ECFR asks Europe to prepare anti-corruption sanctions for the period after the Trump administration

Europe should keep information about controversial transactions concluded during the Trump administration, refuse funding for suspicious agreements, and strengthen its own anti-corruption sanctions regimes, argue two authors from the European Council on Foreign Relations. They propose that a future American administration should be able to quickly use sanctions against foreign individuals and entities involved in such transactions.

European governments should start documenting external transactions that could raise corruption issues during the current American administration and prepare for the possibility of coordinated sanctions with the United States after Donald Trump leaves the White House, argue two authors from the European Council on Foreign Relations. Sarah McCool and Jim O’Brien also propose strengthening European anti-corruption sanctions regimes and examining how bodies such as OLAF and the European Public Prosecutor's Office could cooperate with American authorities in such a scenario.

In short

1. The authors propose that the next American administration be prepared from day one to use anti-corruption sanctions against individuals and institutions outside the U.S. involved in transactions deemed corrupt.

2. Europeans could start keeping information about such transactions now, refuse their funding when European interests are involved, and strengthen their own sanctions regimes.

3. The analysis identifies relevant areas as the South Caucasus, the Western Balkans, Gaza, Russia, and Ukraine, where trade agreements and rights over land, infrastructure, or resources may subsequently influence political options.

4. The authors believe that investigations by journalists, civil society, European governments, and the American Congress could provide information for potential sanctioning decisions.

5. In the case of the EU, the analysis proposes examining cooperation between European rule of law instruments, bodies such as OLAF and the European Public Prosecutor's Office, and American authorities responsible for sanctions, without claiming that such cooperation has already been decided.

The proposal is made in a commentary published on August 10 by the European Council on Foreign Relations and signed by Sarah McCool, former special assistant, and Jim O’Brien, Distinguished Visiting Fellow of the organization. ECFR specifies that its publications express the authors' opinions and do not represent the collective positions of the organization.

The two authors start from the assertion that several foreign policy initiatives of the Trump administration have created or may create financial advantages for individuals close to American officials. They argue that some such arrangements may produce effects that will continue after the current administration ends and may limit the freedom of action of a future American government.

These assertions represent the assessment of the ECFR authors. The material does not present judicial conclusions that the described transactions have been established as acts of corruption and specifies that not every example of privileged relationship or transaction with individuals close to the administration can be demonstrated as corrupt.

One of the areas mentioned is Gaza. The authors believe that granting land rights or other assets to individuals close to the current administration could influence who will control properties and resources and could restrict the options of an American administration that would later want greater Palestinian involvement in the administration of the territory.

The analysis extends the same concern to agreements regarding minerals, infrastructure, and investments in other regions. The South Caucasus, the Western Balkans, Ukraine, Russia, and eastern Democratic Republic of Congo are mentioned among the areas where economic rights currently granted could create actors with strong interests against future policy changes.

The authors propose that an American administration succeeding Trump consider anti-corruption sanctions as an immediately available tool. The indicated legal basis is the American Global Magnitsky regime and the associated executive orders.

These tools allow for the sanctioning of certain foreign individuals involved in corruption, including by restricting access to the United States and the American financial system. The analysis focuses on individuals and institutions that are not American because the described mechanisms cannot be used in the same way against American citizens.

The authors consider this limitation relevant for situations where a transaction simultaneously involves American beneficiaries and foreign partners. Even if sanctions would not apply to the American beneficiary, they could affect the foreign companies, institutions, or individuals that participated in the transaction.

Such a mechanism could block the foreign partner's access to the American financial system and could create incentives for providing information about how the transaction was negotiated.

The material argues that sanctions would have an additional advantage over internal criminal procedures: they are not affected by the presidential power of pardon. The authors anticipate the possibility that individuals close to the current administration may benefit from pardons before the end of the term and believe that this could complicate any subsequent criminal investigations.

