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God Morgon

Geopolitics · Europe · Sweden · Türkiye · the economy
Background

How Europe pays for Ukraine, what it may do at sea, and what Washington would add

Europe pays for Ukraine with the interest on Russian reserves it has chosen not to confiscate. At sea it has a flag check under Article 110, which lets a warship stop a tanker but not keep it. Washington's contribution was tariffs of up to 100 percent on the five largest buyers of Russian oil and gas, signed into law on 18 September and waived by the president on 16 October, while drones hit shipping off Romania and Bulgaria.

On 16 October 2026 President Trump waived the Russia sanctions package he had signed into law on 18 September, telling Congress it was in the national interest. Europe's own instruments did not change with it: the interest on the frozen Russian reserves, 8 billion euros so far on the Commission's count, and a flag check at sea that can stop a tanker but not keep it.
How Europe pays for Ukraine, what it may do at sea, and what Washington would add

The Russian money Europe spends on Ukraine is interest; the reserves stay frozen. Cash accumulates at the depositories as the immobilised securities mature. The Council decided the net profits should go to Ukraine. On 3 August 2026 the EU received 1.4 billion euros, taking the total since immobilisation to 8 billion on the Commission's count. Of that, 95 percent helps Ukraine repay the EU's macro-financial assistance loan and the G7 ERA loans. The 90 billion euro loan agreed in December 2025 is separate borrowing, repaid only when Ukraine receives reparations.

The EU's 21st sanctions package, adopted on 23 July 2026, added 41 ships to the 632 already sanctioned, and the criteria now reach ships that service them. A listing shuts a vessel out of EU ports and services. At sea it stops nothing. Going aboard is the work of EUNAVFOR MED Irini, the EU's mission for the UN arms embargo on Libya, which was authorised in March 2026 to check tankers' flags. Its first such boarding, in early May, was an inspection of the ship's papers.

Article 110 of the UN Convention on the Law of the Sea lets a warship board a foreign ship only on reasonable suspicion of piracy, the slave trade, unauthorised broadcasting, statelessness, or a ship really of its own nationality. Sanctions enforcement is not on that list. Miro Sedlák calls a quarrel over nationality the surest hook the law offers, because any warship may board a stateless ship. Italy's defence ministry says its 2 August boarding of the Toa Payoh complied with the article, without naming the ground.

Washington aimed at Russia's oil revenue and then set its own law aside. Trump signed the Lindsey O. Graham act on 18 September, with tariffs of up to 100 percent on the five largest buyers of Russian oil and gas. The law gave him the authority, not the obligation. On Friday 16 October he waived the package shortly before it was due to take effect, telling Congress it was in the national interest. Earlier that month he had announced a diesel deal with Putin.

Kallas told the European Parliament on 20 October that vessels in the Black Sea had been attacked six times in ten days, a dangerous and unacceptable escalation in her words. Article 110 says nothing about drones. On Friday 23 October a drone struck the Comoros-flagged Khoryv 13 nautical miles east of Constanța. One sailor was killed, nine rescued and three still missing that day. The ship was just outside Romanian waters, and Romania's defence minister, Ștefan Radu Oprea, said the army may intervene only when drones enter its airspace.

”Article 110 gives a legal cause to act, but it does not give the right to confiscate a ship or try its crew.”
Miro Sedlákassociate research fellow, Institute for Central Europe

