EU Sanctions Against Belarus — What Polish Companies Risk for Breaching Regulation 765/2006

Legal status as of: 2026-05-20.

If your company trades with Belarus, uses Belarusian carriers, or works with Belarusian counterparties — you are subject to EU sanctions in exactly the same way as when dealing with Russia. The legal basis is Council Regulation (EC) No 765/2006 of 18 May 2006 concerning restrictive measures directed against President Lukashenko and persons and entities associated with him.¹ This is not a regulation for banks — it applies to every company registered in the EU.

In Poland, breaching sanctions carries an administrative fine imposed by the Head of the National Revenue Administration (Szef Krajowej Administracji Skarbowej — KAS) of up to PLN 20,000,000 (Article 6(2) of the Act of 13 April 2022 on special solutions to counter support for aggression against Ukraine).² Below you will find everything you need to know: the legal background, the scope of the sanctions, the risk of circumvention through Belarus, and a practical counterparty screening checklist.

TL;DR — the key points in 30 seconds

• Legal basis: Council Regulation (EC) No 765/2006 of 18 May 2006 — directly applicable in Poland with no transposition required.¹³
• EU sanctions against Belarus have existed since 2006 (originally targeting political repression) and have been extended repeatedly — especially after 2020 and after 2022.
• The list covers individuals and entities linked to the Lukashenko regime, as well as sectoral prohibitions (export, import, financial services).
• Belarus is actively used to circumvent sanctions against Russia — this is the so-called circumvention risk, which affects your company even if you have no direct trade with Russia.
• Sanctions extend to any entity in which a listed person holds more than 50% of the shares or exercises control — the mere absence of a listed name from a contract does not release you from liability.⁴
• Penalty in Poland: up to PLN 20,000,000 administrative fine (Article 6(2) of the Act of 13 April 2022, imposed by the Head of KAS).²
• Following implementation of Directive (EU) 2024/1226, violations will also carry criminal liability — the Polish implementing bill is currently in progress.⁵

How EU sanctions against Belarus came about

The European Union introduced its first restrictive measures against Belarus in 2006 — in response to the political repression carried out by the regime of Alexander Lukashenko against the democratic opposition and journalists. The legal instrument adopted at that time remains in force today: Council Regulation (EC) No 765/2006 of 18 May 2006.¹

For many years the scope of the sanctions was limited — covering mainly asset freezes for selected officials and travel bans. The situation changed dramatically in 2020, when Lukashenko falsified the results of the presidential election and brutally suppressed mass protests. The EU responded with successive extensions of the list of individuals and entities subject to restrictive measures. A further catalyst came from incidents that violated international law, including the forced landing of a Ryanair passenger aircraft in Minsk in 2021.

February 2022 was a turning point. Belarus allowed Russia to use its territory to attack Ukraine, and Russian forces entered Ukraine from Belarusian soil. The EU responded with further, substantially broader packages of sanctions against Minsk — running in parallel with sanctions against Moscow. From that point on, the Belarusian sanctions have developed in ever-closer alignment with the Russian sanctions. That linkage — and the resulting risk for Polish companies — is discussed in detail in the sections that follow.

Legal basis — Council Regulation (EC) No 765/2006

Council Regulation (EC) No 765/2006 of 18 May 2006 is an EU act that is directly applicable in every Member State — including Poland — without any need for transposition into national law.³ This means your company is bound by it under EU law, not Polish law.

Regulation 765/2006 has been amended on numerous occasions — by successive Council Regulations and Commission Implementing Regulations. Each amendment added new individuals and entities to the annexes, or extended the list of prohibited categories of goods and services. The current consolidated text is available on EUR-Lex under CELEX number 32006R0765.¹

The accompanying instrument is a Council Decision under the Common Foreign and Security Policy (CFSP) — analogous to the structure of the Russian sanctions, where a Regulation is paired with a CFSP Decision. Both layers — the Regulation (directly applicable) and the Decision (binding on Member States in policy matters) — together constitute the EU sanctions regime against Belarus.

