Brussels has drafted its largest sanctions list. On Monday morning it could not agree to extend the ones it has.

Two items about European sanctions on Russia, both dated Monday 21 September.

In the morning, this desk published EU ambassadors failed to renew the sanctions on Monday morning; the extension runs to Tuesday.¹ Nothing had lapsed. Ambassadors ended a meeting without agreement, with a day left on the clock.¹

In the evening, the Kyiv Independent reported the contents of a document it had obtained. The European External Action Service has proposed adding 827 entities and 744 individuals to the bloc’s sanctions list — nearly 1,600 listings, which the outlet describes as the largest single package of listings to date.² Adoption by EU ambassadors is scheduled for 7 October, with the foreign ministers formally voting it through on 12 October.²

The same institution, sixteen days apart.

I want to hold those two facts against each other, because the gap between them is where the actual argument about sanctions lives, and it is not the argument that usually gets had.

Give it its due first, since the detail is genuinely more serious than a headline number.

Previous EU packages have gone at Russia across sectors — finance, fossil fuels — or have picked out high-profile figures.² This one specifically targets companies and executives involved in Russia’s defence-industrial complex: shipyards, aviation companies, electronics manufacturers, armoured vehicle repair facilities, aerospace companies.² It appears to fill gaps in the EU regime by picking up entities already sanctioned by the United States or other partners.²

And the stated reason for inclusion is the part worth pausing on. The EU document points to the fact that the Russian government has recently listed these entities as part of its own military-industrial complex, which entitles them to federal subsidies.²

That is an elegant piece of drafting. The evidentiary basis is the target’s own government’s paperwork. Moscow designated these entities as part of its military-industrial complex, a designation that entitles them to federal subsidies, and Brussels proposes to take that designation as its ground for listing them.² It is an awkward thing to be told you have been misidentified as part of a war economy by a government that is not your own, when your own has put you on that list.

For a measure like this, the evidence problem is usually the whole problem: proving that a particular electronics firm in a particular city is feeding a particular weapons line. Here the ground offered is the Russian government’s own designation.² I think that is the most intelligent thing in the document, and it would be worth saying on any day.

Which brings us back to Monday morning.

The individual sanctions in question came with a date on them: our own report gives a legal extension running to 22 September, and a morning meeting that ended without agreement the day before.¹ That is the shape of the thing. A measure with an expiry is a measure that has to be re-argued, on a date the sanctioned party can read as easily as anyone else. And a listing that expires has not been weakened. It has gone.

So the question that matters for the 1,600 is not whether they are well chosen. On the Kyiv Independent’s account they are well chosen.² The question is what happens to them at renewal, given that the existing measures went to a Monday morning meeting and came out of it unagreed with a day remaining.¹ Adding to a list is the part that gets announced. Keeping the list is the part that has to be done again.

I am not sneering at the difficulty. Unanimity among that many governments is a hard thing and the alternative designs are all worse. But an honest account of this proposal has to hold both halves: a smarter list, and a renewal of existing measures that reached a morning meeting without agreement and a day to spare, published within hours of each other.¹

There is a detail near the end of the report that reads to me as an admission, and I offer that reading as mine.

Once this package is adopted, the Kyiv Independent reports, the EU intends to move toward a more agile approach: adopting smaller lists on a rolling basis rather than bundling them into a single package.²

Consider what that is conceding. The method that produced a twenty-first package in July — targeting drone manufacturers, ship-servicing crews, oil refineries and cryptocurrency platforms — and that is about to produce one of nearly 1,600 listings in October is being changed by the people who built it, immediately after they use it one more time.² The stated direction is smaller and more frequent.² I read that as an institution that has decided the single large bundle is not the shape it wants, and I offer the reading as mine; the report gives the intention, not the reasoning.

Three dates and one absence, all of them checkable.

7 October, when ambassadors are due to adopt the listings, and 12 October, when foreign ministers are due to vote them through.² Watch whether both dates hold.

Then watch the extension that was still unagreed on Monday morning, with its own deadline the following day.¹ The package is the visible half of the policy. The extension is the half that has to keep being done, and it was the one in difficulty.

The absence is the names. The outlet has chosen not to publish any of the listings so as not to help Russia evade the EU’s sanctions efforts.² I think that is the right call by a newsroom and I want to be plain that it leaves this column, and every other one written from the document, unable to check the most important thing about a list: whether the right names are on it.

So the ledger. A proposal exists to add 827 entities and 744 individuals, scheduled for 7 and 12 October, and the Kyiv Independent calls it the largest single package of listings to date.² The entities are there because Russia’s own government recently listed them as part of its military-industrial complex.² And on the morning of the day that document was reported, the same bloc’s ambassadors ended a meeting without agreeing to extend measures already in force, with the extension running out the next day.¹ Adding names is a decision taken once, in a package with a date on it. Extending them is a decision taken again, on a deadline somebody else can read — and it was the extending, not the adding, that was in trouble on Monday.¹