Booking a package for a customer on the EU sanctions list is the provision of a service — and it's prohibited. Liability sits with the agency, not the traveller.
Yes. If you sell packages, bookings or concierge services, you are required to screen your counterparties against sanctions lists — regardless of whether you are an obliged entity under AML law.
The most common mistake is: "sanctions are a matter for banks". In fact, Council Regulation (EU) 269/2014 prohibits making funds and economic resources — including services — available to anyone on the EU list. The ban binds every company operating in the EU, and selling a trip, a ticket or a hotel package counts as "making a service available" within its meaning. Holding the status of an AML obliged entity changes nothing here.
The flashpoints are corporate and VIP clients, group bookings through intermediaries, and payments from foreign companies. A listed person rarely buys a package under their own name — they use a company, a foundation or an agent. That is why screening a name alone is not enough: you have to establish the UBO of the payer, especially with B2B collection.
Beyond the list of persons and entities, sectoral sanctions under Regulation 833/2014 also apply — including restrictions on flights, luxury services and certain destinations. A yacht charter, a premium service or arranging a trip to a restricted destination may breach the rules even when the client themselves is not on any list.
For making funds or services available to a listed party, the Act of 13 April 2022 provides for an administrative penalty of up to PLN 20M. Directive (EU) 2024/1226 additionally requires EU states to criminalise sanctions violations — in Poland it is being transposed by draft bill UC92. A documented screening procedure is at the same time evidence of due diligence.
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 corporate client books a package for the board. Payment by the company card; the company's majority shareholder is in Annex I of Reg. 269/2014. The agency provides the service → liability sits with the agency.
An agent sells a 40-person package to a "cultural foundation" with a Russian parent company. UBO screening exposes the link in seconds.
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