The consolidated list of entities subject to EU sanctions (including Belarusian entities) is maintained by the European Commission through DG FISMA — the Directorate-General for Financial Stability, Financial Services and Capital Markets Union.⁶ An overview of sanctions regimes is available through the EU Sanctions Map.⁷

What the sanctions against Belarus cover

EU sanctions against Belarus operate at two main levels: individual (persons and entities) and sectoral (prohibitions covering entire categories of goods and services).

Individual sanctions — lists of persons and entities

The first layer consists of asset freezes and travel bans for specific individuals and entities — named in the annexes to Regulation 765/2006. They include persons responsible for repression and human rights violations, as well as business entities linked to the regime or financing its activities.

A crucial rule: sanctions cover not only the entities listed, but also companies in which a listed person or entity holds more than 50% of the shares or exercises control (the ownership/control rule).⁴ If your Belarusian counterparty belongs — directly or indirectly — more than half to a listed person, any transaction with it is prohibited, even if the company name appears nowhere on the sanctions list.

Sectoral sanctions — goods and services

The second layer consists of sectoral prohibitions: the export of certain goods and technologies to Belarus, the import from Belarus of certain categories of raw materials and products, and the prohibition on providing certain services to Belarusian entities. Sectoral prohibitions against Belarus — analogous to the mechanism used in the Russian sanctions regime from EU sanctions packages against Russia — are based on CN (Combined Nomenclature) codes listed in the annexes to the implementing acts.

If you import or export goods from or to Belarus, checking your products’ CN codes against the current text of Regulation 765/2006 on EUR-Lex is an obligation, not an option.

Belarusian and Russian sanctions — the circumvention risk

This is the most important section for Polish companies that may have no direct relationship with Belarus at all — yet may still be exposed to sanctions risk.

Belarus as a route for circumventing Russian sanctions

Since 2022, Belarus has become one of the main routes through which goods subject to sanctions against Russia reach the Russian market. Electronics, machinery, and dual-use components — serving both civilian and military purposes — exported by EU companies to Belarusian recipients have ended up in Ukraine as Russian military equipment. The mechanism is straightforward: a Polish company sells goods to a Belarusian intermediary; the Belarusian intermediary re-exports them to Russia.

The EU is responding by broadening anti-circumvention clauses — measures designed to prevent the evasion of sanctions. In the Russian regime, this mechanism includes, among other things, an obligation to include a written “No re-export to Russia” clause in contracts with third-country counterparties for goods on specified lists.⁸ This approach is being progressively extended to related sanctions regimes, including the Belarusian one.

The practical consequence for your company: if you export goods to Belarus, you are obliged to conduct due diligence on end use and end users. It is not sufficient to establish that your direct counterparty is not on the list — if there is a risk that the goods will reach Russia, you are in breach of the sanctions regime. How to identify such a supply chain is explained in the article on circumventing sanctions through third countries.

The “mirror” structure of the sanctions

A growing number of measures in the Belarusian regime are being constructed in parallel with measures in the Russian regime. The EU often adopts them within the same timeframe — a “Belarusian package” frequently accompanies a Russian package, although it has separate numbering and a distinct legal basis. The result: the same goods may be prohibited both as an export to Russia (under Regulation 833/2014) and as an export to Belarus (under Regulation 765/2006).

When reading about EU sanctions against Russia — bear in mind that equivalent restrictions often apply to Belarus as well, although the scope and details may differ. Screening must be carried out against both regimes independently.

Which Polish companies are affected

EU sanctions against Belarus apply to every company registered in the EU — not only banks. Below are several sectors where the risk of violation is particularly real.

Trade and e-commerce. If you sell to Belarus online, by email, or through a commercial intermediary — check whether your goods appear on lists of prohibited exports. Also check whether the recipient or courier company is owned by a person on the sanctions list. The same 50% ownership rule applies as in the Russian regime.⁴

Transport and logistics. Belarus borders Poland. Polish carriers use Belarusian transit routes; Belarusian lorries operate on Polish roads. Every relationship with a Belarusian carrier or freight forwarder requires screening against the sanctions list — the company may be managed by a sanctioned individual.

Real estate. Individuals and entities from Belarus subject to sanctions have their assets in the EU frozen — including real estate. A real estate agency acting as an intermediary in the sale or letting of a property on behalf of a beneficiary on the sanctions list is committing a violation, even if unwittingly.

