A Russian operation to assassinate a dual American and Ukrainian citizen in Warsaw was stopped on 7 August. What made the case internationally legible was the American passport. Europe has no equivalent category, and it has spent two years building one for everything except people.

On 13 August Donald Tusk told journalists in Warsaw that Polish services had detained a Russian citizen six days earlier whose task was to carry out an execution in the capital. The intended victim held two passports, American and Ukrainian, and was, in the Prime Minister’s phrase, inconvenient from the point of view of the Putin regime. The arrest was made by the Internal Security Agency with the police, and the minister who oversees the Polish services, Tomasz Siemoniak, said the operation had been coordinated with American agencies throughout.

Tusk then said something more precise than the headlines that followed it. This was the first case, he said, in which someone acting on Russian orders had decided to attack an American citizen on the territory of another NATO country. Read that carefully. It is not a claim that Russia has begun assassinating people in Europe. It is a claim about which passport the intended victim was carrying.

Russian assassination plots, and how firmly each is documented

Russian state-directed operations against individuals on European soil are not new, and the strongest evidence for that is not intelligence briefing but a criminal file. In June 2020 German federal prosecutors charged a Russian citizen with the murder of a Georgian national shot dead in a Berlin park the previous August, and stated in terms that state agencies of the central government of the Russian Federation had tasked him with the killing and that he had accepted the assignment. Germany had already expelled two Russian diplomats over the investigation. That is a state-directed execution in an EU capital, established through a prosecution rather than a leak.

The pattern since has been documented with varying firmness. The firmest concerns Armin Papperger, who runs the arms manufacturer supplying much of Ukraine’s artillery: a plot against him, first reported in July 2024 on the account of unnamed officials, was confirmed publicly in January 2025 by NATO’s deputy assistant secretary-general for hybrid and cyber affairs, James Appathurai, before a European Parliament committee, who placed it in a wider campaign against defence industry figures. No prosecution has followed. Disrupted plots have also been reported in France, against the Russian exile Vladimir Osechkin, and in Lithuania, on official briefings that produced no public case files. In June a Kremlin critic, the Russian artist Robert Kuzovkov, was shot dead outside his home in eastern Poland; prosecutors have not attributed that killing to Russia, and Tusk said it had the marks of a political assassination.

So the novelty in the Warsaw case is not the conduct. Every element of it has happened before in at least four member states. The novelty is that this time the person in the crosshairs was American, and that fact mattered enough for a European prime minister to lead with it.

What the EU hybrid sanctions framework was built for

None of this took the Union by surprise. On 8 October 2024 the Council created a dedicated sanctions framework for Russian destabilising activity, Decision (CFSP) 2024/2643, covering sabotage of critical infrastructure, interference in elections, cyber operations, information manipulation and the instrumentalisation of migrants. The External Action Service lists assassination attempts among the hybrid activities the Union has observed. The instrument was not designed in ignorance of what was happening to people.

The first listings came on 16 December 2024, and they were pointed: sixteen individuals and three entities, among them GRU Unit 29155, which the Council described as known for its involvement in foreign assassinations and for bombings and cyber-attacks across Europe. That was the correct target, named correctly, for the correct reason.

The list has grown steadily since, through a broadening of scope in May 2025 and repeated additions, and was extended last October to run until 9 October 2026. At the Council’s own review of its published record on 13 July 2026, eighty individuals and twenty entities stood designated. The Council’s description of who they are is the part worth reading. The individuals, it says, include propagandists, television presenters and news anchors, editors of state-controlled newspapers, cultural figures, foreign-policy analysts, influencers and bloggers. The entities include media companies, fishing companies, the state broadcasting network and a journalists’ association.

That is not a complaint about any single designation. The propaganda apparatus is a legitimate target, and asset freezes and travel bans are real measures with real effects. It is an observation about the shape of the list rather than about anyone’s motives. Across the same period, plots to kill people were disrupted in France, Lithuania, Germany and Poland, and a man was shot dead in a Polish town. The list is not exclusively a media roster, and it would be wrong to say so: GRU Unit 29155 and serving intelligence officers sit on it, placed there in the first round. But that round was December 2024, and the composition the Council now reports is overwhelmingly informational. My characterisation, not the Council’s, is that a framework which opened by naming a unit known for foreign assassinations has since been built out mainly against people who broadcast.

Where EU victim protection law stops

There is a reason for that, and it is not cowardice. Attribution is the difficulty. A sabotaged cable or a manipulated broadcast leaves an evidentiary trail that can be assembled in Brussels and defended before the General Court. An assassination attempt produces a criminal file held by one member state’s prosecutors, subject to that state’s rules on disclosure, and normally unusable as the basis for a Union listing until the case has run its course. Sanctions law rewards what can be shown in a public document, and a live prosecution is the opposite of that.

It would be wrong to say the Union has built nothing for people at risk. Directive 2012/29/EU sets minimum standards on the rights, support and protection of victims of crime and requires an individual assessment of protection needs, with attention directed to victims of terrorism and organised crime. Directive 2011/99/EU on the European Protection Order, with Regulation 606/2013 beside it in civil matters, lets a national protection measure travel with a person who moves to another member state.

Look at what those instruments require. The European Protection Order presupposes a protection measure already granted at national level against an identified person causing danger, and what it carries across borders are bans on approach and contact. It was written for domestic violence and stalking, and the Commission’s own implementation report of 2020 found it barely used in practice. The Victims’ Rights Directive attaches to a person who is already a victim inside a criminal proceeding. Neither can attach to someone on the ground that a foreign government has decided to kill them, because in these cases the source of danger is a state, the person causing danger is a contractor nobody can name until afterwards, and the protection is needed before any national measure exists.

