What do the EU sanctions against Russia change for companies?

The European Union has already adopted 20 sanctions packages against Russia — the latest on 23 April 2026.¹² If you run a company in Poland — a travel agency, an online shop, an estate agency, leasing, insurance, telecoms — then your company too must, every few months, check whether a new package affects it.

Every few months you hear in the media: “the 19th package”, “the 20th package”, “a new sanctions package against Russia”. Most SME owners assume this is a matter for banks. Yet the Polish Act of 13 April 2022 provides for a financial penalty of up to PLN 20,000,000 for breaching sanctions obligations — and this penalty is imposed by the Head of the National Revenue Administration, not necessarily on a bank alone.³

Below you will find a 30-second summary, the full chronology of all 20 packages in a single table, a discussion of the three most recent ones (the 18th, 19th and 20th) and concrete steps: how, after each new package, to check whether it affects your company.

TL;DR — the essentials in 30 seconds

• The EU has already adopted 20 sanctions packages against Russia since 23 February 2022; the latest (the 20th) was published on 23 April 2026.⁴¹²
• A “package” is not a single legal act — it is a set of amendments to two base regulations: Council Regulation (EU) No 269/2014 (lists of persons and entities) and Council Regulation (EU) No 833/2014 (sectoral and goods bans).⁵⁶
• A typical package contains three things: new persons/entities on the list, new sectoral bans, new CN codes of goods covered by a ban.⁷⁸
• The packages do not concern banks alone — they catch travel agencies, insurers, real-estate agents, leasing, e-commerce and telecoms.
• You will find the current texts on EUR-Lex, on the DG FISMA website at the European Commission and in the Polish MSWiA list.⁹¹⁰
• After each package your company should: check its CN codes in the annexes, rescan counterparties against the updated lists, update the hit register.
• A breach in Poland carries up to PLN 20 million of administrative penalty (Article 6(2) of the Act of 13.04.2022, imposed by the Head of KAS), and once Directive 2024/1226 is implemented — also criminal liability.³¹¹

What an “EU sanctions package” means — a plain-language definition

A “sanctions package” is a media and political convention, not the name of a legal act. You will not find the word “package” in any Council regulation — the numbering of successive packages is informal and comes from communications by the European Commission (DG FISMA) and the Council of the EU.¹² For your company, something else matters: each package is a series of amendments to two base acts, plus possibly new implementing acts.

These two base acts are Council Regulation (EU) No 269/2014 of 17 March 2014 (lists of natural persons and entities subject to an asset freeze) and Council Regulation (EU) No 833/2014 of 31 July 2014 (sectoral bans — energy, finance, transport, dual-use, luxury goods).⁵⁶ Each of them is accompanied by a Council decision under the Common Foreign and Security Policy: Decision 2014/512/CFSP for 833/2014¹³ and Decision 2014/145/CFSP for 269/2014. How this system of acts is built — from the treaties to the Polish act — is explained in the article the legal basis of EU sanctions.

A single “package” usually consists of 5–15 separate documents: Council regulations, CFSP decisions, European Commission implementing regulations, communications and DG FISMA guidance. The proposal is prepared by the European External Action Service (EEAS) together with the High Representative; the text goes through COREPER (the Committee of Permanent Representatives); the Council of the EU adopts it unanimously; it then goes to the Official Journal of the EU and, as a rule, enters into force on the day following publication (sometimes with a transitional period for existing contracts).

Where the 20 packages come from. The first five (2014–2015) were a response to the annexation of Crimea and the destabilisation of the Donbas. Packages 1–20 in the EU’s current media numbering are, however, counted from 23 February 2022 — the date of the first package in response to Russia’s recognition of the Donetsk and Luhansk oblasts, two days before the full-scale invasion.⁴ The numbering the press refers to today (“the 18th package”, “the 19th package”) is the series running from 2022.

Chronology — all 20 packages in a single table

The table below sets out all 20 EU sanctions packages against Russia since the start of the full-scale invasion. Each row contains the date of publication in the Official Journal of the EU and a short description of the most important change. For packages 14 and 15 we also know the numbers of the main regulations (Reg. (EU) 2024/1745 and 2024/3192); for the others you will find the specific number of the amending regulation by the publication date on EUR-Lex.

The Commission keeps a full chronology with links to the OJEU on the official DG FISMA website — it is one of two places (alongside EUR-Lex) where it is worth going back for new information.² Packages 6 to 12 often have built-in transitional periods (phase-out periods) — the wind-down of existing contracts is usually spread over 3–12 months; you will find the details in the preambles of the successive amending regulations.

Full breakdown of the 20th sanctions package | Full breakdown of the 19th package — shadow fleet, crypto-assets, LNG | Detailed analysis of the 18th sanctions package

The two base regulations — 269/2014 and 833/2014

All 20 packages fit into one of two base regulations (sometimes both). Without understanding this pair, it is impossible to read the texts on EUR-Lex.

269/2014 — lists of persons and entities

Council Regulation (EU) No 269/2014 of 17 March 2014 governs the freezing of the assets of specific natural persons and entities (designated persons and entities) in response to actions undermining the territorial integrity of Ukraine.⁵ The annexes contain named lists: name, identification data, date of entry, statement of reasons. The lists are updated practically every week — more often through Council implementing regulations than as part of “packages”.

