Questions from Member Van Meijeren (FVD) to the Minister of Foreign Affairs on the EU sanctions regime

Questions from Member Van Meijeren (FVD) to the Minister of Foreign Affairs on the EU sanctions regime (submitted 12 January 2026)

Question 1
Are you aware of the article in the newspaper ‘De Andere Krant’ of 9 January 2006, “EU declares critics fair game”?¹

Question 2
Are you aware of Council Decision (CFSP) 2024/2643 of 8 October 2024 concerning “restrictive measures in view of Russia’s destabilising activities”?
Can you confirm that this decision provides for sanctions against natural persons, including EU citizens and residents, and not exclusively against states or foreign entities? How does this relate to the scope of Article 29 of the Treaty on European Union (TEU), which forms the legal basis for the decision and, as indicated by its inclusion in Title V of the TEU, concerns the Union’s external action and the Common Foreign and Security Policy?

Question 3
How do you assess the fact that recital 8 of this decision describes Foreign Information Manipulation and Interference (FIMI) as a “mostly non-illegal pattern of behaviour”, and that inclusion on the sanctions list therefore does not require a criminal offence or otherwise illegal conduct? Can you confirm that EU residents who do not engage in any illegal activity may, under this decision, be subjected to far-reaching sanctions such as travel restrictions (Article 1 of the decision) and the freezing of funds and economic resources (Article 2 of the decision)?

Question 4
How do you assess the fact that the decision does not provide for rule-of-law safeguards, such as the presumption of innocence, prior hearing of the person concerned, and substantive review by an independent court?

Question 5
Do you acknowledge that, if a natural person brings an action under Article 263 of the Treaty on the Functioning of the European Union (TFEU) against a sanctions decision, the Court of Justice of the European Union (CJEU) generally confines itself to reviewing procedural requirements and conducts only a marginal substantive review? How do you assess this lack of adequate legal protection for those affected?

Question 6
Are you aware of Council Decision (CFSP) 2025/2572 of 15 December 2025, by which, on the basis of the aforementioned decision, twelve natural persons and two entities were added to the sanctions list?

Question 7
How do you assess the fact that among the persons sanctioned under this implementing decision are journalists, scientists, academics, analysts and commentators, such as Jacques Baud, Xavier Moreau, Fyodor Lukyanov and Ivan Timofeev?

Question 8
How do you assess the fact that the “Statement of Reasons” for these persons largely consists of characterisations such as “acts as a mouthpiece for pro-Russian propaganda”, “promotes Kremlin narratives” and “justifies Russian actions”, without there being any demonstrable criminal offences or even any (financial) ties to the Kremlin? Do you acknowledge that, as a result, natural persons can be subjected to far-reaching sanctions purely and solely for expressing an unwelcome opinion that is not a criminal opinion? Do you share the view that this effectively shifts the scope of the sanctions regime from combating an external threat to disciplining expressions and viewpoints? How do you assess this in the light of freedom of expression?

Question 9
Are you willing to advocate within the Council for limiting the application of this sanctions regime to persons who are guilty of criminal or demonstrably violent acts? Are you also willing to argue that sanctions imposed on journalists, scientists, academics, analysts and commentators, in particular EU residents, who do not make criminal statements, should be lifted or avoided? If not, why not?

Question 10
Can you answer these questions separately and within the prescribed time limit?