Tourism and OTAs. A travel agency serving a group from Belarus has no obligation to screen every individual tourist — but it does have an obligation to check the persons with whom it concludes contracts, particularly when organising corporate trips or events for Belarusian entities.

Financial services and insurance. The prohibition on providing financial services to listed entities also covers insurance brokers and agents. If you insure a Belarusian company or machinery belonging to a listed entity — you are in breach of the sanctions.

A full overview of obligations arising from EU sanctions and a catalogue of penalties for their violation can be found in separate articles.

Checklist — how to screen a Belarusian counterparty

Below are four concrete verification steps. Carry them out before every new transaction and after every update to the sanctions lists.

1. Download the current EU consolidated list. The European Commission (DG FISMA) maintains a consolidated list of all individuals and entities subject to EU sanctions.⁶ It is also accessible through the EU Sanctions Map (sanctionsmap.eu) — an interactive tool for browsing sanctions regimes.⁷ Download the XML or CSV file and search it against your counterparty’s details: company name, names of owners, identification numbers.

2. Check the ownership structure (UBO). Checking the company name alone is not sufficient. EU Regulations cover entities in which a listed person holds more than 50% of the shares or exercises effective control.⁴ Identify the Ultimate Beneficial Owner (UBO) of your Belarusian counterparty — and check them against the list. The UBO identification requirement also follows from the Act of 1 March 2018 on countering money laundering and terrorist financing.⁹

3. Check the Polish MSWiA list. Poland maintains its own sanctions list — administered by the Minister of Internal Affairs and Administration (Ministerstwo Spraw Wewnętrznych i Administracji — MSWiA) — at gov.pl/web/mswia/lista-osob-i-podmiotow-objetych-sankcjami.¹⁰ The Polish list may cover individuals and entities not yet included on the EU list. Check it independently of the EU list.

4. Verify the CN code of the goods. If the transaction involves goods — check the CN (Combined Nomenclature) code in the current text of Regulation 765/2006 and its amendments available on EUR-Lex. CN nomenclature uses eight-digit codes — search for the first four or six digits in the annexes to the Regulation.

5. Document the screening. Record every check in your internal register: date of screening, name of the individual or entity, list/source consulted, result (CLEAR / POSSIBLE / MATCH). Documentation is evidence of due diligence in the event of an inspection by the Head of KAS or MSWiA.

Penalties for breaching the Belarus sanctions

Violating Regulation 765/2006 or its associated acts constitutes a breach of EU sanctions — with identical consequences to breaching the Russia sanctions. In Poland, liability is governed primarily by the Act of 13 April 2022 on special solutions to counter support for aggression against Ukraine and to protect national security.²

Administrative fine. The Head of the National Revenue Administration (Szef KAS) may impose a financial penalty of up to PLN 20,000,000 for breach of the obligation to freeze funds or the prohibition on making funds available to sanctioned persons and entities — under Article 6(2) of the Act of 13 April 2022.² The same penalty is imposed by the Head of KAS for other breaches of the prohibitions established by that Act.

Criminal liability. Directive 2024/1226 of the European Parliament and of the Council of 24 April 2024 on the definition of criminal offences and penalties for the violation of Union restrictive measures requires Member States to introduce criminal liability for sanctions breaches.⁵ The transposition deadline was 20 May 2025. Poland is running a national implementing bill — the specific sentencing brackets will be known once the domestic implementing statute is enacted and published.

It is also worth noting that the Council Regulations and Decisions imposing restrictive measures are grounded in the EU Treaties — which means the Council can extend a sanctions regime quickly and without public consultation, and new provisions often enter into force the day after publication in the Official Journal of the EU.

A full description of the legal and financial consequences can be found in the article Penalties for breaching EU sanctions in Poland.

FAQ

How does Regulation 765/2006 differ from Regulation 269/2014?

Both are Council Regulations imposing sanctions, but they concern different countries.¹ Regulation (EC) No 765/2006 covers Belarus — it creates a sanctions regime targeting individuals and entities linked to the Lukashenko regime. Regulation (EU) No 269/2014 covers Russia — it creates a sanctions regime targeting persons responsible for undermining Ukraine’s territorial integrity. Your company may be subject to both simultaneously — for example, if it works with both Russian and Belarusian counterparties.

