Saturday, March 26, 2022

Designing Geo-economic Policy for Europe (2022)

Geo-economic policies have become an increasingly important feature of international politics – and not just since the war in Ukraine. The EU has proposed an economic anti-coercion tool to deter third-party geo-economic coercion. Reviewing the academic literature on coercion and the effectiveness of economic sanctions, this policy brief analyses the risks and benefits as well as the challenges related to the EU’s proposed deterrence policy. 

> To be credible, EU anti-coercion policy requires some level of delegation. Germany should ensure that the parameters within which the Commission can act are set in a way that balances the need for credibility with the need to limit unwarranted escalation risk.

> As a member state with significant extra-EU economic interests, Germany benefits from EU geo-economic deterrence. As it stands, it will also bear a disproportionate share of the costs in case deterrence fails and retaliation is triggered.

> Germany should therefore propose the creation of an Economic Deterrence Fund to ensure a more equitable distribution of the costs of retaliation policies. This should go some way towards aligning member state interests.


The shift from a multilateral, rules-based international economic order to one where bilateral political and economic power plays a more prominent role poses risks to German and European economic interests. EU and especially German interests may become the target of third-party geo-economic policies, if only indirectly and in the guise of secondary sanctions.[1]

The EU is currently debating the creation of an economic ‘anti-coercion’ tool. Germany as the most trade-dependent among the larger EU countries stands to gain if the EU manages to successfully harness its economic deterrence potential. But Germany will also incur disproportional costs in case deterrence fails and retaliation becomes necessary. 

Proposed EU Geo-Economic Deterrence Policy

The EU has proposed the creation of a so-called ‘anti-coercion instrument.’ [2] The instrument is meant to deter coercion of the EU and individual member states by enabling the Commission to take swift, proportionate, targeted and temporary economic measures to force the coercing party to withdraw its measures. The tool’s primary function is to deter and only secondarily to retaliate. The proposal foresees the Commission to design retaliatory measures in a way that is both low-cost and effective from the point of view of the EU as well as individual member states. The triggers that provoke retaliation are meant to be sufficiently broad to also cover informal coercion, like for example consumer boycotts. Importantly, the new tool is to fall under the EU’s Common Commercial Policy. This means that deterrence policies would be largely delegated to the Commission. It would require a qualified majority in the Council of the EU to prevent the Commission from taking action in response to third-party coercion.

Harnessing the EU’s geo-economic power to defend against third-party coercion is a sensible proposal in view of the increased ‘weaponization of economic interdependence.’ Deterrence can help reduce individual members’ vulnerability to coercion by mobilizing the full economic weight of the EU. At present, the effectiveness and credibility of Europe’s geo-economic deterrence policy is hampered by the need for consensus (unanimity, in fact), which makes the formulation and implementation of EU deterrence and retaliation policies vulnerable to third-party ‘pre-emption.’ Trade-dependent EU countries quickly become the target of economic threats by a third-party coercer keen to pre-empt EU retaliation. Germany is at particular risk of becoming the focus of such policies due its extensive extra-EU economic interests.

While delegation to the Commission would alleviate this risk, it would also significantly curtail the influence of member states over policies. The German government should therefore carefully assess the scope within which the Commission is authorized to formulate policy, including the definition of triggers, the scope and type of retaliatory measures, and escalation strategies, before delegating powers. Delegation under broad parameters would help make EU geo-economic deterrence both more effective and credible, allowing the Commission to wield the new deterrence instrument with great flexibility. But this could also lead to greater geo-economic conflict if the mandate is defined very broadly. This calls for sensible calibration.

Delegation would also limit the ability of individual member states to affect the distribution of the costs in case retaliation becomes necessary. Ensuring greater intra-EU equity in terms of the costs of EU retaliation measures through a jointly financed compensation mechanism (or Economic Deterrence Fund) would go some way towards addressing this issue. It would provide for a more equitable allocation of costs and give the more trade-dependent members some reassurance that geo-economic conflict is not fought out on their backs. While successful deterrence benefits all EU members, the economically more outward oriented members face considerably greater costs in case of deterrence failure. In case the EU gets drawn into a geo-economic tit-for-tat over China’s coercion of Lithuania, Germany would end up shouldering a large part of the cost, not least because Lithuania’s exports to China are very small in both absolute and relative terms. Finally, it would help align the interests of member states more closely by sharing the burden of retaliation ore equally.


What Is Geo-Economic Coercion?

Geo-economics refers to the use of economic instruments to pursue foreign policy goals. In a world, where great power competition between the United States and China takes place in the context of economic interdependence, geo-economic policies will play a more prominent and varied role than, for example, during the Cold War.[3] After the end of the Cold War, foreign economic policy was largely geared towards cooperation and the pursuit of what IR scholars call absolute economic gains. Today, intensifying US-Chinese geopolitical competition has spilled over into the economic realm, leading countries to pursue relative gains as well as pay greater attention to their economic-financial vulnerabilities more generally – especially vis-à-vis their geo-political adversaries. 

The world’s most important economic powers are cognizant of the risks attached to the shift towards an economic order where rules matter less and power matters more. Unsurprisingly, they have begun to pro-actively manage their respective vulnerabilities. China is shifting towards ‘dual circulation’ (namely, a lesser dependence on the international economy), the EU is striving for ‘(open) strategic autonomy’, and the US is focused on addressing its geo-economic vulnerabilities by limiting supply chain risks. All three powers have also become more inclined to exploit other countries’ geo-economic vulnerabilities in pursuit of a variety of political objectives, such as punishing human rights abuses or military aggression.

Geo-economic policies can be positive and negative. Negative geo-economic policies involve the deliberate withdrawal (or threat of withdrawal) of customary trade and financial relations in pursuit of broader foreign policy goals. Positive policies offer (or promise to provide) a deepening of economic and financial relations. Although all geo-economic measures thus impose costs on, or offer benefits to the target,[4] not all seek to change the target’s behavior. Tighter export controls, for example, may not seek to change the target’s behavior, but may simply deny another country (or company) access to advanced technology consistent with the goal of slowing down technological development or weakening national security. This is a foreign policy goal that does not involve changing the target’s behavior. Geo-economic measures may be effective (they have an economic effect on the target) without being efficacious (in terms of realizing the political objective). 

A last important distinction: ‘Coercion’ comes in two forms: compellence and deterrence. Compellence, which colloquially is often equated with coercion, seeks to force the other party to take some specified action. Deterrence consists of persuading another party to refrain from initiating a specified action. Deterrence comes in two forms: deterrence by denial (denying the coercer the opportunity or benefits of their own geo-economic attack) and deterrence by punishment (inflicting unacceptable costs on the coercer). The literature suggests that compellence is more difficult to pull off than deterrence, in part perhaps because targets are generally more reluctant to accept a loss than to forego a gain – thus they will resist changing their policy despite suffering significant economic losses, as Russia appears to be demonstrating at the moment.