Osechkin, Papperger, the unnamed man in Warsaw and the artist at Biala Podlaska are, in Union law, four separate criminal matters in four jurisdictions. That is not for want of cooperation. Europol and Eurojust support cross-border casework, national services share what they hold, and the Warsaw operation itself was run jointly with a partner. What is missing is narrower and much harder to improvise. No Union instrument attaches to a person by reason of having been targeted by a foreign state, and so there is no threshold at which the fourth such person becomes the Union’s concern rather than the host state’s alone.

That absence is why the American passport did the work. A dual national of the United States and Ukraine, living in Poland, becomes internationally legible through Washington, because Washington has a doctrine about its citizens and the machinery to act on it. Europe’s answer to a person hunted on its own territory is the criminal law of whichever state they happen to be standing in.

Three steps inside existing EU competence

Three things follow, each inside a competence the Union already holds, though not all inside the same one.

1. First, the Council should use the October 2024 framework for what its own founding documents describe, listing those responsible for attacks on persons as readily as those responsible for attacks on cables and broadcasts, and accepting that the evidentiary standard for a listing has never been the standard for a conviction.
2. Second, Eurojust and Europol should hold a common file on state-directed attacks against individuals across the Union, so that the fourth plot is understood as the fourth and not as a first.
3. Third, rather than invent an instrument, the Union should extend the victims’ package it already has, to reach people targeted on its territory for their support of Ukraine or their opposition to the Russian government, with the practical content that follows: protection, residence, and a named institution responsible.

Here the legal ground has to be described honestly rather than waved at. Article 82(2) of the Treaty on the Functioning of the European Union permits minimum rules on the rights of victims of crime, and it is the base on which the Victims’ Rights Directive rests, but it permits them only so far as they facilitate mutual recognition and judicial cooperation in criminal matters with a cross-border dimension, and only within criminal proceedings. Protection and information duties can be built there. Residence cannot: the Victims’ Rights Directive confers no residence entitlement, and entry and residence belong to Article 79(2), in the immigration chapter, which is a harder political room. The opt-out position is the same in both places, since Protocols 21 and 22 cover the whole of Title V: Denmark stands outside it and Ireland decides case by case, which is why Denmark sits outside the European Protection Order already.

So the protective content has a clear home and the residence content has a home elsewhere and a steeper climb. Neither needs a new treaty on the face of the Treaties, though the exact reach of each base is the kind of question the Council Legal Service settles and the Court decides. The residence limb has a working precedent: Council Directive 2004/81/EC, adopted under what is now Article 79, already grants residence permits of limited duration to third-country nationals who are victims of trafficking. That precedent carries a warning as well as a permission, since it ties the permit to cooperation with the authorities and to the life of the proceedings. Article 82(2), for its part, reaches this case where there is a criminal proceeding to attach to, which there is once a plot is foiled and a suspect charged, and does not reach it where protection is wanted before any offence has been committed. The competences are in place and largely unused, which is a different problem from their absence, and a more embarrassing one.

Until then the honest description of European practice is the one Tusk gave without meaning to. A man was nearly executed in Warsaw this month, and the reason the continent noticed was that another country had a claim on him.

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Note on the record:
The reading of Tusk’s remark as revealing an absence in Union law is the author’s argument, not a claim about his intent. His statement is quoted for what it says, which is that the case was the first of its kind involving an American citizen on the territory of another NATO country.

The account of the Warsaw arrest rests on Tusk’s press conference of 13 August 2026. The Polish Prime Minister’s Chancellery published its own summary the same day, in Polish, recording that on 7 August a Russian citizen was detained whose task was to carry out an execution in Warsaw on a person holding American and Ukrainian citizenship simultaneously, and that the action of the ABW and the police prevented it. That wording matches the international agency accounts on every point relied on here. It was read in reproduction rather than fetched from the Chancellery’s own channel. Neither the intended victim nor the detained suspect has been identified by the Polish authorities, and reports about their identities circulating in Polish media are unofficial and are not relied on here. Sourcing for the earlier cases now differs by case and is described that way in the text. The Berlin killing rests on the German federal prosecutors’ charging statement of June 2020. The Papperger plot rests on an on-record confirmation by a NATO official before a European Parliament committee in January 2025, following press reporting that cited unnamed officials; no prosecution has followed and the German government declined to comment at the time. The French and Lithuanian cases rest on official briefings reported by news agencies, without public case files, and are presented here as reported rather than as established. The sanctions figures and the description of who is designated are the Council’s own, taken from its standing page on hybrid sanctions at its stated review date of 13 July 2026. An earlier draft of this piece traced the listings round by round and stopped in April; that sequence has been replaced by the Council’s current statement of the position, which is both later and less liable to arithmetic error.

Provenance:
The sanctions record is taken from the Council’s own published notices: the establishment of the framework on 8 October 2024, the first listings of 16 December 2024 including GRU Unit 29155, the listings of 29 January 2026 and 16 March 2026, and the Council’s standing page on hybrid sanctions. The characterisation of assassination attempts as observed hybrid activity is the External Action Service’s own. Events in Warsaw are attributed in the text to the Polish Prime Minister’s statement of 13 August 2026 and to the wire reporting of it.