

---

Episode Overview

This episode features an in-depth discussion with Daniel Tannenbaum, a leading expert on anti-financial crime, regarding the effectiveness and future of sanctions imposed by the European Union and the US on Russia. With the EU set to announce a new, 19th round of sanctions, the conversation centers on whether further pressure is possible, the transatlantic divide on enforcement, and the challenges of targeting third-party countries like China and India.

---

Key Discussion Points & Insights

1. Effectiveness of EU and US Sanctions Regimes

• Current Impact & Limitations:
  • Tannenbaum emphasizes that enforcement—a vital aspect of any sanctions program—remains sorely lacking in both the US and Europe, despite the numerous packages imposed since the 2022 invasion.

    “Enforcement has largely been lacking, not just from Europe, but from the US and UK as it relates to all of the earlier sanctions.” — Daniel Tannenbaum (01:17)

  • He notes a divergence in approach: The US under the Trump administration appears more focused on tariffs than fresh sanctions, possibly due to tariffs generating revenue, unlike sanctions.

2. Shifts in US Policy Under President Trump

• Lack of New Sanctions:
  • According to Tannenbaum, the Trump administration has imposed “absolutely zero new sanctions on Russia” since taking office, focusing instead on symbolic or unrelated targets such as the International Criminal Court and officials outside Russia.

    “There have been no sanctions on Russia in nine months... It is a real question of what the President wants to do.” — Daniel Tannenbaum (02:16)

  • A much-touted sanctions package targeting Russia’s “shadow fleet” (oil transport network) has been ready for months, but not signed.
• Negotiation Over Enforcement?:
  • The administration's rationale, says Tannenbaum, is that sanctions could hinder negotiations with Russia—a justification he finds questionable given continued Russian aggression in Ukraine.

3. The European Union’s Response and Autonomy

• EU Taking the Lead:
  • With tepid US action, the EU feels compelled to be “out in front” with sanctions and must focus on educating member states and companies about enforcement.

    “The EU will continue to need to be out in front, and it really does need to educate the bloc in how to effectively enforce and police these sanctions.” — Daniel Tannenbaum (03:28)

• Coordination Opportunities:
  • Recent, “real meaningful discussions” between US and EU officials (notably David O’Sullivan) suggest the first real thaw in months.

4. Role of Third Countries: India and China

• Oil Trade Still a Lifeline for Russia:
  • Russia’s economy is under pressure, but oil exports to India and China help sustain war financing—these countries have not yet felt pressure to distance themselves from Russian energy.

    “…until you begin to get India and China to kick their Russian oil habit, it is difficult to really disrupt the flow of funds that they're getting to finance this war in Ukraine.” — Daniel Tannenbaum (04:18)

• India as a Real Pressure Point:
  • The US has focused its pressure on India rather than China, as ongoing trade negotiations with China make sanctions trickier.

5. Time Lag in Sanctions Impact

• No Precedent for Sanctioning a Major Economy:
  • Tannenbaum reminds listeners there’s never been an effort to sanction an economy as large as Russia’s; immediate results were never realistic.

    “Any thought that the sanctions would so immediately impact them were always a bit of a misnomer...” — Daniel Tannenbaum (05:01)

  • He points to recent EU moves on liquefied natural gas (LNG) as meaningful but emphasizes that it takes time to isolate and affect such a large economy.

6. Corporate Compliance and Enforcement Gaps

• Sanctions as a Deterrent:
  • Many Western companies left Russia post-invasion, but some European firms remain, as certain activities aren’t technically illegal. Without robust enforcement, companies feel little pressure to make the ethical or “existential” choice to exit.

    “…without enforcement that was so famously done for sanctions evasion related to Iran and Libya and Cuba and North Korea...they don't feel the pressure to make that choice either.” — Daniel Tannenbaum (05:56)

• EU's Opportunity:
  • Europe could learn from the US playbook (e.g., OFAC—the Office of Foreign Assets Control) and develop unified enforcement to ensure compliance.

7. Structural Challenges in the EU

• Lack of Centralized Sanctions Enforcement:
  • The US has OFAC; the UK comes close; the EU and member states do not. This lack of central authority hinders effective enforcement.

