Sanctions on Russia and Belarus & Export Control in Poland

Last Updated: 17.06.2026

Sanctions on Russia and Belarus & Export Control in Poland: Obligations, Penalties, and Risk Management

Exporting goods to Russia or Belarus is subject to restrictions resulting from economic sanctions. Since February 2022, multiple rounds of EU sanctions and Western sanctions have been adopted in response to Russia’s invasion, with the aim of protecting Ukraine’s territorial integrity and helping to reduce Russia’s ability to finance the war.

Due to the rapid changes in national and EU regulations, it is necessary to verify sanctions lists on a case-by-case basis to avoid the risk of unintentionally circumventing sanctions. As a result, many companies exporting goods to Russia or Belarus are choosing to implement advanced compliance procedures to effectively protect themselves against severe financial penalties, forfeiture of goods, and criminal liability.

Key risk areas

The biggest threat to businesses currently stems from circumventing imposed economic restrictions (sanctions). The threat stems not only from direct trade but, above all, from participation in the re-export of goods.

EU regulations (including Directive 2024/1226) explicitly mandate penalties for the deliberate circumvention of economic sanctions, including the concealment of actual beneficiaries. In the case of transit through countries subject to an embargo, the basis for a secure transaction is a detailed verification of the end-user.

Starting in 2025, Polish sanctions law requires the submission of a declaration regarding the final destination of the goods, under penalty of criminal liability. Any irregularities grant customs authorities the right to seize the goods and even to request a ruling for their forfeiture to the State Treasury (Article 14b(1) of the Act of April 13, 2022, on special measures to counteract support for aggression against Ukraine and to protect national security – the Sanctions Act).

Economic sanctions, foreign assets control and financial penalties

In addition to the risk of goods being detained, violating sanctions also entails severe financial penalties.

In Poland, failure to comply with the obligation to freeze assets or making goods available to entities on sanctions lists, including Russian entities, certain persons, Russian banks or entities linked to the Russian Central Bank, is punishable by administrative penalties of up to PLN 20,000,000. In turn, under the amended EU regulations, the authorities of member states may impose fines on companies of up to 5% of their total global turnover.

New customs declaration requirements from January 2025

The amendment to the Act on Counteracting Support for Aggression Against Ukraine of January 2025 (Act of January 9, 2025, amending the Act on Special Measures to Counteract Support for Aggression Against Ukraine and to Protect National Security, the Act on the National Revenue Administration, and the Act on Counteracting Money Laundering and Terrorist Financing, Journal of Laws 2025.172—amending act) introduced significant changes for businesses by tightening the rules for trade with countries at risk of circumventing restrictive measures (high-risk countries). 

The new regulations impose an obligation on exporters of goods subject to EU restrictions to attach a customs declaration to their declaration, under penalty of criminal liability. This document is intended to demonstrate, among other things, that transit constitutes only part of the transport route, that the goods will not be resold, and that the final destination of the goods is a third country other than Russia or Belarus.

Export control deadlines: The 45-day rule and risk of administrative fines

An important operational element of export controls is the so-called 45-day rule. This is the time limit within which the exporter must submit to the head of the customs and tax office an authentic document confirming customs clearance in the country of destination, starting from the date the goods were taken out of the EU customs territory (Article 14a(4) of the Sanctions Act).

Failure to submit such a document within the prescribed time limit results in the imposition of an administrative fine of up to PLN 500,000 (Article 14c); therefore, it is crucial to implement advanced compliance procedures, which ultimately enable effective process control and protection against financial sanctions.

Dual-use goods under EU sanctions and Russia sanctions programs

A specific area subject to export controls that requires particular attention from companies is dual-use goods. Although these are products intended for civilian use, their specifications allow them to be used for military purposes as well.

To prevent the supply of such goods to Russian military systems, trade in these items is subject to special oversight by state authorities, which apply expanded control mechanisms in this regard.

This is one of the areas in which sanctions against Russia directly affect Russia’s economy, defence capacity and access to sensitive technologies.

