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.