Background Article 8a of Council Regulation (EU) 833/2014 (the “EU Russia Regulations”) imposes obligations on EU parents to undertake “best efforts” to ensure that activities conducted by their non-EU subsidiaries do not undermine EU sanctions targeting Russia and Belarus. This requirement, which was introduced in June 2024, raises complex questions about the scope of EU sanctions and their applicability to the activities of non-EU entities. The Commission previously issued guidance in November 2024 in relation…
Background The European Union continues to expand its sanctions regime against Russia and Belarus. The latest – the 18th – EU Russia/Belarus sanctions package was published on 19 July 2025, and included a range of additional sanctions, mainly targeting the Russian energy, banking and military industries, but also individuals and the Russian shadow fleet (see our previous blog post on the 18th sanctions package). EU sanctions against Russia are enacted in the form of regulations,…
On 18 July 2025, the European Union adopted its 18th package of sanctions against Russia, including by amending Regulation (EU) 833/2014 and Regulation (EU) 269/2014. The EU also mirrored a number of measures and introduced additional designations in its Belarus sanctions by amending Regulation (EC) 265/2006. Adopted just two months after the 17th package, this latest round of measures reflects the EU’s continued strategic shift toward more dynamic, extraterritorial, and asset-specific sanctions and reinforces the…
The EU Commission has issued a factsheet shedding light on the relationship between Incoterms and EU sanctions compliance. It makes clear that the Incoterms “Ex Works” rule—which shifts responsibility and risk to the importer/buyer from the moment of collecting the goods—does not exempt EU-based exporters or sellers from their legal obligations under EU sanctions law. The Commission underscores that adherence to EU sanctions is mandatory for all individuals and entities under EU jurisdiction, regardless of…