Geo-Economic Coercion Can and Does Fail

The literature also suggests that geo-economic compellence, despite being widespread and costly, is not particularly successful in terms of changing a target state’s behavior.[5] Sanctions, for instance, are more likely to be successful if three conditions are met: 

(1) they are aimed at friends rather than foes;

(2) the policy goal that is being pursued is relatively minor; and 

(3) the target is highly economically dependent on the sender country. 

It is not surprising that sanctions are more successful with respect to allies than adversaries, for “the higher compliance with sanctions by allies and trading partners reflects their willingness to yield on specific issues in deference to the overall relationship with the sender country. In addition, allies will not be as concerned as adversaries that concessions will undermine the government’s reputation and leave it weaker in future conflicts.” [6] This explains why geo-political adversaries are often highly resistant to geo-economic compellence.

In terms of geo-economic coercion, the coercer seeks to take advantage of the target’s economic vulnerabilities by threatening to impose costs on the target in case of noncompliance with stated aims. Coercive threats in terms of both compellence and deterrence are only credible if the costs to the coercer are lower than the costs to the target. An economically relatively more vulnerable country does not typically seek to coerce a relatively less vulnerable country, or at least it cannot do so credibly. The relatively greater costs it would incur would make such coercive threats neither credible nor effective. Economic dependence makes a country more susceptible to coercion, but greater susceptibility does not automatically translate into successful coercion – if only because the political cost of complying with the demands of the sender country may far exceed the economic costs incurred. At least, this is the case in case of compellence. 

Two examples serve to illustrate successful and unsuccessful coercion. Russia is quite willing to sustain the costs of international economic sanctions, as it appears to value the political gains related to the Ukraine war more highly. By contrast, Iran agreed to limitations to its nuclear program in the guise of Joint Comprehensive Plan of Action, following a sustained geo-economic pressure campaign that imposed significant economic costs on the Iranian economy. Coercive failure is variously attributed to signaling failures, cognitive biases, and misperception, as well as the misestimation of the (subjectively valued) costs of compliance versus the costs of non-compliance.[7] Ultimately, the success and failure of coercion simply depends on how badly the coercer wants to impose costs, and how badly the target is prepared to absorb them. [8] This is also why ‘escalation dominance’ (whether vertical or horizontal) makes coercive success more likely, but far from certain. 

As George put it, the effectiveness of coercion “rests in the last analysis on psychological factors,” even if decisionmakers’ psychological disposition is affected by material costs and benefits.[9] In other words: “Weakly motivated aggressors are easy to deter; intensely motivated one (…) can be impossible to deter.”[10] By the same token, strongly motivated defenders can be impossible to compel. The costs of coercive measures are nonetheless real, and they are a function of the scope and intensity of economic ties as well as the ability of the target to deflect the coercive measures or limit their costs. To echo the distinction drawn above: Coercion may be effective (in terms of imposing costs on the target), but not efficacious (in terms of deterrence or compellence). The point is this: the EU and its members must be prepared for deterrence failure and the need to make good on economically costly retaliatory threats; it must also be prepared that subsequent compellence in terms of forcing the other party to withdraw its original measures might also fail.

Designing Optimal Coercion Policies

The EU will increasingly be faced with the challenge of designing effective and efficacious coercion policies. Jentleson and Whytock,[11]two academics, provide a heuristically helpful analytical framework to evaluate the chances of coercive success and failure. Two sets of factors affect the effectiveness and efficaciousness of coercion, one related the coercer’s strategy, the other related to the target’s vulnerability. Ideally, the EU’s deterrence policy should be capable of incorporating these elements into its design to achieve maximum effect.

As far the coercer’s strategy is concerned, it is important that the “costs of noncompliance it can impose on, and the benefits of compliance it can offer to, the target state are greater than the benefits of noncompliance and costs of compliance” (p. 51). The ability to create the proper carrots and sticks is in turn affected by three factors: (1) proportionality, (2) reciprocity, and (3) coercive credibility. 

Key Elements of the Coercer’s Strategy

> Proportionality refers to the scope and nature of the objectives pursued, and the instruments used in their pursuit. Proportionality does not mean equivalence. Rather it means ‘not out of proportion,’ as disproportional threats are not credible, such as threatening a military invasion in response to higher tariffs. 

> Coercive credibility relates to the coercer’s ability to make the target believe that the coercer will make good on its threat if the target does not comply. 

> Reciprocity implies an explicit (or tacit) understanding of the link between the costs threatened by the coercer and costs incurred by the target. Reciprocity must also be clear and explicit about the link between coercive action and the target’s behavior.

For the target, the costs and benefits of compliance and non-compliance are also influenced by factors pertaining to the target state’s vulnerability to coercive measures, such as (1) domestic political support as a function of the costs and benefits of defiance compared to compliance; (2) economic costs of the coercive measures as a function of existing vulnerabilities; and (3) the role of elites as either ‘transmission belts’ or ‘circuit breakers’ of coercive policies.[12]

Designing Effective Coercive Geo-Economic Policies

How well-suited is the proposed EU anti-coercion instrument to optimal policy design? Designing deterrent measures that are proportional and reciprocal is a technical exercise, while credibility requires the ability to instill the belief in the target that the EU will make good on its retaliatory threat in case of third-party coercion. Delegating the formulation and implementation of deterrence policies to the Commission helps make them more effective and credible, compared to a policy that requires unanimity and extensive compromises at every turn – if agreement can be reached at all. Credibility also benefits from delegating the decision to retaliate to the Commission. The more leeway the Commission is given, the more credible and effective deterrence will be.

However, if formulation and implementation are delegated to the Commission, and if deterrence fails, the costs of retaliation policies may be spread unevenly among the EU members, in spite of the Commission’s commitment to designing policies that are low-cost to the EU and its members. Countries that rely more on extra-EU trade and finance will generally bear a disproportionate share of the associated costs. On the other hand, if deterrence policies require a high level of member state support, more trade-dependent countries may become the target of counterretaliation threats to dissuade from supporting EU retaliation and escalation. In other words, the greater the intra-EU consensus necessary to deter and retaliate, the less credible, deterrence will be. But the more ex-ante delegation exists, the less control individual member states will retain over policies, including the costs of retaliation. Automaticity and delegation enhance credibility, but they come at the cost of less control. This is an issue any deterrence policy needs to address.[13]Delegation is helpful to optimize policies in terms of proportionality, reciprocity, and credibility. But it also curtails the ability of member states to influence policies and escalation strategies. The Commission’s proposal clearly recognizes that unanimity is too high a hurdle. 

