In December 2020, the European Union (EU) rolled out a human rights sanctions regime, emulating the US Global Magnitsky Act. It constitutes the third horizontal sanctions regime adopted by the EU over the past three years. The organising logic of horizontal blacklists, almost alien to the Common Foreign and Security Policy (CFSP) until recently, fits well the targeted nature of the EU sanctions because it de-links the designation from an international crisis. However, it highlights the existence of a number of challenges that might potentially hinder the smooth application of the sanctions, or the overall success of the EU's policy approach. Three key issues with political implications are singled out: the overlap between horizontal and country-label listings, the non-enforceability of visa bans, and the partial nature of sanctions alignment with liked-minded countries.