The numbers

The freeze, in the EU's own words
Council Regulation 2025/2600 of 12 December 2025, adopted under Article 122, paragraph 1, of the Treaty on the Functioning of the European Union, prohibits any transfer of Central Bank of Russia assets and reserves. Recital 26 says the accumulated cash balances do not belong to the bank and are not sovereign assets, and that the prohibition on transfers is temporary, reversible and under periodic review. Article 6 says the measures cease to apply once Russia ends its war of aggression, provides Ukraine with reparations sufficient for reconstruction, and no longer poses a serious risk to the Union's economy.
EUR-Lex
The loan Europe took out
In December 2025 the European Council agreed a 90 billion euro limited-recourse loan to Ukraine for 2026 and 2027, financed by EU capital market borrowing and backed by the EU budget headroom, to be repaid by Ukraine only once Ukraine itself receives reparations. The first instalment, 3.2 billion euros, was disbursed on 25 June 2026.
European Commission
The fifth transfer of the interest
€1.4bn
On 3 August 2026 the EU received 1.4 billion euros in interest on the cash balances arising from immobilised Central Bank of Russia assets. It was the fifth such transfer and covers the first half of 2026. The Commission states that since immobilisation the assets have generated 8 billion euros in all. 95 percent goes through the Ukraine Loan Cooperation Mechanism, which helps Ukraine repay the EU's macro-financial assistance loan and the loans G7 lenders made under the ERA initiative. The other 5 percent goes to the European Peace Facility.
European Commission
What a shadow-fleet listing does
+41 ships, July 2026
The EU's 21st sanctions package, adopted on 23 July 2026, listed 41 more vessels on top of the 632 already sanctioned. The measure is a ban on access to EU ports and a ban on receiving services. The listing criteria were widened at the same time to reach, for the first time, ships that provide services to the listed vessels.
European Commission
What Article 110 allows
Under Article 110 of the UN Convention on the Law of the Sea, a warship meeting a foreign ship on the high seas is not justified in boarding it unless there is reasonable ground to suspect piracy, the slave trade, unauthorised broadcasting, that the ship is without nationality, or that it is really of the same nationality as the warship. Sanctions enforcement is not among those five. The article does not govern interference deriving from powers conferred by treaty. Once a ground applies, the warship may verify the ship's right to fly its flag, and the article gives it no power to seize the ship.
United Nations
The mission that does the boarding
EUNAVFOR MED Irini was launched on 31 March 2020 under Council Decision 2020/472 to implement the UN arms embargo on Libya, with four original tasks: countering arms trafficking, gathering information on oil smuggling, disrupting the human smuggling business model, and training the Libyan institutions responsible for law enforcement and sea rescue. Council Decision 2025/488 of 11 March 2025 extended the mandate to 31 March 2027 and added a fifth task, maritime situational awareness. In March 2026 the mission was authorised to exercise the right of visit for flag verification under Article 110. Its first such boarding, in early May 2026, was on an oil tanker suspected of sailing under a false flag; it inspected the documents on board and reported what it found to the EU authorities. The mission's account does not say which of the article's grounds applied.
EUNAVFOR MED Irini
The boarding of the Toa Payoh
The Italian navy ship Thaon di Revel, serving with the EU's Operation Irini, boarded the Cameroon-flagged tanker Toa Payoh in international waters west of Pantelleria on Sunday 2 August 2026. The ship is under EU sanctions and is counted as part of Russia's shadow fleet. The Italian defence ministry's account says the boarding was carried out in full compliance with Article 110, took about two hours and had support from a Greek ship and a Polish patrol aircraft. The master did not cooperate at first, so an Italian team reached the vessel by helicopter. The account does not say which of the article's grounds applied.
Euronews
What the US Senate passed