Moreover, the less influence individual member states have over policy, the greater the risk that member states will be dragged into geo-economic standoffs against their will as well as of losing control over subsequent policies, including escalation. The Baltic states would not exactly have been thrilled if they had been forced to take retaliatory against secondary US sanctions targeting Nord Stream 2. Therefore, the economically more outward-oriented countries, such as Germany, have an interest in unambiguously defining what constitutes coercion and setting parameters with respect to retaliatory measures, including issues such as trade versus financial retaliation, retaliation and counterretaliation, horizontal vs vertical escalation. These parameters do not need to be made public, as this might allow third parties to game EU policy. But the German government needs to be able to set a limit to geo-economic escalation in case retaliation fails. The coercer, of course, must not know what it is, lets it weakens deterrence policies. 

Adjusting Policies to Exploit Target’s Vulnerabilities

The optimal design of measures in terms of the target state’s vulnerabilities is also affected by the delegation/ consensus trade-off. Optimal EU retaliatory measures in terms of the target state’s politics, economics, and elites, is also likely to translate into an uneven allocation of costs. If, for example, the UK were part of the EU, financial retaliation would disproportionally fall on the UK due to London’s prominence as a financial center. Intra-EU conflict over what measures to take in view of differential costs may take optimal measures off the table, and may translate into sub-optimal, less effective deterrence policies that fail to mobilize the EU’s geo-economic potential. Add to this the possibility of the target engaging in counterretaliation by targeting the most economically dependent member states and the distribution of costs becomes even more uneven. 

Delegation within pre-set parameters should therefore be flanked by a compensation mechanism (or Economic Deterrence Fund) financed by all states in proportion to their size. Such a mechanism is not meant to fully compensate countries subject to third-party economic coercion. Instead, it is meant to distribute the potential costs of retaliation measures more evenly in case deterrence fails and retaliatory measures are triggered. If Germany, for example, gets dragged into a geo-economic tit-for-tat with China over Lithuania, Lithuania’s financial contributions to the fund are never going to compensate Germany for its economic losses. But it would nevertheless obligate all members to share the costs more equitably. It would thereby help align the costs and benefits more closely, and limit ‘moral hazard.’ It will also make it less likely that the anti-coercion is ‘hijacked’ by protectionist interests, as some of the more free-trade-oriented EU members fear. Finally, it would facilitate the design of more ‘optimal’ retaliation measures and thereby make the EU deterrence posture more effective. 

Limiting the ability of third-party coercers to pre-empt EU deterrence and retaliation measures is important to make them credible and effective. Delegation helps address this problem. To limit the risks associated with delegation, more equitable burden sharing of EU anti-coercion measures is desirable. The flexibility that comes with delegation is important not just in terms of optimal. It is also important in terms of being able to scale up or scale down retaliatory threats and measures, as the situation demands. Delegation within clearly defined, pre-set parameters flanked by a compensation mechanism would help make the EU’s anti-coercion both more effective and credible. It would not eliminate all the associated risks. There is no free lunch.


[1] Secondary sanctions threatening to impose penalties on third parties in case they engage in proscribed transactions with a primary sanctions target. Secondary sanctions effectively extend the sanctions regime to third parties to ensure the primary sanctions are not undermined by ‘third-party spoilers.’ See Bryan Early, Busted sanctions (Stanford 2015).

[2] European Commission, Commission Proposal for an Anti-Coercion Instrument, December 8, 2021. 

[3] Despite a lower degree of (inter-alliance) interdependence, geo-economics was a feature of the Cold War. Michael Mastanduno, Trade as a strategic weapon, International Organization, Vol. 42, No. 1, 1988; Randall Newnham, Deutsche mark diplomacy, Penn State University Press, 2002. Alan Dobson, US economic statecraft for survival, 1933-91, London: Routledge, 2002.

[4] Sometimes economic sanctions are defined more narrowly as the exclusion from the world economy to uphold international norms. See Nicholas Mulder, The economic weapon (New Haven 2022), p. 14.

[5] The literature is focused on compellence as opposed to deterrence. Assessing the success of deterrence involves unobservables and counterfactuals, as the behavioral change is not directly observable. Robert Pape, Why Economic sanctions do not work, International Security 22 (2), 1997; Daniel Drezner, The sanctions paradox, Cambridge: Cambridge University Press, 1999.

[6] Clyde Hufbauer et al., Economic sanctions reconsidered (Washington 2009).

[7] For a critical take on rational deterrence theory, Richard Ned Lebow, Key texts in political psychology and international relations Theory (2016), pp. 3-24.

[8] Richard Nephew, The art of sanctions (New York 2017).

[9] Alexander George, Forceful persuasion (Washington 1991)

[10] RAND, What deters and why, 2021.

[11] Bruce Jentleson and Christopher Whytock, Who ‘won’ Libya, International Security 30 (3), 2006.

[12] This is the rationale behind ‘smart sanctions,’ which target specific, politically relevant domestic actors with the intent of minimizing the costs of broader economic measures. Smart sanctions do not seem to be notably more successful than regular sanctions. Daniel Drezner, Sanctions sometimes smart, International Studies Review 13 (1), 2011.

[13] Thomas Schelling’s famous “threat that leaves something to chance” comes to mind.

Defense and Deterrence Against Geo-Economic Coercion (2022)

The geo-economic conflict between the United States and China as well as uncertainty about America’s longer-term commitment to a liberal and rules-based multilateral order pose risks to Germany’s economic prosperity and national security. The new German government must systematically identify economic dependencies and develop a forward-looking and comprehensive strategy to address vulnerabilities.

> Structurally, China and the United States are better equipped to deal with geo-economic conflict than Germany or the EU. Both countries benefit from greater centralization and flexibility of geo-economic policymaking.

> Germany, due to its extensive economic relations with both China and the United States, is even more vulnerable to geo-economic coercion than other EU countries. EU membership helps mitigate but does not eliminate German vulnerabilities. 

> The new German government should seek to reduce the most critical geo-economic risks and improve its geo-economic instruments both at the national and the European level. It should also support EU-US attempts to address common vulnerabilities. 


