SCENARIO 01
Buying a car through a shell company
A showroom sells a PLN 480k car to a company whose UBO is in Annex I of Reg. 269/2014. Releasing the vehicle = making an economic resource available.
Selling a car, a yacht or jewellery to a person on the sanctions list is the provision of an economic resource — and it's prohibited. The seller is liable.
Yes. Selling a high-value item to a person or company on the sanctions list is the provision of an economic resource subject to an absolute ban — liability rests with the seller.
Regulation (EU) 269/2014 prohibits making funds and economic resources available to listed entities. A car, a yacht, a watch or jewellery sold to a listed person is exactly such a resource — regardless of the form of payment and of whether the buyer collects the item in person. Some dealers in high-value goods are also an obliged entity under AML law, but the sanctions duty applies regardless of that status and binds every seller.
Beyond the ban on selling to listed entities, sectoral sanctions also apply — Regulation (EU) 833/2014 prohibits the sale and export of luxury goods to Russia, and analogous restrictions cover Belarus. High-value cars, yachts, jewellery and watches belong to the categories covered by that ban. For a dealer, then, the risk lies not only in the buyer but also in the destination the goods ultimately reach.
With high-value goods, purchase through a company, a proxy or a foreign entity is common. An invoice made out to a "clean" company does not mean the transaction is safe — it may be controlled by a UBO on the list. Verification has to cover not only the person at the table but also the buyer's company, its owners and the payer.
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. On top of that comes the risk of the transaction funds and the goods themselves being frozen, and of liability for the showroom's management and owner.
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 showroom sells a PLN 480k car to a company whose UBO is in Annex I of Reg. 269/2014. Releasing the vehicle = making an economic resource available.
High-value jewellery is bought by a proxy acting on behalf of a person on the sanctions list. Releasing the goods to a listed principal is a provision covered by the ban.
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