Neither is this situation presented as a fact already produced. It is one of the scenarios the authors use to explain why a future administration might consider sanctions as an available tool even when criminal procedures are difficult or contested.

Applying sanctions would require a sufficient factual basis. The authors propose that the process of preparing this basis should start before the administration change.

European governments could contribute by keeping information about transactions involving European companies, institutions, or funding. Journalists and civil society organizations could document the relationships between participants, economic beneficiaries, and how contracts, concessions, or rights over resources were granted.

The American Congress is identified as another possible source of investigations. The authors specifically mention the scenario in which Democrats gain control of one of the chambers after the midterm elections in 2026.

This development is presented as a political hypothesis, not as a known outcome. In such a scenario, Congressional committees could conduct investigations that would produce documents and testimonies useful to a future administration.

The authors also propose more immediate action from European leaders. They could publicly declare that they expect the future American administration to distance itself from transactions through which individuals close to officials gain economic advantages.

Such communication would aim to influence the behavior of potential partners of the Trump administration. The authors argue that the possibility of subsequent sanctions may alter the calculations of a foreign individual or company before they accept a transaction.

This deterrent capacity, however, depends on the credibility of the threat. If external actors consider it unlikely that a future administration will review agreements or impose sanctions, the preventive effect would be diminished.

For this reason, the analysis recommends that the discussion about sanctions begin before the administration change and be supported both in the United States and in Europe.

At the same time, the authors acknowledge the limitations of the tool. Sanctions do not represent a complete solution for all situations and may be inappropriate in some cases.

Establishing corruption can be difficult when transactions are presented as business decisions or legitimate agreements between states and companies. A person's relationship with a political official is not sufficient, in itself, to demonstrate the existence of a corrupt act.

The analysis provides as an example an alleged pressure exerted on the authorities in Kazakhstan to grant a mining concession to a certain American company associated, according to the authors, with individuals politically close to the Trump administration.

The authors argue that the American administration should analyze at the same time the funding of development and export of minerals. They believe that the circumstances justify an examination of how the company was selected.

These assertions are not presented in the material as conclusions of a court or an official investigation that established the existence of corruption.

Another example provided is Bosnia and Herzegovina, where the authors state that the United States supported granting a concession for a gas pipeline to a newly created American company.

The material describes the founders of the company as individuals without relevant experience in the field and mentions political connections with the American administration. The authors argue that Washington would have exerted pressure for the concession to be granted and for the departure of an international official who opposed the project.

In this case as well, ECFR uses the example to argue for the need to examine transactions, without presenting a judicial finding that the individuals involved committed acts of corruption.

Rights over minerals occupy an important place in the authors' analysis. They argue that the current administration seeks to grant such rights to preferred partners in regions such as Central Asia, Ukraine, and eastern Congo.

The raised issue is the long-term effect of concessions. A company that obtains rights for many years may become a relevant actor for any government that later tries to change economic, security, or reconstruction policy.

The same argument is applied to infrastructure and trade routes. The authors mention the possibility that individuals associated with the current administration may gain control over assets that will remain important after a political power change.

They believe that documenting the owners, contractual conditions, and the process by which such rights were granted would allow a future government to distinguish between legitimate trade agreements and cases that justify an anti-corruption examination.

The material also mentions Venezuela, where the authors anticipate that a potential democratic transition could face difficulties related to companies associated with the current American administration and their relationships with individuals remaining from Nicolás Maduro's regime.

This scenario is explicitly prospective. ECFR does not claim that a democratic transition in Venezuela has occurred nor that all the companies described would be involved in illegal activities.

The analysis also cites trade relations involving businesses owned by Trump. The authors mention a $500 million investment from a fund controlled by a member of the ruling family in the United Arab Emirates and state that, a few weeks after the transaction, the Emirates received a waiver for purchasing advanced chips.

Another example concerns a $50 million investment by a Chinese businessman in a crypto business owned by Trump and the subsequent resolution of his legal issues in the United States through a presidential intervention.

