The Unmaking of the West

The Unmaking of the West

On December 23, 2025, the US State Department did something without precedent: it imposed visa restrictions on five European officials, including former EU Commissioner Thierry Breton, for enforcing European law. The charge was participation in a “censorship-industrial complex.” The target was the Digital Services Act. The message was unmistakable.

This was not a trade dispute dressed in diplomatic language. It was not a negotiating tactic awaiting resolution in some future summit communiqué. Secretary of State Marco Rubio’s announcement—complete with a threat to “expand today’s list if other foreign actors do not reverse course”—represented something more fundamental: the explicit rejection of regulatory cooperation as a legitimate form of allied engagement.

The transatlantic relationship has weathered currency wars, agricultural subsidies, and steel tariffs. It has survived Suez and Iraq. But those disputes operated within a shared grammar of Western liberalism. What makes the current rupture different is that it targets the grammar itself. When America sanctions Europeans for regulating American companies under European law, it is not merely disagreeing about policy. It is declaring that the European conception of digital governance is itself illegitimate—an act of aggression requiring punishment.

The question is not whether transatlantic regulatory cooperation can survive this. It cannot, at least not in its previous form. The question is what replaces it.

Two Liberalisms, One Internet

The conventional framing presents this as a clash between American free speech absolutism and European content regulation. That framing is not wrong, but it is incomplete. The deeper conflict concerns where sovereignty resides in a networked world.

The EU’s Digital Services Act, which became fully applicable in February 2024, operates on a simple premise: platforms are not neutral conduits but active shapers of public discourse, and their power requires democratic accountability. The DSA mandates risk assessments, transparency in algorithmic systems, and mechanisms for removing illegal content. It treats platforms as infrastructure—like telecommunications or broadcasting—subject to public interest obligations.

American constitutional tradition treats this as heresy. The First Amendment protects speech from government interference; Section 230 of the Communications Decency Act shields platforms from liability for user content. Together, they create a regime where private companies make content decisions that governments cannot. From this perspective, the DSA does not regulate platforms—it conscripts them into state censorship.

Both positions contain internal coherence. Both claim to protect democratic values. And both are, in practice, extraterritorial. American platforms serve European users under American legal assumptions. European regulations constrain American companies operating globally. The internet made this collision inevitable; politics merely determines its timing.

What the sanctions reveal is that the United States has abandoned the fiction that these two systems can coexist through diplomatic management. The EU-US Trade and Technology Council, established in 2021 as a forum for coordinating approaches to digital governance, now resembles a building whose foundation has been removed. The structure remains. The purpose has vanished.

The Audience Cost Mechanism

Sanctions are instruments of pressure. But they are also performances. Understanding why the Trump administration chose this particular form of escalation requires understanding who the audience is.

Visa restrictions under Section 212(a)(3)(C) of the Immigration and Nationality Act are bureaucratic tools—ordinarily quiet, deniable, reversible. What made the December announcement unusual was its public naming of targets. This feature, rare in diplomatic practice, transforms administrative action into political theater.

By naming Thierry Breton and four other Europeans, the State Department created what political scientists call “audience costs”—the domestic political price a government pays for backing down from a public commitment. The administration has now staked its credibility on confronting European “censorship.” Retreat would signal weakness. The sanctions have become self-reinforcing.

This is not accidental. Rubio’s framing—“censorship-industrial complex,” “radical activists,” “weaponized” regulation—draws directly from American culture-war vocabulary. The DSA becomes not a regulatory framework but a front in the battle against progressive overreach. The domestic political utility of this framing explains its intensity.

But audience costs cut both ways. The European Commission responded by “strongly condemning” the sanctions and promising to “respond swiftly and decisively to defend our regulatory autonomy.” European officials now face their own audience costs. Accommodation looks like capitulation. The structure of the confrontation makes de-escalation politically expensive for both sides.

The Sovereignty Trap

Beneath the rhetoric lies a genuine dilemma that neither side has resolved: how to govern global platforms through territorial law.

The DSA attempts this through market access. Platforms serving European users must comply with European rules or face fines up to 6% of global annual turnover. This creates powerful incentives for compliance. But it also creates extraterritorial effects. When Meta or X adjusts its content policies to satisfy European regulators, those adjustments ripple through the platform globally. European law shapes American speech.

The US House Judiciary Committee’s report of July 2025 made this explicit: “European regulators define political speech, humor, and other First Amendment-protected content as ‘disinformation’ and ‘hate speech,’ and then require platforms to change their global content moderation policies to censor it.” The complaint is not merely that Europe regulates differently. It is that Europe’s regulations constrain American expression.