The three decades following the end of the Cold War were characterized by an international security environment conducive to economic cooperation. Today, US-Chinese geopolitical rivalry portends much more competitive and conflict-oriented international dynamics. While countries increasingly rely on adversarial foreign economic and geo-economic policies, multilateral institutions like the WTO have become less important. Even if the EU and Germany do not become a primary target of Chinese or US geo-economic policies, they risk incurring substantial economic costs. US secondary sanctions as well as Chinese countersanctions, for example, can hurt German and European economic interests. [1]

The challenge for Germany and other heavily trade-dependent countries is to preserve the benefits of economic interdependence while limiting the economic-political vulnerabilities associated with it. International Relations scholars refer to this as the challenge of managing economic interdependence. In addition to addressing vulnerabilities at the national and EU level, Germany and the EU should pursue transatlantic cooperation to alleviate common vulnerabilities vis-à-vis third parties, as is already happening in several areas.[2]

Historically, the security externalities associated with economic cooperation have facilitated close economic relations within alliances. Critical technology, for example, is more likely to be shared among allies than between adversaries. Relations between allies are not a zero-sum game, and the security externalities of economic cooperation have the effect of increasing the aggregate strength of an alliance. This does not mean that there can never be any conflict. But shared national security objectives will tend to limit the degree to which allies will exploit each other’s economic vulnerabilities, as the transatlantic disagreement over export controls in the 1950s or the failure of the Reagan-era pipeline sanctions demonstrate.[3]

However, Germany and Europe should prepare broader contingency plans in case transatlantic cooperation falters. Those plans should focus on addressing the most critical vulnerabilities as well as on creating credible geo-economic instruments capable of deterring third-party coercion. After all, transatlantic relations may yet take a significant turn for the worse after the 2024 presidential election, and the intensifying US-Chinese competition will have negative implications for Germany and Europe.[4]

German Economic Vulnerabilities

Countries that are characterized by a low level of economic dependence can take advantage of the vulnerabilities of economically more dependent countries. Economic vulnerabilities can be leveraged for political and economic ends through the imposition of restrictions on the cross-border flows of goods, services, and capital as well as information and data. Geo-economic policies seek to exploit bilateral dependencies or what is also called asymmetric interdependence. This typically requires that the costs imposed on the target country exceed the costs incurred by the so-called sender country.[5] The ability to impose relatively greater costs does not mean that the sender country will necessarily realize its political objectives.[6] Nevertheless, the economic costs to the target country are real, and in the context of zero-sum geopolitical competition, it is the pursuit of relative rather than absolute gains that tends to inform foreign economic policy. 

Given its extensive dependence on the international economy, this is a particularly salient issue for Germany. It raises three important issues: How significant are Germany’s economic vulnerabilities vis-à-vis the other major economic powers? What tools do Germany and the EU currently have at their disposal to mitigate vulnerabilities? What policies and instruments should be created at the national and EU level to more effectively contain political-economic vulnerabilities?

How do geo-economic policies leverage vulnerabilities, and how vulnerable is Germany to such policies by third countries such as China and the United States? First, countries can restrict the import of goods and services through tariffs and non-tariff barriers. Such measures reduce exports from the target country and harm its economic growth. The country that imposes restrictions also typically suffers economic losses due to the higher costs of imported goods. The greater the relative dependence of the exporting country on the importing country (and the less able it is to divert its exports to third countries), the more vulnerable the exporting country is to import restrictions.

Roughly two thirds of German trade is with the EU-27 and the UK. Nevertheless, German exports to the United States and China correspond to a significant share of Germany’s GDP (see chart). They are also considerably greater than American and Chinese exports to Germany. In the event of a bilateral trade conflict, Germany is therefore far more vulnerable than either the United States or China. Germany does benefit from EU membership and the EU’s trade-related influence. China currently depends more on the EU market than the EU does on the Chinese market (at least as measured in gross exports). [7] It is therefore unlikely to engage in an escalatory trade conflict with the EU if it is convinced that the EU will manage to respond in kind. The transatlantic relationship is different. The EU is more dependent on exports to the United States than vice versa, and this makes it relatively more vulnerable in the event of a bilateral conflict.

Second, countries can restrict exports. The more a country depends on critical goods (or services) produced by another country, the more vulnerable it is to that country’s export controls (provided it cannot acquire the goods elsewhere). Reduced access to critical imports can entail significant costs and even lead to broader economic disruption. (Think of the Arab oil embargo of the early 1970s.) Export controls can also hold back another country’s economic and technological development by placing restrictions on the export of advanced technology. The exporter of critical goods typically suffers only modest losses compared to the importer. Unlike export dependency, vulnerability associated with critical imports is less well captured by total import volumes or values. Instead, it is best described in terms of a combination of import volumes of critical goods and their degree of substitutability. 

According to the European Commission, the United States depends more on the EU for critical goods than vice versa, at least in quantitative terms. But both Americans and Europeans are relatively more dependent on China, if not in terms of the number of items, then certainly in terms of import values and substitutability. Importantly, US and EU dependency on Chinese rare-earth exports is significant, as China currently controls up to 90 percent of global supply. And Germany, as Europe’s dominant manufacturer, is more dependent on rare-earth imports than other EU members. 

Third, in addition to international trade, countries can restrict cross-border financial flows. Such measures may affect both flows and stocks and can include asset freezes, forced divestments, and outright expropriation. Restricting inward investment makes it more difficult for the target country to hold savings or raise investment in the sender country’s domestic financial market. At the same time, it reduces the demand for the financial assets of the sender country, while restrictions on outflows limit the ability of residents to invest in the target country. (Restricting financial flows also harms the economic interests of domestic financial service providers in terms of their ability to sell services to non-residents.) Like in all other cases, imposing geo-financial restrictions only makes sense if the target country is both significantly more dependent on the sender country than vice versa and if it cannot easily offset any losses by switching to third countries (including financial offshore centers).

Financial flows and stocks can be divided into foreign direct investment (FDI) and non-FDI, such as portfolio flows and cross-border loans and deposits. As with trade, the bulk of German outward FDI is in the EU-27 (and the UK). Again, the United States and China are the top two destinations for German FDI outside Europe. German FDI in the United States is much larger than in China. American and Chinese FDI in Germany is much smaller in both dollar and GDP terms than German FDI in the United States and China. It is important to note, however, that to the extent that FDI is a critical part of international supply chains, a mere quantitative comparison only captures part of a country’s overall vulnerability, even if it remains indicative of bilateral financial vulnerabilities. 

A good if imperfect proxy of vulnerability to cross-border restrictions of non-FDI financial flows is bank lending, if only because bank-related financial vulnerabilities have a greater potential to cause economic instability in the target country (due to their greater systemic importance) than do non-bank financial institutions’ risks. Cross-border bank lending is difficult to measure accurately and comprehensively. But based on consolidated cross-border claims, German bank lending to the United States is quite large, while US lending to Germany is relatively small. In comparison, both US and German cross-border lending to China is negligible.[8]

Last but certainly not least, restricting a target country’s access to the domestic financial system also limits its ability to use the sender country’s currency offshore. Such restrictions prove even more effective if secondary sanctions, which threaten third parties with penalties or market exclusion if they do business with the target, force third parties to stop transacting with it. When the restrictions are imposed by a country whose currency is widely used internationally, the target country’s ability to engage in international trade and financial transactions can be severely curtailed.