On 7 August 2026 the United States Senate passed H.R. 5334, titled "An act to impose sanctions and other measures with respect to the Russian Federation, as championed by the late Senator Lindsey O. Graham, and for other purposes", by 86 votes to 11, with three senators not voting. The Senate passed it as amended, so the text it approved is not the text the House passed. Maggie Hassan of New Hampshire voted no.
United States Senate
The listings renewed, two names dropped
On 22 September the member states extended their individual sanctions on Russia for 36 months, where they had been renewed every six months. The compromise dropped two names: Alisher Usmanov at France's request, and Mikhail Fridman after Slovakia vetoed his continued listing. More than 2,600 people, organisations and entities remain listed. Latvia had blocked the deal on 21 September and relented the next afternoon with a constructive abstention, which supplied the unanimity.
Euronews
The law Washington signed
up to 100 percent
Trump signed the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026 on 18 September. The Senate passed it in August and the House on 16 September, with 58 Democrats crossing party lines. It sanctions Putin, senior officials and oligarchs, Russian banks and financial institutions, the energy and defence sectors and the shadow fleet of tankers, and it gives the president authority to impose tariffs of up to 100 percent on the five largest buyers of Russian oil and gas. The report expects it to fall hardest on China and India.
Al Jazeera
The Black Sea shipping attacks, 5 and 6 October 2026
A Turkish-owned cargo ship carrying Ukrainian grain sank off Romania with two killed, and Zelenskyy said Russian drones attacked it. The next day a merchant ship was attacked about 130 kilometres off Bulgaria's coast, one ship sinking and another damaged. A leaked EU defence readiness report, drawn up by the European Defence Agency, says critical gaps remain in naval munitions and missile stockpiles. A Commission spokesperson, Christian Wigand, put the EU's work in the region at 65 projects worth 200 million euros under its Black Sea Security Strategy.
Euronews
The executive order that waived the law, 16 October 2026
Trump signed an executive order on Friday 16 October 2026 waiving the new package of sanctions and tariffs on Russia shortly before it was due to take effect, telling Congress it was in the United States' national interest. The package came from the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026, which he had signed into law in September, and had sought to sanction Russian government and military officials, major banks and shadow-fleet vessels, and to impose duties on Russian goods and on goods from countries still buying Russian oil and gas. Kirill Dmitriev, the Russian presidential envoy, called putting the sanctions on hold a significant and truly historic moment.
Euronews
The diesel deal, in Trump's own numbers
3,000,000 tons
Writing on his Truth Social account, Trump said it was agreed that Russia will immediately supply over 300,000 tons of diesel fuel to the American and global marketplace, another 500,000 tons during the month of November, and 1,000,000 tons immediately thereafter, and that Russia will then deliver 3,000,000 tons within a short period of time, based on the condition of its refineries. The stated aim was to bring down fuel prices ahead of the United States' midterm elections.
Euronews
The Khoryv, 13 nautical miles off Constanța, 23 October 2026
A drone hit the Comoros-flagged Khoryv on the morning of Friday 23 October 2026, about 13 nautical miles east of Constanța, Romania's largest port. The ship caught fire and capsized. Romania's interior ministry said ten of the crew were recovered by another commercial vessel, nine alive and one dead, and that three others were still missing; the crew was ten Ukrainian and three Azerbaijani nationals. The attack fell just outside Romanian territorial waters, and Romania's defence minister Ștefan Radu Oprea said the army can intervene only when drones enter Romania's airspace. President Nicușor Dan called the attack a new example of the tragic consequences of Russia's aggression against Ukraine, and Euronews read that as Romania having determined that the attack came from Russia.
Euronews

