On 22 November 2024, the European Commission updated its frequently asked questions on sanctions against Russia and Belarus (the FAQs ). The update explains the "best efforts" obligation under Article 8a of Council Regulation (EU) No 833/2014 ( Regulation 833 ) on the EU sanctions compliance obligations of EU operators and entities outside the EU, including those in Russia, that such operators own or control. This places a critical responsibility on EU operators to prevent any actions outside the EU that could undermine the prohibitions outlined in Regulation 833.