EU publishes new best efforts guidance for Russia and Belarus sanctions

21 August 2025

The EU has published new ‘best efforts’ FAQs under the Russia and Belarus sanctions regime. See our EU guidance pages for these FAQs and other FAQs on Russia and Belarus sanctions. Further information can be provided by the EU sanctions helpdesk, according to the guidance.

EU individuals, businesses and entities that own or control entities outside the EU are required under Regulations 833/2014 (Russia) and 765/2006 (Belarus) (the Regulations) to use their best efforts to ensure that EU sanctions are not undermined by those entities. The new guidance says:

• Undermining sanctions for the purposes of the Articles 8a of the Russia and 8i of the Belarus Regulations means undertaking an activity that weakens the effect of sanctions.

• ‘Best effort’ means a ‘high degree of effort’ and ‘all actions that are necessary and feasible’ to prevent undermining sanctions. The EU Commission’s FAQs on the Russia Regulations define best efforts in the same way.

• What best efforts means for a business will be ‘situation-specific’. Best efforts need to be ‘calibrated to the sanctions risk your business is exposed to’; the higher the risk, the more work is required to ensure compliance.

• Lack of feasibility may occur where a foreign affiliate cannot be control because of countermeasures in place in their country.

• EU businesses should ‘take steps to develop EU sanctions compliance within affiliates they own or control before a crisis situation develops’.

• If businesses are exposed to trade involving Russia or Belarus, they should (1) undertake a risk assessment; (2) implement a sanctions compliance programme; and (3) plan ahead to ensure best efforts are adhered to.