• Manufacturer’s liability: pursuant to the amendment to the Act, the National Revenue Administration (KAS) has gained the right to contact the manufacturer of the goods directly. In situations where customs authorities detect a high likelihood that an intermediary is circumventing sanctions, the head of the customs and tax office has the right to request evidence to verify the end-user directly from the manufacturer of the goods. To avoid the risk of a shipment being blocked or goods being confiscated, it is therefore important to maintain detailed documentation and conduct due diligence prior to the planned transaction.
• Imprisonment: In the context of trade in dual-use goods, it is worth noting that the European Union requires member states to expand the list of prohibited acts. Pursuant to Directive (EU) 2024/1226, EU member states are required to ensure that violations involving dual-use goods constitute a criminal offense not only in cases of intentional conduct but also as a result of “gross negligence” (Article 3(3)). Poland’s sanctions law for violating EU prohibitions provides for a prison sentence of no less than 3 years (Article 15(1) of the sanctions law). It is worth noting that Polish law directly imposes liability on the person responsible for concluding a commercial transaction—that is, directors, managers, or members of the management board—if such an offense was committed in the course of the company’s business (Article 15(3) of the Sanctions Act).
• Revocation of licenses: Another important risk is the loss of export licenses, which are essential for the completion of transactions. EU law grants competent authorities the power to refuse to issue, revoke, suspend, amend, or even completely withdraw an export license for dual-use goods if they deem it necessary for the effective enforcement of sanctions. Furthermore, in the event of serious violations, the directive explicitly permits imposing a ban on a company’s operations. Implementing advanced compliance procedures helps effectively manage risks and protect the business from sudden operational shutdowns.
• Implementing procedures: Under EU Regulation 765/2006, companies exporting certain technologies and components, designated as high-priority items, have a legal obligation to implement documented supply chain verification procedures. This means that companies are required to implement internal procedures, maintain documentation, and conduct risk assessments.

National List of the Ministry of the Interior and Administration

The foundation of the sanctions regime in Europe is the directly applicable EU lists of persons and entities subject to sanctions; these lists stem, among other things, from EU Regulations 269/2014 and 765/2006.

The European Council and EU institutions shape this framework as part of the EU’s common foreign policy, while Poland also maintains national instruments supporting the same government-level response – this includes a national sanctions list administered by the Ministry of the Interior and Administration (MSWiA).

Consequences of inclusion on the National Sanctions List

Inclusion of a company on the Polish list has immediate consequences, including:

• A complete freeze on financial assets and economic resources;
• An absolute prohibition on making any funds or resources available to such an entity;
• Exclusion of the entity from public procurement procedures in Poland.

Beneficial ownership, foreign assets and sanctioned capital structures

Sanctioned capital is often hidden, for example, abroad within complex capital structures. To effectively protect your business, you must conduct a thorough verification of the beneficial owners of every business partner. A lack of caution carries serious consequences, including the risk of losing the company’s assets. In such situations, the state has the right to appoint a temporary compulsory administration over the company for up to 36 months, which may lead to the forced sale of assets or their transfer to the State Treasury.

The combination of stringent EU regulations with national mechanisms, such as the Ministry of the Interior and Administration’s list, imposes high legal requirements on companies. A superficial check of a business partner is simply not enough.

To effectively protect against the confiscation of goods, massive fines, and even the seizure of the company’s assets, constant and thorough verification of supply chains is essential. This is precisely why the implementation of advanced compliance procedures is becoming the foundation for the safe operation and growth of a business.

Case study: Legal export of medical goods to Russia and Belarus

Sanctions do not mean a complete blockade of trade with Russia or Belarus. We regularly support our clients, including those in the medical sector, for whom the export of life-saving goods is the foundation of their business and, at the same time, a major administrative challenge. The law permits the legal shipment of such products thanks to exemptions for medical and pharmaceutical purposes, including under the provisions of Council Regulation (EC) No. 765/2006.

The interpretation of this concept by public authorities is very narrow; it is required to prove that the exported goods are essential for saving human life or health, and that replacing them with other products on the market is impossible. To obtain an export license for goods, it is therefore crucial to compile reliable documentation. 

It is advisable to plan in advance exactly what types of documents need to be obtained at each stage of the supply chain in order to demonstrate the necessity of the products in advance.

The complete set of documents should include:

• a detailed description of the medical application, precisely indicating the life- or health-saving medical procedures performed using this product;
• opinions from specialists or medical staff confirming the product’s intended use;
• internal procedures of the healthcare facility providing for the use of the product (documentation from the hospital or laboratory);
• clinical documentation indicating its use in healthcare.

If you need assistance obtaining an export license and compiling the required documentation, please contact us. Our experts will help you understand the legal requirements and guide you through the entire process so that you can conduct your business legally and without any issues.

FAQ: Sanctions on Russia and Belarus, export control and compliance obligations in Poland