SCENARIO 01
B2B sale with a corporate payment
A wholesale client pays from the account of a company whose majority shareholder is in Annex I of Reg. 269/2014. Fulfilling the order means making goods available — which is prohibited.
Shipping goods to a recipient on the sanctions list or under embargo is a prohibited transaction — including in dropshipping and cross-border sales. Liability sits with the seller.
Yes. Selling and shipping goods to a recipient on the sanctions list or under embargo is a prohibited transaction — the seller named on the invoice is liable.
Regulation (EU) 269/2014 prohibits making funds and economic resources available to entities on the EU list — and selling and releasing goods fall squarely within that. The duty does not depend on the size of the store or on whether it is an AML obliged entity. It is enough that the recipient or the payer is on the list for fulfilling the order to become a breach of the rules.
In retail sales to consumers the risk is low, but it rises sharply with B2B and wholesale orders. A corporate client pays from the account of a company whose majority shareholder may be on the list. That is why, for business orders, it is worth screening not only the counterparty's name but also the invoice details and the UBO of the payer.
The hardest area is cross-border shipping, dropshipping and marketplace sales. Goods can travel from the supplier straight to an intermediary in a third country that re-exports them to Russia — breaching the sectoral sanctions under Regulation 833/2014. The seller who issued the invoice remains liable, even if they do not know the end recipient.
The Act of 13 April 2022 provides for an administrative penalty of up to PLN 20M for breaching the ban. Directive (EU) 2024/1226 requires EU states to criminalise sanctions violations — in Poland it is being transposed by draft bill UC92. A real-world consequence is also the payment provider blocking the transaction and the marketplace suspending the seller's account.
This material is educational and does not constitute legal advice. Legal status: May 2026. Basis: Council Regulations (EU) 269/2014 and 833/2014 and the Polish Act of 13 April 2022.
A wholesale client pays from the account of a company whose majority shareholder is in Annex I of Reg. 269/2014. Fulfilling the order means making goods available — which is prohibited.
Goods travel from the supplier straight to an intermediary in a third country that re-exports them to Russia. The seller named on the invoice is still your store.
Deployed in 4 days, integrated with the e-commerce platform over an API. Payer screening runs automatically on B2B orders. Package: Business — 5 900 EUR one-time.
No salesperson, no slide deck. We'll show the install and answer the legal questions.