The material uses the succession of these events to argue the need to examine the links between public decisions and private transactions. However, it does not present in the text a judicial ruling declaring the respective transactions as acts of corruption.

In the perspective of a potential change in Washington, the authors believe that sanctions should be able to be applied quickly but remain subject to review as new information arises.

Such an approach would allow a new administration to adopt initial measures and modify them later when American institutions finalize their investigations.

The analysis assigns Europe a role both before and after a change of administration. European governments could keep documents and information about relevant transactions and could avoid financial participation in agreements they consider insufficiently transparent.

The authors explicitly indicate the South Caucasus, the Western Balkans, Gaza, Russia, and Ukraine among the regions where European interests may be affected by such transactions.

Europe could also strengthen its own anti-corruption regimes. Some European states already have national sanctioning mechanisms in this area, and the authors recommend that more countries consider adopting such tools.

For the European Union, the analysis proposes examining how initiatives regarding the rule of law and its investigative bodies could support future cooperation with American sanctioning authorities.

OLAF and the European Public Prosecutor's Office are explicitly mentioned. The authors do not propose transferring sanctioning powers to these bodies nor do they claim that they are currently preparing such operations.

OLAF conducts administrative investigations into fraud and other irregularities affecting the financial interests of the EU. The European Public Prosecutor's Office conducts investigations and prosecutions for crimes affecting the Union's budget in participating states.

The possible role suggested by the analysis concerns the investigative capacity and information exchange in situations where the facts fall within the competencies of European institutions.

The authors also propose resuming coordination between the European Union and the United States in programs aimed at reforming public procurement. Such programs could reduce vulnerabilities that allow for non-transparent awarding of contracts and concessions.

A European sanctions policy would have additional effects when coordinated with American measures. A foreign person or institution simultaneously sanctioned by the U.S., EU, and the United Kingdom could lose access to a much larger part of the international financial and commercial system.

The material does not claim that the EU or the United Kingdom have decided to participate in future American sanctions against the described individuals. This is the recommendation made by the authors for a subsequent political scenario.

Coordination would also involve legal differences between jurisdictions. Each sanctions regime has its own criteria, designation procedures, and possibilities for contestation, so the existence of an American measure does not automatically lead to the application of the same measure in the EU.

The authors acknowledge that a rapid application of sanctions may generate diplomatic difficulties. The targeted individuals may be important for other objectives of a future administration, and their governments may publicly contest the sanctions.

An administration that decides to postpone sanctioning an individual to protect another diplomatic relationship may be accused of double standards. Generalized application, on the other hand, may affect negotiations in areas without a direct link to corruption.

The material argues that these dilemmas should be analyzed before a new administration takes power. The recommendation is to prepare the necessary tools and information, not to automatically apply sanctions in every mentioned case.

The authors believe that the advantage of sanctions is flexibility. A designation can be introduced quickly when there is a sufficient basis and can be subsequently modified or lifted if new information arises.

This flexibility is presented as useful during a political transition period when a new administration may try to quickly change the foreign policies of its predecessor.

The proposed objective is to prevent individuals or institutions from using the economic rights obtained during the current administration to subsequently block changes regarding reconstruction, governance, infrastructure, or resource management.

The European Council on Foreign Relations published the analysis on August 10, 2026, in the form of a commentary. The document does not represent a decision of the European Union, a European government, or the American administration.

The proposals regarding sanctions for the post-Trump period are recommendations from the authors Sarah McCool and Jim O’Brien. ECFR specifies that the organization does not adopt collective positions through its publications.

Several examples presented in the analysis contain assertions regarding links between foreign policy decisions, companies, and individuals close to the Trump administration. The material also acknowledges that not all examples of insider dealing will be able to be demonstrated as corruption.

The central proposal is for Europe to use the coming years for documentation, protecting information, strengthening its own tools, and preparing for possible transatlantic coordination, so that a future American administration has information and sanctioning options immediately after taking office.