On 24 June 2024, the European Union (EU) implemented its
14th package of sanctions against Russia to combat its
continued aggression against Ukraine. A notable addition was made
to Article 8a of Council Regulation (EU) No 833/2014, which
introduced the requirement that EU operators "undertake their
best efforts to ensure that any legal person, entity or body
established outside the Union that they own or control does not
participate in activities that undermine the restrictive measures
provided for in [the] Regulation." A similar clause has also
been included in the Belarus sanctions framework.
On 22 November 2024, the European Commission (the Commission)
published
FAQs to clarify the "best efforts" obligation (the
FAQs). This post provides a brief summary of the Commission's
answers to some of the most frequently asked questions regarding
the parameters of "best efforts."