It is mainly the United States and the EU (or euro area) which can gain leverage from this instrument. If they impose restrictions, banks will refrain from transacting with the targeted party, lest they lose access to important capital markets as well as their ability to engage in hard-currency-based international trade and financial transactions. In this respect, the relatively insignificant international role of the Chinese yuan makes Chinese restrictions much less consequential than comparable US or EU measures. And, of course, Chinese banks’ relatively greater reliance on the euro and the dollar make the broader use of a ‘yuan weapon’ targeting US and EU interests rather non-sensical. 

To sum up, Germany is more vulnerable to Chinese and US bilateral trade and financial restrictions and geo-economic measures than vice versa. This vulnerability is somewhat mitigated through Germany’s EU membership. In terms of exports and FDI, Germany is nevertheless relatively more dependent on both China and the United States than vice versa, at least in purely quantitative terms. Germany is also relatively more vulnerable to the United States in terms of non-FDI and the dollar. Importantly, Germany is more vulnerable to Chinese and US geo-economic policies than virtually all other EU members. This provides Berlin with good reasons to seek greater EU cohesion and integration. At the same time, it makes it a primary target of third-party geo-economic measures aimed at weakening EU cohesion. 

A few caveats are in order. Macro-level dependence does not translate one-to-one into exploitable geo-economic vulnerabilities, let alone coercibility. First, so-called ‘issue linkage’ means that a simple analysis of bilateral sectoral vulnerabilities is insufficient to evaluate overall vulnerability. Sectoral vulnerability matters, but a country keen to employ coercive measures may be able to pursue a strategy of ‘horizontal escalation.’ That means that a threat in one area (trade) can be leveraged to extract concessions in another area (finance), or that unfriendly geo-economic measures in one area can be deterred by credibly threatening retaliation in another. 

Second, relative vulnerability does not directly translate into coercibility, as the success of coercive policies ultimately rests on the resolve of the target. And resolve is not simply a function of economic loss, relative or absolute. It is therefore important to distinguish between the efficacity (realization of political ends) and the effectiveness (imposition of costs) of geo-economic measures. However, even when geo-economic policies do not meet their political objective, they are capable of imposing losses on the target.

Third, it is not possible to exploit vulnerabilities or defend against geo-economic coercion without creating the necessary policies and tools to do so. Take, for example, a bilateral relationship in which the EU is economically less vulnerable than the other country. But if that other country can block EU retaliatory policies, it may get away with imposing geo-economic costs on the EU (or individual member states) despite being the relatively more vulnerable party. The same holds true if the target country lacks the necessary policy tools to mobilize its geo-economic power. The EU, for instance should be able to stand up to China as far as trade is concerned. But if it does not have the appropriate policy tools, or if it fails to generate sufficient intra-EU consensus for a sufficiently convincing geo-political response, China will be able to avoid EU retaliation. That is what seems to be happening in the case of the recent China-Lithuania spat. Nevertheless, assessing bilateral economic dependencies is a necessary step to gauge economic and potential political susceptibility to geo-economic coercion.

Power relies not just on the degree of asymmetric economic interdependence, but also on the ability and willingness to leverage it. In this domain, Germany and the EU are at a disadvantage vis-à-vis China and the United States, and here is why:

EU trade policy is largely under the purview of the European Commission. But unilateral, non-WTO-authorized retaliatory measures are classed as foreign policy and require unanimous approval by all member states. [9] Such unanimity is hard to achieve because member states often face different cost-benefit calculi in relation to trade retaliation, particularly if the original ‘unfriendly’ trade measures only affect a subset of EU members. This makes it difficult to generate consensus in support of retaliatory measures. 

In terms of critical imports, the EU has begun to identify and address some of its vulnerabilities.[10] But as of now, risk mitigation policies still depend on cooperation and coordination among EU member states, which makes it challenging to establish effective mitigation policies. 

Export control policy largely remains under the purview of national authorities in the EU. Recent EU reforms have sought to enhance intra-EU coordination and cooperation. But overall, the reform falls far short of mobilizing the EU’s significant geo-economic potential with respect to critical exports. EU member states can introduce tougher and broader controls than what has been proposed under EU export control policy.[11] But a national approach is far less effective than an EU-wide strategy.

Inward FDI regulation in the EU is under the purview of national authorities as far as investment from third countries is concerned. Germany has tightened its inward FDI regulations several times over the past few years, recently adding 20 sectors to its screening regime. New sectors include many emerging technologies, such as satellite systems, artificial intelligence, quantum mechanics, etc. This provides the German government with greater oversight and discretion than before.[12] Meanwhile, the EU has just created a new FDI screening mechanism. However, the new regime is not a stand-alone mechanism akin to CFIUS (Committee on Foreign Investment in the United States) and does not provide for a comprehensive EU-wide export control regime. Rather it is an enhanced information sharing regime that does not even mandate the creation of national-level FDI reviews.[13]

As far as non-FDI investment is concerned, the European Commission has rightly recognized that threatening third parties with market exclusion in the context of its proposed anti-coercion policy might serve as a potentially effective deterrent. But geo-financial measures (commonly referred to as sanctions) require the support of all EU members. This makes them less effective than they could be.[14]What applies to non-FDI-related sanctions is also largely true for currency-related measures. Sanctions require unanimous support, and the implementation of policies largely rests with national authorities. As in most other economic areas, this limits the EU’s ability to harness its geo-economic potential more effectively and more credibly.

Geo-Economic Policymaking in China and the United States

Both the American and Chinese governments are in a much better position to pursue effective geo-economic policies, given the greater centralization of decision-making in both countries. In most cases, the two governments also dispose of more flexible policy instruments which can used under fewer domestic political constraints. In the United States, trade policy is broadly controlled by the president (who directs the Commerce Department and the United States Trade Representative), except for trade liberalization measures, which are a matter for Congress. As the Trump administration demonstrated with its trade policy towards both China and US allies, the domestic checks on unilateral geo-economic trade policies are very weak. Various statutes provide the government with significant leeway in terms of trade restrictions.[15] If all else fails, the government can simply invoke a national security exemption.[16] The relative autonomy of the executive combined with the country’s limited vulnerability to foreign trade measures provides the United States with significant geo-economic power. 

In China, the government also faces few if any domestic constraints in terms of trade policy. China’s continued dependence on international trade does represent a constraint – at least vis-à-vis the United States and the EU. Yet as China is moving to reduce its dependence on international trade in the context of its ‘dual circulation’ strategy and ‘Made in China 2025‘ policy, it may become more willing to resort to geo-economically driven trade policies. Both the United States and China have demonstrated their willingness to use their ‘trade power’ vis-à-vis ‘smaller’ (that is, more dependent) countries (United States against China; China against Australia, Japan, and Korea), as has the EU.

