The paper investigates how the effectiveness of the European Union’s action and its accountability are tackled in the field of international sanctions regimes. This is particularly meaningful for sanctions targeting individuals and private companies, considering the negative outcomes that international sanctions have, sometimes even just indirectly, on both. While, on the one hand, the Court of Justice of the EU has expanded the right to claim damages that individuals might suffer from sanctions, the enactment of more general regimes (such as the Global human rights sanctions regime) might have adverse effects on those individuals’ defense rights. In this context, the Commission is in search of solutions to provide the Union’s sanctions with full effectiveness also by means of criminal procedural law tools.