In the sanctions practice of the EU, human rights motivations feature prominently, reflecting their centrality to the Union’s foreign policy. This Brief discusses plans to create a new EU sanctions regime addressing gross human rights violations. It examines the various challenges surrounding the initiative and its implementation, and argues that the way forward could be to disaggregate the proposed sanctions regimes into two separate strands: one dealing with breaches of international humanitarian law and a second addressing human rights abuses linked to large-scale transnational corruption.