This article explores the extent to which the European Global Human Rights Sanctions Regime (eughrsr) should be deemed to contain punitive elements, and if such elements do exist, how the principle of presumption of innocence should be applied to the targeted entity. Taking into account the Engel-criteria, literature research and existing national human rights sanctions regimes, we claim that under specific circumstances the Regime could be considered punitive, and argue that in such situations, certain safeguards with regard to the burden of proof require additional attention.