37It is true, as the Court has held on numerous occasions, that the cigarette market particularly lends itself to the development of unlawful trade (judgment of 13 December 2007 in BATIG, C‑374/06, EU:C:2007:788, paragraph 34 and the case-law cited). The obligation which stems from Article 20(3) of Directive 92/12, namely to take the necessary measures to deal with any offence or irregularity and to impose effective penalties, must be interpreted in the light of that finding.
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