    “European sanctions haven't been that big a deal historically... In the US we've had the Office of Foreign Assets Control, a singular agency tasked with administering and enforcing sanctions. There is no equivalent in Europe.” — Daniel Tannenbaum (06:55)

---

Notable Quotes & Memorable Moments

• On Enforcement Gaps:

  “Enforcement has largely been lacking, not just from Europe, but from the US and UK as it relates to all of the earlier sanctions.”
  — Daniel Tannenbaum (01:17)

• On US Policy Shift:

  “My president seems to have fallen off on sanctions as of late and likes tariffs because they generate revenue.”
  — Daniel Tannenbaum (01:17)

• On the Absence of New Sanctions:

  “There have been no sanctions on Russia in nine months... He has had a sanctions package drawn up on the Shadow Fleet for months. He has not signed it yet.”
  — Daniel Tannenbaum (02:16)

• On Third Countries Role:

  “…until you begin to get India and China to kick their Russian oil habit, it is difficult to really disrupt the flow of funds...”
  — Daniel Tannenbaum (04:18)

• On Corporate Choices and Enforcement:

  “Without enforcement...reminding companies the consequences of getting this wrong, they don't feel the pressure to make that choice either.”
  — Daniel Tannenbaum (05:56)

• On EU’s Sanctions Structure:

  “In the US we've had the Office of Foreign Assets Control, a singular agency... There is no equivalent in Europe. There's no equivalent in any European country.”
  — Daniel Tannenbaum (06:55)

---

Timestamps of Key Segments

• 00:29–01:17 — Sanctions update and introduction to Daniel Tannenbaum
• 01:17–01:52 — Limits of sanctions enforcement and US/EU divergence
• 01:52–02:51 — Trump administration’s lack of action on Russia
• 02:51–03:19 — Political rationale for not imposing sanctions
• 03:19–03:28 — EU left to act independently
• 03:28–04:01 — US-EU transatlantic coordination and the EU’s role
• 04:01–04:53 — Russian economic strain and the India/China oil challenge
• 04:53–05:33 — Time lag and scale of sanctions impact on Russia
• 05:33–06:47 — Corporate behavior, enforcement, and Europe's structural issues
• 06:47–07:28 — EU's organizational immaturity on sanctions

---

Summary Takeaways

• The West’s sanctions arsenal against Russia is hampered by enforcement weaknesses in both the US and EU.
• The Trump administration has pivoted away from new sanctions on Russia, opting for tariffs and symbolic actions.
• The sustained purchase of Russian oil by India and China remains a critical loophole, limiting sanctions’ effectiveness.
• The EU is progressively taking the lead in the absence of strong US action but must develop more unified enforcement mechanisms.
• Corporate compliance continues to hinge on the risk of enforcement—without it, many firms see little reason to fully disengage from Russia.
• The lack of a centralized European sanctions body is a major policy gap to be filled in the coming years.

---

This conversation is a vital listen for anyone tracking sanctions policy, US/EU relations, and the evolving economic frontlines of the conflict in Ukraine.

Transcript

[Indiana University Announcer]

Indiana University is shaping the future of healthcare, advancing discoveries that become treatments for Alzheimer's, obesity, cancer and rare diseases and training the providers trusted to deliver them from the lab to the clinic. IU powers medical breakthroughs and the talent behind them. See how IU solves What's next iu. Edu Impact Bloomberg Audio Studios Podcasts Radio.

[Radio Host]

News Ukraine's president Volodymyr Zelensky says he expects a decision this week by the European Union on a new sanctions package on Russia. The measures, the 19th package would be expected to focus on entities in third countries like China and India, but the role of the United States will be key to make the measures work. Joining us now to discuss Daniel Tannenbaum, who is global anti financial crime practice leader at the consulting firm Oliver Wyman. Daniel, great to see us with the with us in the Brussels radio studio. You're here in the city for an Atlanta Council event that's happening later this morning with, among others, the EU sanctions envoy, David o'. Sullivan. So we appreciate having your perspective this morning. We're talking about this 19th package of sanctions by the EU on Russia. Is there much more pressure that can be exerted by the European Union at this stage on Russia and its economy?

[Daniel Tannenbaum]

There is, Stephen. And I think it's important to note enforcement is a key element of any sanctions regime. I say this as an alum of the US Government's sanctions age. Enforcement has largely been lacking, not just from Europe, but from the US And UK as it relates to all of the earlier sanctions. There's more sanctions that can be levied on third countries like India and China, although I do think there's a difference of view between the US and the EU on tariffing versus sanctions. My president seems to have fallen off on sanctions as of late and likes tariffs because they generate revenue.

[Radio Host]

Supposedly in terms of whether there is willingness in the Trump administration, I mean, it's interesting that you don't think that there's been enough follow through in Europe despite the concerns that obviously the EU and the UK have around Russia. Is there willingness, do you think? Is there anything changing in the Trump administration? It all does seem to depend on President Trump's attitude to Vladimir Putin.