What the comparison shows

Where they agree

Every voice here wants Russia squeezed harder. Albuquerque's Commission keeps adding sanctions packages, Sedlák's complaint about the boardings is that they achieve too little rather than too much, Hassan, who voted against the Senate bill on 7 August, says she supports sanctioning Russia, and Kallas and Zelenskyy both read the American easing as a concession given for nothing.

Where they split

The Commission's case rests on what Russia has spent: more than two thirds of the liquid assets in its sovereign wealth fund have gone since the war began, on the Commission's own count. Sedlák's case rests on what Russia still earns from oil, and on the tankers that sail away after a boarding. Hassan is arguing about a third thing, who pays for the American tariffs. Kallas and Zelenskyy answer the American easing differently: she says the sanctions Russia wants lifted are European decisions that nobody gives away for free, and he expects the easing to reach the frozen assets anyway.

What nobody is saying

When Euronews reported the boarding, the Italian authorities were still going through the Toa Payoh's documents, and the report does not say what happens to the ship next. Sedlák's charge, that nobody has built the legal grounds needed to keep a boarded tanker, gets no answer from the Commission, whose 21st-package announcement does not mention boarding at all. And nothing in the reporting here says what the waiver leaves of the tariff authority the September law created, or whether the easing, which Euronews says runs to April 2027, touches the immobilisation the interest transfers depend on.

Who says what

Maria Luís Albuquerque, European Commissioner for Financial Services and the Savings and Investments Union

Each package closes loopholes and tightens enforcement. Her Commission's account of the 21st package says more than two thirds of the liquid assets in Russia's sovereign wealth fund have been run down since the war began, and calls the Russian economy the weakest it has been since the war started.

”Our objective remains unchanged, to bring Russia towards meaningful negotiations and help create the conditions for a just and lasting peace for Ukraine.”Our objective remains unchanged, to bring Russia towards meaningful negotiations and help create the conditions for a just and lasting peace for Ukraine.
Source: European Commission · Thursday, 23 July 2026
Miro Sedlák, associate research fellow, Institute for Central Europe

French, British, Swedish and Finnish boarding parties have all taken control of shadow-fleet tankers, and most of the ships were freed shortly afterwards: the Boracay was released within days and by June 2026 carried Russian crude under a new name. Sedlák calls the operations tactical rather than strategic, and writes that Russia still earns more than 10 billion euros a month from oil exports, revenue that ship listings have not meaningfully cut. What is missing, he says, is the will to build durable legal grounds for condemning the ships and their cargo.

”Article 110 gives a legal cause to act, but it does not give the right to confiscate a ship or try its crew.”Article 110 gives a legal cause to act, but it does not give the right to confiscate a ship or try its crew.
Source: CEPA · Wednesday, 17 June 2026
Maggie Hassan, United States senator for New Hampshire

Al Jazeera relays a post by Hassan on X: she supports sanctioning Russia, but says she does not think tariffs, which are paid for by American businesses and consumers, will help Ukraine win. Critics of the bill, including her, say it hands the president too much power over tariffs.

Source: Al Jazeera · Friday, 31 July 2026
Volodymyr Zelenskyy, President of Ukraine

Zelenskyy reads the diesel deal as the first step in a chain. Ukraine cannot accept diesel deals, he says, because gas deals come next, and the easing then spreads to the banking system, to named individuals and to the chemical industry. He says there are risks around the frozen assets, whose interest is repaying Ukraine's loans, and that if he does not defend them through diplomacy nobody else will.

”After gas, sanctions will be lifted on other things. It will eventually extend to the banking system, specific individuals, and the chemical industry. And there are risks around the frozen assets.”After gas, sanctions will be lifted on other things. It will eventually extend to the banking system, specific individuals, and the chemical industry. And there are risks around the frozen assets.
Source: Euronews · Friday, 16 October 2026 · Said to the media in Brussels on Friday 16 October 2026, the same day as the executive order, and published by Euronews the next day. The wording is Euronews's rendering of the exchange.
Kaja Kallas, High Representative of the EU for Foreign Affairs and Security Policy

Kallas says American negotiators have spent nearly two years trying to push Ukraine into surrender, and that the reason it has not happened is European support. She wants Europe at the table to balance the White House's positions: what Russia wants, the lifting of sanctions, is a European decision, and she says Europe is not giving these things up for free. She accuses Russia of endangering Black Sea security with an armed blockade, refusing an energy ceasefire and stepping up its bombing before winter.

”Why Ukraine hasn't surrendered on Putin's terms is because Europe has been supporting Ukraine.”Why Ukraine hasn't surrendered on Putin's terms is because Europe has been supporting Ukraine.
Source: Euronews · Tuesday, 20 October 2026 · Said to the European Parliament in Strasbourg on Tuesday 20 October 2026, the same day a new round of talks was held in Oslo. The wording is Euronews's rendering.

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