EU Sanctions Helpdesk ¦ The ‘Best Efforts’ Rule under sanctions targeting Russia and Belarus

EU Sanctions Helpdesk ¦ The ‘Best Efforts’ Rule under sanctions targeting Russia and Belarus

Understanding the EU’s ‘Best Efforts’ Obligation in Sanctions Compliance: What Businesses Need to Know

Since June 2024, European Union individuals and businesses with ownership or control over entities outside the EU have been facing new responsibilities when it comes to enforcing sanctions against Russia and Belarus. The EU requires these operators to use “best efforts” to ensure that their foreign affiliates do not undermine the effectiveness of EU sanctions—even if those affiliates are outside the EU’s legal reach.

This reflects a growing focus on closing loopholes and preventing sanctioned goods or services from reaching their targets through indirect channels. It means that simply following the letter of the law is no longer enough. Instead, EU-based owners must actively work to prevent their foreign subsidiaries from engaging in activities that could weaken or bypass EU sanctions.

Bastian Schwind-Wagner
Bastian Schwind-Wagner "Since June 2024, EU individuals and businesses must use their best efforts to ensure that entities they own or control outside the EU do not undermine EU sanctions against Russia and Belarus. This means taking all necessary steps to prevent foreign affiliates from weakening the effect of these sanctions."

The article linked below explains in detail what it means to breach, circumvent, or undermine sanctions, and how the “best efforts” standard is different from previous requirements. It also outlines practical steps businesses should take to protect themselves, including risk assessments and setting up compliance programs.

Whether you’re an SME or a large multinational, understanding and implementing these new requirements is crucial. Read on for clear guidance, practical examples, and information about the support available from the EU Sanctions Helpdesk — so you can keep your business compliant and avoid costly penalties.

The information in this article is of a general nature and is provided for informational purposes only. If you need legal advice for your individual situation, you should seek the advice of a qualified attorney.
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  • EU Sanctions Helpdesk ¦ The ‘Best Efforts’ Rule under sanctions targeting Russia and Belarus ¦ Link

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Bastian Schwind-Wagner
Bastian Schwind-Wagner Bastian is a recognized expert in anti-money laundering (AML), countering the financing of terrorism (CFT), compliance, data protection, risk management, and whistleblowing. He has worked for fund management companies for more than 24 years, where he has held senior positions in these areas.
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