EU Commission clarifies ‘Best Efforts’ Obligations under Belarus and Russia Sanctions. Read out deep-dive for a detailed analysis of our obligations and download the guidance.
Following the EU's expanded sanctions against Russia and Belarus during the summer of 2024, new “best efforts” obligations were introduced to counteract sanctions circumvention. These obligations require EU-based entities to exert significant influence over their non-EU subsidiaries to ensure compliance with restrictive measures.
On November 22, 2024, the European Commission released its long-awaited guidance in Frequently Asked Questions (FAQs), clarifying the scope and expectations of these "best efforts" obligations.
This blog explores the nuances of the guidance, its implications for businesses, and actionable steps EU Operators can take to ensure compliance.
Questions we answer in this deep dive are:
Who is affected?
What activities fall under "best efforts" obligations?
When must EU Operators act?
What are the compliance expectations?
When can liability arise as a result of “best efforts” obligations?