On the legal and evidentiary deficiencies of the European Union’s restrictive measures against Israeli civil society actors in Judea and Samaria.

Between April 2024 and May 2026, the Council has adopted three successive listings under the Global Human Rights Sanctions Regime targeting Israeli individuals and entities active in Judea and Samaria.

The following memo addresses the question of whether the listings comply with the standards the European Court of Justice has, since its Kadi ruling, required of every restrictive measure operating
as an individual sanction.