Recently，the number，scope and grounds of unilateral sanctions have continued to expand, which posed new challenges to international law. In the field of EU unilateral sanctions，the establishment of the EU global human rights sanctions regime reflects the transformation from country-based sanctions towards thematic sanctions as well as from comprehensive sanctions towards targeted sanctions. From a global perspective, this regime demonstrates the joint action in the form of autonomous sanctions taken by the EU and its allies on specific issues in the name of human rights and democracy. There has been longstanding debate on unilateral sanctions in international law. The EU has always argued that unilateral sanctions comply with international law on the basis that unilateral sanctions constitute countermeasures. However, as a thematic sanction, the EU global human rights sanction regime is different from countrybased sanctions, and the existing theory of countermeasures cannot provide the legal basis for it，neither can universal jurisdiction do so. The EU global human rights sanctions regime faces crises of legality, legal certainty and human rights protection, which may constitute international wrongful acts. On the one hand, states affected by sanctions can take countermeasures to safeguard their national interests. On the other hand, individuals or entities affected by sanctions can defend their rights through the EU judicial review mechanism.