From Brussels, the mirror image applies. American platforms dominate European digital life. Their algorithms shape what Europeans see, read, and believe. Their terms of service override European legal traditions. American Section 230 immunity means European users have no legal recourse when platforms fail them. European regulation is, from this perspective, a defensive assertion of sovereignty against American digital colonialism.

Both sides are right. Both sides are also trapped. The internet’s architecture makes jurisdictional boundaries porous. Every assertion of sovereignty by one party constrains the sovereignty of the other. There is no neutral ground, only competing claims to authority over the same digital space.

The Infrastructure of Divergence

Regulatory cooperation requires more than goodwill. It requires institutional machinery—regular meetings, shared definitions, mutual recognition agreements, and bureaucracies that speak each other’s language. The transatlantic relationship built this machinery over decades. The sanctions are dismantling it.

The Trade and Technology Council was designed precisely to manage digital governance disputes before they escalated. Its working groups on platform regulation, data flows, and AI standards created channels for technical negotiation below the political radar. These channels remain formally open. But sanctions against officials who participated in DSA enforcement send a clear message: engagement is complicity.

The effect is to poison the bureaucratic well. European officials now face career risk from cooperation with American counterparts. American officials must treat European regulatory enforcement as adversarial rather than allied. The institutional muscle memory of cooperation atrophies. What replaces it is the institutional muscle memory of confrontation.

This matters because regulatory divergence, once established, compounds. Different definitions of illegal content require different compliance systems. Different transparency requirements create different data architectures. Different liability regimes shape different business models. Each divergence increases the cost of future convergence. The path dependence is relentless.

Platforms will adapt. They will create regional versions, segment their user bases, and build compliance walls between jurisdictions. The unified global internet—already fragmenting under Chinese and Russian pressure—will fracture further along transatlantic lines. Not because technology requires it, but because politics demands it.

The Paradox of Enforcement

The EU faces a peculiar problem: its regulatory power depends on the continued presence of the platforms it regulates.

The DSA’s enforcement mechanism—massive fines calculated as percentages of global revenue—assumes that platforms will pay rather than exit. This assumption holds for now. The European market is too large and too lucrative to abandon. But the assumption is not costless. Platforms that resent regulation can comply minimally, litigate endlessly, and invest in jurisdictions that welcome them.

More troubling is the possibility that the EU’s regulatory success creates its own obsolescence. If American platforms increasingly view European operations as legally hazardous, they may reduce their European footprint. Not withdrawal—that would be too dramatic—but gradual disinvestment. Fewer engineers in Dublin. Less infrastructure in Frankfurt. A slow hollowing out that leaves the regulatory framework intact but the regulated entities diminished.

The irony is sharp. The DSA was designed to make platforms accountable to European democratic values. But if platforms respond by reducing their European commitment, Europeans lose access to the services they sought to regulate. Sovereignty asserted becomes influence lost.

This dynamic creates perverse incentives. The EU needs platforms to remain engaged enough to regulate but not so dominant that regulation becomes impossible. Platforms need European market access but not so badly that they accept regulatory terms they consider illegitimate. The equilibrium is unstable. The sanctions have destabilized it further.

The China Variable

Every transatlantic dispute now occurs in the shadow of Beijing.

The strategic logic of Western regulatory cooperation was always partly about China. A unified transatlantic approach to platform governance, AI standards, and data protection would create a democratic alternative to Chinese digital authoritarianism. Fragmentation serves Chinese interests by eliminating the possibility of a coordinated Western model.

This was the implicit bargain of the Trade and Technology Council: Americans and Europeans would manage their differences privately to present a united front publicly. The sanctions shatter this bargain. They announce that the United States considers European regulation a greater threat than Chinese competition. They invite Beijing to position itself as a more reliable partner for European digital cooperation.

The EU is not naive about Chinese intentions. But it is also not immune to Chinese courtship. If American platforms become regulatory adversaries, Chinese platforms—already expanding in European markets—become more attractive partners. Not because Europe trusts China, but because Europe needs alternatives. The sanctions accelerate a reorientation that serves no Western interest.

There is a deeper strategic incoherence. The same American officials who sanction Europeans for content moderation celebrate Elon Musk’s transformation of Twitter/X into a platform where content moderation is minimal and verification is optional. The policy is not “free speech” in any principled sense. It is “our platforms, our rules”—a position that mirrors the Chinese approach the United States claims to oppose.