Do I need to check the 765/2006 sanctions list if I do not trade with Belarus?

Not necessarily with Belarus directly — but if you have counterparties in third countries through which Belarusian goods or services may pass, the anti-circumvention risk may still affect you. If your company has no relationships with Belarusian entities and does not export goods through Belarus, the risk is minimal. Nonetheless, checking — even once — whether any of your counterparties appears on the list is good compliance practice.

What does it mean that the sanctions have “direct effect” in Poland?

EU Regulations — including 765/2006 — are directly applicable in every Member State without the need to pass a separate national statute.³ A Polish company breaches them by virtue of EU law alone, even if no provision of Polish national law expressly describes the particular prohibition. Unlike Directives, which require transposition into national law, a Regulation applies automatically from the day it enters into force.

Does the sanction screening obligation apply to small companies?

Yes. The size of a company is irrelevant to the obligation to comply with EU sanctions. Regulation 765/2006 applies to any EU entity — a sole trader, a limited liability company, an association — if it enters into transactions with listed persons or entities, or trades in prohibited goods. More on who is subject to the sanction screening obligation is covered in a separate article.

How often is the EU sanctions list against Belarus updated?

The EU sanctions list is updated regularly — through Council Implementing Regulations adding new individuals and entities to the annexes. Updates may enter into force very quickly after publication in the Official Journal of the EU. Practical advice: do not rely on a one-off check — build screening into your counterparty onboarding process and repeat it regularly.

Where can I find the current Belarus sanctions list?

Three places: (1) EUR-Lex — the consolidated version of Regulation (EC) No 765/2006 with annexes (CELEX 32006R0765); (2) EU Sanctions Map (sanctionsmap.eu) — an interactive map of EU sanctions regimes;⁷ (3) DG FISMA (finance.ec.europa.eu) — the European Commission hub with a consolidated list of all sanctioned entities.⁶

How Sanqto can help

Sanqto is sanctions screening software installed on-premise — within your company’s own infrastructure, so your counterparty data never leaves your network. The system screens counterparties using a three-state MATCH / POSSIBLE / CLEAR model — it does not merely flag a hit; it gives your compliance officer the decision-making space needed for ambiguous cases. The declared response time is sub-30 ms, which means that screening does not hold up your sales or onboarding process. Sanqto automatically pulls in up-to-date lists — including the Belarusian regime from Regulation 765/2006, DG FISMA lists, the Polish MSWiA list, and OFAC and OFSI registers — so you do not need to manually track every update to the Official Journal of the EU. The software comes with a package of implementation documents ready for inspection by the Head of KAS or MSWiA.

Legal basis

• Council Regulation (EC) No 765/2006 of 18 May 2006 concerning restrictive measures in respect of Belarus — CELEX 32006R0765
• Council Regulation (EU) No 269/2014 of 17 March 2014 — restrictive measures in respect of Russia (lists of persons and entities) — CELEX 32014R0269
• Council Regulation (EU) No 833/2014 of 31 July 2014 — restrictive measures in respect of Russia (sectoral prohibitions) — CELEX 32014R0833
• Directive 2024/1226 of the European Parliament and of the Council of 24 April 2024 — criminalisation of violations of EU sanctions — CELEX 32024L1226
• Act of 13 April 2022 on special solutions to counter support for aggression against Ukraine and to protect national security (Journal of Laws 2022, item 835) — ISAP
• Act of 1 March 2018 on countering money laundering and terrorist financing (Journal of Laws 2018, item 723) — ISAP
• Polish sanctions list maintained by MSWiA — gov.pl/web/mswia
• EU Sanctions Map — sanctionsmap.eu
• DG FISMA — EU sanctions hub — finance.ec.europa.eu

Information, not legal advice. This article is for informational and educational purposes only. It does not constitute legal advice. Legal status as of: 20 May 2026. The specific obligations of your company depend on your business profile and require individual assessment — if in doubt, consult a lawyer or compliance adviser.