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ARTICLE · 07 AUGUST 2024

EU Targets Foreign Subsidiaries In New Sanctions Packages

Jones Day
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The European Union's latest sanctions packages in relation to Russia and Belarus impose novel obligations on EU companies with respect to their foreign subsidiaries' operations.

European UnionInternational Law
Nadiya Nychay
Nadiya Nychay
Rick van 't Hullenaar
Rick van 't Hullenaar
Ravelle Melissen
Ravelle Melissen
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The European Union's latest sanctions packages in relation to Russia and Belarus impose novel obligations on EU companies with respect to their foreign subsidiaries' operations.

On June 24 and 29, 2024, the EU adopted and published Council Regulation (EU) 2024/1745 and Council Regulation (EU) 2024/1865 (the "Amending Regulations"), imposing new sanctions relating to Russia and Belarus. The Amending Regulations include an obligation for EU operators to undertake their best efforts to ensure that non-EU companies they own or control do not participate in activities that undermine the relevant EU sanctions. This new measure establishes a new legal basis to hold EU parent companies liable for failure to take measures to prevent conduct of their foreign subsidiaries that is inconsistent with these EU sanctions.

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