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Since the 11th package of sanctions against Russia came into force, everyone is obliged to provide information. Information on possible circumvention of the sanctions must be submitted to the competent authority within two weeks. The aim is to effectively combat the circumvention of sanctions against Russia. To date, Russia has still managed to obtain goods from the West that can be used for military purposes – usually by taking detours via third countries. To prevent this, German companies are being asked to provide information in the event of suspicion.

The obligation to provide information is set out in Article 6a of EU Regulation No. 833/2014. According to paragraph 1

“Natural and legal persons, entities and bodies shall

a) provide information that facilitates the implementation of this Regulation to the competent authority of the Member State in which they are resident or established within two weeks of receiving that information; and

(b) cooperate with the competent authority in the verification of such information.”

Stefanie Brzoska from Möllenhoff Rechtanwälte sees a number of problems with the practical implementation of the “Every Man’s Duty” regulation. According to the lawyer, only a small group of people may have necessary information for a positive suspicion.

Sources: Handelsblatt, Möllenhoff Attorneys at Law (German)