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This chapter examines the legitimacy and sustainability of sanctions against media outlets as a tool to counter foreign propaganda, focusing on the European Union’s restrictive measures against state-controlled Russian media following the invasion of Ukraine. While acknowledging the pressing need to address harmful disinformation and propaganda, particularly in times of war, we argue that the EU’s current sanctions model raises significant concerns regarding media freedom and freedom of expression. The chapter critically analyses the conceptual ambiguity surrounding ‘propaganda’ and ‘disinformation’ in international law, highlighting the tensions between content-based restrictions and fundamental rights. Drawing on comparative analysis of national approaches, particularly from Eastern European states, the chapter proposes an alternative tripartite framework for assessing media sanctions. This framework focuses on: (1) behaviour and content of media outlets; (2) adherence to principles of independent media and quality journalism; and (3) the relationship with ‘aggressor states’. We contend that this approach provides more objective criteria for identifying bona fide news media and propaganda channels, while better aligning with international human rights standards and the liberal understanding of media freedom.
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