In terms of import dependence, the United States is exploring ways to strengthen its supply chains and reduce its dependence on critical imports.[17] Centralized executive decision-making and deep financial pockets are helpful. Congress rarely fails to fund economic policies deemed essential for national security, as the proposed US Innovation and Competition Act currently under debate in Congress demonstrates. Meanwhile, China is also seeking to reduce its dependence on the international economy, and especially vital imports, through its ‘dual circulation’ and ‘Made in China 2025’ strategies. To this end, large amounts of financial resources have been made available. The Belt and Road Initiative and the creation of a blue water navy can also be rationalized in terms of supply security, especially regarding foodstuff and energy. The recent experience of geo-economic conflict with the United States has further strengthened China’s desire to reduce geo-economic vulnerabilities. Compared to the EU, the United States and China are far better positioned to pursue a whole-of-government approach to managing import-related dependencies.


Like in trade, the US government has also significant latitude in terms of export control policy. [18] Under the so-called foreign direct product rule, for example, the government can even prohibit third-country exports that make use of American equipment or intellectual property rights, in addition to more typical measures, such as restrictions on re-exports and in-country transfers. Moreover, US technological leadership gives Washington’s export control policy significant reach and heft, as several Chinese technology companies have recently learnt. The Chinese authorities similarly face few domestic political constraints with respect to export controls. However, China’s own import dependence may cause Beijing some reluctance to go up against the bigger economic powers for fear of retaliation. China, like the United States, has demonstrated its willingness to use export controls. US controls include restrictions of semiconductor exports to selected Chinese companies, while China temporarily embargoed rare earth exports to Japan.

The United States has also tightened its FDI regulations several times in the past few years.[19] The so-called CFIUS process led by the Treasury establishes an inter-agency review of foreign FDI in sectors related to national security. The scope of sectors and types of investment has been broadened. Even after partial liberalization, China is much more restrictive in terms of FDI than the United States or Germany, and the authorities retain significant discretion and control over inward FDI in sectors deemed to be of strategic importance. Tighter national security guidelines also give the Chinese authorities extensive control over investment in critical sectors.

The United States administers financial sanctions through the Treasury’s Office of Foreign Asset Control based on various elements of sanctions legislation. While US financial measures largely target entities involved in criminal and terrorist activities, Washington has recently also taken aim at Chinese companies. Existing legislation gives the president broad authority to impose sanctions. Similarly, China faces few bureaucratic or legal constraints when it comes to financial sanctions, even though the relatively closed nature of its financial systems provides it with limited leverage vis-à-vis other countries.

Last but not least, American dollar-based sanctions, thanks to the dominant role of the dollar in the global economy, have proven a powerful geo-economic tool. Through the Treasury’s Office of Foreign Asset Control, the president has a fair amount of discretion on applying currency sanctions based on specific legislation or broader economic emergency powers.[20] In contrast, China is in a much weaker position concerning currency-related sanctions. The country’s capital account is relatively closed, and the yuan is rarely used offshore. China can certainly restrict access of foreign institutions to its financial system, but the dependence of foreign banking and financial institutions on the Chinese market is limited. Restricting access to the yuan would have only a negligible effect and therefore does not lend itself as a geo-economic tool given China’s far greater dependence on the dollar and the euro. China has recently made changes to its countersanction policy by introducing a blocking statute and a countersanction tool. This allows the government to prohibit Chinese companies, including foreign companies with a presence in China, from complying with foreign sanctions. Should they disobey, significant penalties can be imposed. This is meant to undercut both primary and secondary sanctions. It is difficult to see how the EU could ever agree to such a bold deterrence and retaliation policy.

In brief, China and the United States have more flexible geo-economic tools at their disposal. Centralized decision-making with few effective domestic checks on the use of existing instruments gives both governments significant flexibility. EU-level policymaking, by comparison, is much more cumbersome and too dependent on the need for consensus or extensive coordination among members. 

This situation allows third countries to target the proverbial weakest link – the country with the most to lose in economic terms – to weaken or even completely undermine European geo-economic deterrence and retaliatory policies. And Germany, economically speaking, is often the weakest link. Meanwhile, German national-level policies and instruments remain too rules-based and are frequently subject to intra-government, party-coalitional disagreement. This limits their effectiveness. While Germany should allow for a more flexible and strategic use of its geo-political instruments to enhance its potential for geo-economic deterrence, the EU needs to coordinate national policies more closely and streamline decision-making procedures to make its policies both more credible and effective.


Selected Geo-Economic Policies and Instrument in China, Europe, and the United States

 

 

USA

CHINA

EU/ Germany

Source of Geo-Economic Vulnerability

Trade Policy

Executive (Commerce Department, United States Trade Representative) 

Trade Expansion Act (1962); Trade Act (1974); North American Free Trade Act (1993); Bipartisan Congressional Trade Priorities and Accountability Act (2015)

 

State Council (Ministry of Commerce)

 Foreign Trade Law, Customs Law

EU Directorate General for Trade 

‘Trade defense’ policy/ Anti-coercion tool (proposed)

Export dependence

 

 

Export Control Policy

Executive (Commerce Department/ Bureau of Industry and Security)

Export Control Reform Act (2018) 

  

State Council (Ministry of Commerce, Central Military Commission Chinese Customs Bureau)

Chinese export control Act (2020) 

Government (Federal Office of Economics and Export Control)

EU Export Control Regulation (2021)

Reliance on difficult-to-substitute imports

 

 

Exchange Rate Policy

Executive (Treasury, Federal Reserve)

Omnibus Foreign Trade and Competitiveness Act (1988); Trade Facilitation and Trade Enforcement Act (2015)

 

State Council (People’s Bank of China, State Administration of Foreign Exchange)

 

 

European Central Bank

 

Export dependence

Foreign Direct Investment

Executive (Committee on Foreign Direct Investment in the United States, consisting of nine departments chaired by Treasury)

Foreign Investment Risk Review Modernization Act (2018)

 

 

State Council

Foreign Investment Law (2020)

Special Administrative Measures for Foreign Investment (‘negative list’) (2019)

Government/ Interagency process consisting of (Ministry of Economic Affairs, Ministry of Defense, Ministry of the Interior

Foreign Trade and Payments Act; Foreign Trade and Payments Regulation

EU FDI screening framework (2020)

 

Financial risks related to relative value of inward/ outward FDI

 Supply chain risks in case of expropriation, forced divestment etc.