[Daniel Tannenbaum]

Sadly, it does. And I think it's important to note the president has imposed absolutely zero new sanctions on Russia since he's taken office. There have been sanctions on the International Criminal Court. There have been sanctions on a Brazilian judge and the guy's wife. There have been no sanctions on Russia in nine months. And now you have a new strategy on secondary tariffs which didn't really exist before someone uttered it, I think, in April or May. It is a real question of what the President wants to do. He's had a sanctions package drawn up on the Shadow Fleet for months. He has not signed it yet.

[Radio Host]

So what should we read into that?

[Daniel Tannenbaum]

I think the argument that's been made is that sanctions will be an impediment to a negotiation with Russia. Well, then what are the missiles that keep being launched into Ukraine as it relates to Russia's continued aggression increasing only since the Alaska summit? I think there is a real question of why this President will not impose sanctions and the Senate will not impose them without the President's Go ahead either.

[Radio Host]

Where does that leave the European Union in all of this? We've got EU leaders gathering in Copenhagen in a couple of days. What do they do if they can't seem to get the supportive action that's needed out of Washington?

[Daniel Tannenbaum]

I think the only positive I can glean out of the last few weeks is David o', Sullivan, who I'm speaking with in a few hours, was in Washington with a delegation from the eu I think about two weeks ago. It was the first real meaningful discussion, as I understand it, the US And Europeans have had on Russia sanctions. But it means that the EU will continue to need to be out in front, and it really does need to educate the bloc in how to effectively enforce and police these sanctions as a meaningful reminder for companies who would be on the wrong side of this regime.

[Radio Host]

Having said that, if you look at the data on Russia's economy, I mean, there are fewer petrodollars expected by the Russian government, and obviously their war spending is increasing. So it is having some impact in terms of what Moscow is managing to gather.

[Daniel Tannenbaum]

There's no doubt it's having an impact. However, the trade, especially for oil between India, China and Russia is not insignificant. And those countries have not really felt the pressure to make a choice. Now, China, the US Kind of puts aside India is the one where the US has attempted to exert pressure over the last few months because it isn't focused as much on a trade deal like it is with China. But until you begin to get India and China to kick their Russian oil habit, it is difficult to really disrupt the flow of funds that they're getting to finance this war in Ukraine.

[Radio Host]

Do you think that we're any way close to that? Is there any sign that the Trump administration could move towards, particularly India? We know there's one. One entity has been been sanctioned.

[Daniel Tannenbaum]

Look, there's never been a country an economy the scale of Russia's that have been sanctioned. So any thought that the sanctions would so immediately impact them were always a bit of a misnomer that it will take time. Even the fact that the Europeans in this 19th package are willing to push up a year kicking LNG, that is meaningful. But it was always going to take time to isolate and really impact an economy of this size, which I do think you are beginning to see, judging by the taxation changes you're seeing reported out of Russia.

[Radio Host]

In terms of what that means. Means I'm trying to understand what this means for your clients. Then if you know we're talking about the ineffectiveness as you see it, of what the EU and what the US has done against Russia economically, how do your clients view then these sanctions efforts and how do you advise them? Surely they would be less concerned about doing business with Russia, or is that not the case?

[Daniel Tannenbaum]

So most of my clients have been out of Russia for years and abandoned ship pretty quickly after the invasion. Now there's a number of European clients that are still operating in Russia because it's not illegal. There's certain business that they can do. Now, should they be doing that? That's certainly the real existential question. Without enforcement that was so famously done for sanctions evasion related to Iran and Libya and Cuba and North Korea for years reminding companies the consequences of getting this wrong, they don't feel the pressure to make that choice either. And that is where Europe can really step up in administering and enforcing these sanctions a lot more aggressively within the bloc. Because that stick works to make companies feel the need to make a choice of things that could be on the border of legality.

[Radio Host]

What's the key change that needs to happen on that policy? Obviously the divisions among EU countries as well. What will be the most effective move that leaders could decide on now?

[Daniel Tannenbaum]

Well, some of it's a maturity issue. European sanctions haven't been that big a deal historically until this invasion in 2022. I don't take for granted the fact that in the US we've had the Office of Foreign Assets Control, a singular agency tasked with administering and enforcing sanctions. There is no equivalent in Europe. There's no equivalent in any European country. The UK is the only other country that has an equivalent. So it's a maturity of governments beginning to figure out who is on point to really enforce these sanctions and then getting on with it.

[Indiana University Announcer]

Essentially, how can you grow your business from idea to industry leader? Bring your vision to life with smart business buying tools and technology from Amazon, business from fast free shipping to In Depth Buying insights and automated purchase approvals. They deliver everything you need to achieve your goals. It's not easy to stand out from the crowd. Simplify how you stock up to get ahead. Go to amazonbusiness.com for support.