SCENARIO 01
A freight order from an intermediary company
A freight forwarder takes regular orders from a logistics company whose UBO is in Annex I of Reg. 269/2014. Arranging carriage for it = providing a prohibited service.
Carrying cargo on the order of a company linked to the sanctions list is the provision of a service — and it's prohibited. The carrier and the freight forwarder are liable — not just the principal.
Yes. Carrying goods and arranging freight for an entity on the sanctions list is a prohibited provision of a service — liability covers the carrier and the freight forwarder, not just the principal.
Regulation (EU) 269/2014 prohibits making funds and economic resources available to listed entities, as well as providing services to them. Carrying cargo, arranging freight and logistics handling all fall squarely within that. The duty does not depend on whether the transport company is an AML obliged entity — it follows directly from sanctions law and reaches every link in the chain: the carrier, the freight forwarder and the logistics operator.
In transport it is rarely about a single client. One order ties together the principal, the consignor, the consignee of the cargo, the payer and the subcontractors. Any of them may be on the list or be controlled by a listed entity — including through a UBO hidden in the company structure. Verification should cover every party to the order, not just the company that signed the contract.
Beyond the ban on dealing with specific entities, sectoral sanctions also apply — Regulation (EU) 833/2014 restricts trade with Russia and the movement of certain categories of goods, including dual-use goods. For a transport company, then, the risk lies not only in the counterparty but also in the relationship itself: the route and the type of cargo. Sanction screening settles the first part of the equation — whether any party to the order is on the list.
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 real risk of cargo being detained and frozen, of vehicles standing idle, and of liability for the transport company's management.
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 freight forwarder takes regular orders from a logistics company whose UBO is in Annex I of Reg. 269/2014. Arranging carriage for it = providing a prohibited service.
A freight forwarder subcontracts the carriage to a carrier that was not screened. The subcontractor or its owner is on the list — paying for the service = making funds available to a listed entity.
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