What Comes Next

The default trajectory is continued escalation. The EU has promised to “respond swiftly and decisively.” Response options include retaliatory visa restrictions, accelerated DSA enforcement against American platforms, or new regulations targeting American digital services. Each response invites counter-response. The cycle has no natural endpoint.

Three factors could alter this trajectory.

First, platform behavior. If American platforms voluntarily adopt transparency measures and content moderation practices that satisfy European concerns, the regulatory pressure diminishes. Musk’s X is unlikely to cooperate. But Meta, Google, and Apple have more to lose and more to gain from accommodation. Platform divergence—some companies cooperating, others resisting—could create space for selective de-escalation.

Second, electoral change. The sanctions reflect the priorities of the current American administration. A different administration might view European regulation differently. But electoral uncertainty cuts both ways. European officials cannot build policy on the assumption of American political change. And the institutional damage accumulates regardless of who holds power.

Third, crisis. A major platform failure—a terrorist attack coordinated on social media, a foreign influence operation that distorts an election, a viral disinformation campaign that causes real-world harm—could force reconsideration. Crises create political permission for cooperation that normal politics forecloses. But crises also create opportunities for further entrenchment. The outcome depends on which narrative captures the moment.

The most likely scenario is neither reconciliation nor complete rupture but managed estrangement. Formal mechanisms persist. Substantive cooperation withers. Each side pursues its regulatory vision independently, accepting the costs of divergence as preferable to the costs of accommodation. The West remains allied on security. It fragments on governance. The unity that defined the postwar order becomes a memory that shapes nothing.

FAQ: Key Questions Answered

Q: Are these actual economic sanctions or something else? A: The measures are visa restrictions under immigration law, not economic sanctions administered by OFAC. They prevent named individuals from entering the United States but do not freeze assets or prohibit financial transactions. The symbolic impact, however, exceeds the practical effect.

Q: Can the EU retaliate in kind? A: Yes. The EU can impose its own visa restrictions on American officials, accelerate enforcement actions against US platforms, or introduce new regulatory measures targeting American digital services. The Commission has explicitly reserved the right to “respond swiftly and decisively.”

Q: What happens to American tech companies operating in Europe? A: In the short term, little changes. Companies must continue complying with the DSA or face fines up to 6% of global revenue. The longer-term risk is that regulatory hostility encourages gradual disinvestment—fewer European employees, less European infrastructure, reduced European engagement.

Q: Does this affect other areas of US-EU cooperation? A: Not directly. Security cooperation through NATO, intelligence sharing, and military coordination operate on separate tracks. But the erosion of trust in one domain inevitably affects others. Officials who view each other as adversaries on digital governance will struggle to cooperate on other issues.

The Grammar of Dissolution

The transatlantic relationship was never merely an alliance. It was a shared project—an attempt to build international order on liberal democratic principles. That project assumed its participants agreed on what those principles meant. They no longer do.

The sanctions against European officials are not the cause of this dissolution. They are its symptom. The cause lies deeper: in divergent constitutional traditions, incompatible conceptions of platform power, and irreconcilable claims to digital sovereignty. The sanctions merely make visible what was already true.

What replaces the old order remains unclear. Perhaps a new accommodation will emerge, built on mutual exhaustion rather than mutual conviction. Perhaps the fragmentation will deepen until the very concept of “the West” becomes an anachronism. Perhaps some crisis will force a reckoning that politics alone cannot achieve.

What is certain is that the grammar of cooperation—the shared assumptions that made transatlantic regulatory coordination possible—has broken. Rebuilding it will require more than diplomacy. It will require answering questions that neither side has yet been willing to ask: What is a platform? What is speech? And who decides?

Those questions have no neutral answers. The fight over them has only begun.

Sources & Further Reading

The analysis in this article draws on research and reporting from:

• CNN: US Sanctions on European Officials - Primary reporting on the December 2025 visa restrictions
• European Commission: Digital Services Act - Official EU documentation on DSA implementation
• Le Monde: EU Response to Sanctions - European Commission’s formal condemnation
• The Verge: State Department Announcement - Coverage of Rubio’s statement and threat to expand sanctions
• EU-US Trade and Technology Council - Background on transatlantic cooperation mechanisms
• BBC: Digital Services Act Overview - Explanation of DSA requirements and penalties
• EUR-Lex: DSA Legal Text - Full text of Regulation EU 2022/2065