Non-FDI

Executive (Treasury - Office of Foreign Asset Control)

 

State Council (People’s Bank of China)

Government (Ministry of Finance, Bundesbank, BaFin)

Council of the European Union (unanimity)

EU sanction tool under EU Common Foreign and Security Policy (Directorate-General for Financial Stability, Financial Services, and Capital Markets Union)

 

Financial risk related to foreign assets/ liabilities

 Especially: Access to currency funding and clearing

 

Economic Sanctions and Countersanctions

Executive (incl. State Department, Treasury, Commerce)

International Emergency Economic Powers Act (1977); various 

 

 

State Council (various agencies)

National Security Law; ‘unreliable entity list’; blocking statute; countersanction tool

 

Government (Ministry of Finance, Bundesbank)

See non-FDI

Blocking statute

“Anti-Coercion” Policy

 

All of the above

Source: Author’s compilation



Enhance EU Cohesion and Improve National Tools 

In terms of trade policy, the Commission has proposed an anti-coercion tool that would be designated as a trade rather than a foreign policy instrument.[21] This would mean that proposals for retaliatory measures would only require a qualified majority in the Council of the EU to come into force – a very different situation from foreign policy measures that require unanimous support to be approved. The Commission proposal also links its ‘trade defense’ policies to a broader cross-sectoral anti-coercion strategy which includes financial and other trade-related sanctions. However, such ‘horizontal retaliation’ carries a risk of politicizing international trade relations too much. It may also be unnecessary, given that in many cases the EU is reasonably well-positioned to fend off unfriendly trade policies by trade-related countermeasures. At the same time, a broader anti-coercion policy would allow the EU to mobilize its geo-economic power through linkage politics.

The challenge is to create a decision-making mechanism which can prevent third parties from pursuing a ‘divide-and-rule’ approach towards EU members while maintaining credible economic deterrence. Member states also face the challenge of deciding how much power and autonomy to grant the Commission in terms of both ‘vertical’ and ‘horizontal geo-economic escalation.’ From their perspective, there is a real risk of ending up in an out-of-control retaliation-counterretaliation cycle if no limits are imposed. Of course, any deterrence policy has to address the issue of automaticity (or pre-delegation) and discretion: Automaticity lends credibility but creates a greater risk of escalation. Given its greater extra-EU trade dependence and vulnerability, automaticity should be of particular concern to Germany. The EU’s anti-coercion policy needs to be calibrated in a way that strengthens EU unity and the credibility of its geo-economic policies without having individual member states lose all control over them (for optimal policy design, see forthcoming Policy Brief).

In terms of import dependence, managing dependencies vis-à-vis third countries at the EU level is preferable to national-level policies. Even if Germany managed to address its extra-EU dependence, it would remain vulnerable because it would still depend on imports from other EU member states, which in turn rely on critical imports from outside Europe. National-level policies can therefore only provide a second and less complete line of geo-economic defense and vulnerability reduction.

The EU must also accelerate its efforts to reduce critical vulnerabilities through a combination of import diversification, reshoring, and the creation of strategic reserves.[22] The optimal balance will be a function of the trade-off between economic costs and the desired reduction of vulnerabilities. One major factor in this equation is how critical a specific import is to the EU as a whole. Greater intra-EU coordination of purchases of critical goods, a least as far EU-level strategic reserves are concerned, would also provide the EU with greater market and pricing power in international markets. The cost of financing stockpiles could be allocated based on member states’ consumption shares. Although the private sector is typically much better placed to manage supply chain risks – the so-called European Materials Alliance, an industrial alliance, certainly has a role to play here – the official sector can help overcome collective action problems.

Moving production of critical inputs onshore is being pushed by the Commission, as in the case of semiconductors.[23] Such policies may lead to international trade tensions, and related industrial policies are fraught with risks in terms of rent-seeking. Both EU and national-level policies should be based on a detailed and careful assessment in terms of their prospective cost-benefit balance. They should also be compared to alternative mitigation policies, such as international cooperation and import diversification. Making critical energy imports more fungible by increasing the interconnectedness of energy connectivity or creating strategic reserves can also help mitigate individual and collective import dependencies.

As for export control policy, the more active, national security-oriented approach taken by both the United States and China should induce Germany to consider making its export control regime more flexible. It should also be turned into more (but not too much) of a political tool. This might require shielding it to some extent from party politics within the governing coalition. Germany’s export control regime should be integrated into a broader geo-economic strategy to enhance its political effectiveness. Turning export controls into a more flexible tool is meant to signal to third countries that they are the addressees of an overarching strategy of geo-economic deterrence. Greater flexibility is not meant to make international financial relations less predictable. Instead, it is meant to signal Germany’s willingness to impose costs on countries whose policies weaken predictable, rules-based cooperation. 

At the EU level, enhanced transparency and closer consultation and coordination of national export control policies is highly desirable, not least to avoid the situation of a prisoner’s dilemma in case other EU members produce close substitutes of the goods to be controlled. Recent reforms do not go far enough.[24] As with trade, diverging interests (and vulnerabilities) of EU members may make it difficult to find consensus. But without agreement, at least among countries that produce close substitutes of goods to be controlled, national export control policies become ineffective.

Regarding geo-financial policies, the German government should continue to support enhanced FDI screening policies at the European level but should not shy away from imposing tighter national oversight (if not necessarily restrictions) than other members. After all, Germany has more high-technology assets likely to become the target of non-market bids by state-supported foreign companies than other EU countries. A more political-strategic rather than legalistic-bureaucratic approach might also offer the opportunity to extract greater reciprocity in terms of overseas FDI access.

As far as non-FDI flows are concerned, the creation of a US-style Office of Foreign Assets Control (OFAC), which implements financial sanctions under guidance from the president and the Treasury, would lend EU geo-economic policies greater heft and credibility. But to be effective, this would require members to largely if not completely delegate decisions on financial sanctions. Again, this is difficult, for unless a sensible calibration of policies and decision-making procedures can be found, geo-financial policies will tend to be either too weak or risk being unnecessarily escalatory. 

In terms of currency-related sanctions, including secondary sanctions, the EU (euro area) should strengthen its monetary union through greater financial, banking, and capital market integration. The goal should be to make the euro coequal to the dollar and thus increase the effectiveness of euro-based financial sanctions. [25] In the short term, few if any effective mitigation policies are available, as the re-instauration of US Iran sanctions and the failure of INSTEX has demonstrated.[26]

In brief, greater EU cohesion is desirable to strengthen Europe’s geo-economic deterrence potential. The problem is that the EU is not a unitary actor and consensus among member states is often difficult to reach. So far, most important geo-economic decisions require the member states’ unanimous approval. National policy tools are less effective, but they offer greater flexibility. If EU solutions remain out of reach, reforms allowing for a more flexible use of existing national instruments would be useful. If handled responsibly, they would help enhance credibility by creating some ‘strategic ambiguity’ – a desirable effect in view of the far more flexible and political tools at the disposal of the other major geo-economic powers. 

Prepare for Geo-Economic Conflict


International economic relations are at risk of further politicization. Germany, more than many other countries, has a huge stake in the survival of the post-WWII multilateral, rules-based economic order. Even if the global economic order does not break down entirely, like it did in the 1930s, greater fragmentation and conflict can cause significant economic harm. As a country that is highly dependent on the international economy, Germany needs to put in place policies to mitigate the effects of increased international economic instability and the mounting risk of geo-economic coercion. Autarky is by far the economically most costly strategy and does not necessarily eliminate all economic risks. Diversifying economic and financial relations and actively managing economic interdependence is a much better strategy. Where expedient, this should involve close cooperation with trusted partners to address shared vulnerabilities.

Yet policy and strategy must not be based on the most desirable scenario but on the most likely one. The rivalry between the United States and China will escalate, and continued US support for the multilateral, rules-based economic order is becoming more uncertain. Germany and Europe must take those risks very seriously. Other trade-dependent middle-powers, like Japan and Korea, are already actively preparing for such a scenario. Japan has even created a Ministry for Economic Security. The new German government can no longer rely on the fragmented ad hoc approach taken to date. It urgently needs to devise a comprehensive and forward-looking national strategy to deal with intensifying geo-economic conflict and the weaponization of economic interdependence. 

[1]
 Markus Jaeger, Germany between a rock and a hard place in China-US competition, DGAP Commentary, March 17, 2021: https://dgap.org/en/research/publications/germany-between-rock-and-hard-place-china-us-competition (accessed: February 20, 2022).

[2] European Commission, EU-US Trade and Technology Council, October 18, 2020: https://ec.europa.eu/commission/presscorner/detail/en/IP_21_5308(accessed: February 20, 2022). Department of State, Joint Statement on the US-EU Energy Council, February 7, 2022: https://www.state.gov/joint-statement-on-the-u-s-eu-energy-council/ (accessed: February 20: 2022). European Commission, Launch of the Joint EU-US Covid Manufacturing and Supply Chain Taskforce, September 22, 2021: https://ec.europa.eu/commission/presscorner/detail/en/STATEMENT_21_4847 (accessed: February 20, 2022).

[3] In the 1950s, the transatlantic dispute over export controls targeting Warsaw Pact countries was resolved in part because Washington was keen to strengthen the Western alliance. In the 1980s, the Reagan administration stepped back from imposing sanctions affecting Western European allies in relation to the construction of a Soviet gas pipeline. Michael Mastanduno, Trade as a strategic weapon, International Organization 42 (1), 1988.

[4] Markus Jaeger, The logic (and grammar) of US grand strategy, DGAP Research, June 2, 2021: https://dgap.org/en/research/publications/logic-and-grammar-us-grand-strategy (accessed: February 20, 2022).

[5] Note that such measures may target individuals, companies, or entire countries. If I subsequently refer to target countries, this is intended to include companies headquartered and natural persons resident in these countries as targets of geo-economic measures. 

[6] Clyde Hufbauer et al., Economic sanctions reconsidered (Washington 2009).

[7] The value-added embedded in export is a more accurate measure. But OECD data shows that the domestic value-added in gross exports in China, Germany, and the United States is remarkably similar. Therefore, gross exports are a reasonable proxy for export dependence.

[8] The BIS does not provide comparable data for cross-border lending by Chinese banks.

[9] European Commission, Trade Defence: https://ec.europa.eu/trade/policy/accessing-markets/trade-defence (accessed: February 20, 2022).

[10] European Commission, Critical Raw Materials: https://ec.europa.eu/growth/sectors/raw-materials/areas-specific-interest/critical-raw-materials_en (accessed: February 20, 2022).

European Commission, EU Chips Act, February 8, 2022: https://ec.europa.eu/commission/presscorner/detail/en/qanda_22_730 (accessed: February 20, 2022).

[11] DLA Piper, Export controls: the EU’s new dual-use regime, September 27, 2021: https://www.dlapiper.com/en/slovakrepublic/insights/publications/2021/09/export-controls-the-eus-new-dual-use-regime/ (accessed: February 20, 2022).

[12] Gibson & Dunn, Germany further strengthens foreign direct investment regime, May 13, 2021: https://www.gibsondunn.com/germany-further-strengthens-foreign-direct-investment-fdi-regime/ (accessed: February 20, 2022).

[13] Kirkland & Ellis, New EU foreign investment regulations take effect, October 29, 2020: https://www.kirkland.com/publications/kirkland-alert/2020/10/eu-fdi-regulation (accessed: February 20, 2022)

[14] European Commission, Restrictive Measures (Sanctions): https://ec.europa.eu/info/business-economy-euro/banking-and-finance/international-relations/restrictive-measures-sanctions_en (accessed: February 20, 2022).

[15] Congressional Research Service, US Trade Policy Functions: Who Does What? January 14, 2022: https://sgp.fas.org/crs/misc/IF11016.pdf (accessed: February 20, 2022).

[16] Congressional Research Service, Section 232 of the Trade Expansion Act of 1962, November 4, 2021: https://sgp.fas.org/crs/misc/IF10667.pdf (accessed: February 20, 2022).

[17] White House, Building Resilient Supply Chains, Revitalizing American Manufacturing and Fostering Broad-Based Growth, 100-Day Reviews under Executive Order 14017, June 4, 2021: https://www.whitehouse.gov/wp-content/uploads/2021/06/100-day-supply-chain-review-report.pdf (accessed: February 20, 2022).

[18] Congressional Research Service, The US Export Control System and the Export Control Reform Act of 2018, January 28, 2020: https://sgp.fas.org/crs/natsec/R41916.pdf (accessed: February 20, 2022).

[19] Congressional Research Service, CFIUS Reform under FIRRMA, February 21, 2021: https://crsreports.congress.gov/product/pdf/IF/IF10952 (accessed: February 20, 2022).

[20] Congressional Research Service, The International Emergency Economic Powers Act, July 14, 2020: https://sgp.fas.org/crs/natsec/R45618.pdf (accessed: February 20, 2022).

[21] European Commission, Proposal for a Regulation of the European Parliament and the of Council on the Protection of the Union and its Member States from Economic Coercion by Third Countries, 2021: https://trade.ec.europa.eu/doclib/docs/2021/december/tradoc_159958.pdf (accessed: February 20, 2022).

[22] Reshoring and/ or self-sufficiency does not necessarily reduce economic risks, and concomitant economic decoupling may create its own set of problems, including oversupply and higher input costs.

[23] European Commission, EU Chips Act, February 8, 2022: https://ec.europa.eu/commission/presscorner/detail/en/qanda_22_730 (accessed: February 20, 2022).

[24] European Commission, Foreign Direct Investment EU Screening Framework, 2020: https://ec.europa.eu/commission/presscorner/detail/en/ip_20_1867(accessed: February 20, 2022).

[25] Markus Jaeger, Promoting the euro - countering secondary sanctions, DGAP Policy Brief, February 8, 2022: https://dgap.org/en/research/publications/promoting-euro-countering-secondary-sanctions (accessed: February 20, 2022).

[26] INSTEX is the special purpose vehicle established by European countries to circumvent US dollar- and SWIFT-related sanctions.