The total number of individual entries (persons + entities) on the EU lists against Russia after the 18th package of July 2025 exceeded 2,500 — and it grew in packages 19 and 20.³⁵ How fast this number is growing and what it means for companies is shown in the article the EU sanctions list in figures.

This is the list your company must check for every new counterparty — regardless of industry. We link to the full overview: which sanctions lists apply to Polish companies.

833/2014 — sectoral and goods bans

Council Regulation (EU) No 833/2014 of 31 July 2014 is the second pillar — sectoral bans (energy, finance, transport, dual-use, telecoms, IT services) and goods bans based on CN codes (the Combined Nomenclature) in the annexes.⁶ The annexes cover thousands of items: weapons, dual-use goods, critical technologies, oil, gas, luxury goods, iron and steel, cement, timber, aluminium, high-strength spirits, diamonds, gold.⁸

This regulation also operates the oil price cap mechanism for Russian oil (Art. 3n)³⁶ and a ban on providing certain services (Art. 5n) — accounting, advisory, legal, IT, marketing — to the Government of Russia and to legal persons established in Russia.³⁷ It is these two articles that are most often cited in questions from non-financial SMEs. For e-commerce, Art. 12g is key — the “No re-export to Russia” clause (we discuss it in a separate section below)²⁵, and for companies trading in goods from the CHP list — Art. 12gb on enhanced due diligence.³⁸

What the 18th package changes (July 2025)

The eighteenth sanctions package, published on 18 July 2025, strikes above all at Russia’s budget revenue from oil.³² Four of the most important elements from the point of view of a company in Poland:

1. Lowering of the oil price cap from 60 to USD 47.6 per barrel of Russian crude oil, with a dynamic mechanism ensuring that the maximum price stays 15% below the average market price of Urals over the last 6 months.³²
2. A ban on transactions with Nord Stream 1 and Nord Stream 2 — including with entities operating the pipelines.³²
3. A ban on importing products refined from Russian oil, even if the refining took place in a third country.³²
4. Extension of the shadow-fleet list to 444 vessels and 55 additional named entries — the total number of individual entries exceeded 2,500.³²

For a travel agency and e-commerce, the 18th package matters indirectly — new entities on the list mean the need to rescan counterparties. For the marine insurance industry (P&I clubs) and logistics — direct consequences when reinsuring and insuring cargo carried by vessels affected by sanctions.

Detailed analysis of the 18th sanctions package

What the 19th package changes (October 2025) — LNG, Rosneft, Gazprom Neft, shadow fleet, crypto

The nineteenth package was published on 23 October 2025 and is so far the largest intervention into the energy and financial infrastructure serving Russia.³³ The package affects five areas — we discuss them in turn.

A full ban on importing Russian LNG

The most talked-about element of the 19th package is the full ban on importing Russian LNG (Liquefied Natural Gas; CN code 2711 11 00).³³ The ban enters into force on two dates:

• Long-term contracts: the import ban applies from 1 January 2027 — a transitional period for existing long-term contracts.³³
• Short-term contracts: the ban applies 6 months after the regulation enters into force.³³

Note a common misunderstanding: the 19th package concerns LNG, not LPG. LPG (Liquefied Petroleum Gas, propane-butane) was covered by an import ban earlier — its embargo already appears in DG FISMA’s baseline description of the energy sanctions regime as being in force before October 2025, having been introduced in the earlier 2022 packages.¹⁹

For Polish gas importers, LNG terminals and energy trading, this means the practical end of Russian LNG on the EU market from January 2027 — from a compliance point of view: review long-term contracts, update sanctions clauses, prepare a wind-down plan.

A full transaction ban for Rosneft and Gazprom Neft

For the first time, a full transaction ban covers the two largest Russian oil companies: Rosneft and Gazprom Neft.³³ Earlier packages introduced partial restrictions (a ban on new investments, restrictions on technology transfers). A full ban means that no EU entity may conclude transactions with these companies or with their subsidiaries — unless it obtains an individual national derogation.

The shadow fleet — 557 vessels in total

The 19th package added further vessels to the “shadow fleet” list — the total number rose to 557.³³ The shadow fleet consists of tankers circumventing the oil price cap, registered in third-country jurisdictions (Panama, Liberia, the Marshall Islands, the Comoros), often with falsified insurance documentation and AIS switched off. For Polish insurers, marine brokers and logistics companies — the obligation to verify every vessel before insuring or chartering it.

The first sanctions on the crypto sector

The 19th package introduces the EU’s first-ever sanctions on the crypto sector in the context of Russia.³³ They concern selected Russian Virtual Asset Service Providers (VASPs). For Polish crypto exchange bureaus, exchanges and fintech companies, this means an obligation to update KYC procedures (Know Your Customer — verifying the customer’s identity) and sanction screening to include the new entities from the list.

Banks from third countries

For the first time, the 19th package covers banks from outside the EU and Russia — selected financial institutions from third countries that helped circumvent sanctions.³³ The mechanism: anti-circumvention, that is, penalising intermediaries in evading the bans. The consequences for Polish companies with relationships with partners in Central Asia, the Middle East and the Caucasus: the need for additional due diligence for every transfer and every transaction.

Full breakdown of the 19th package — shadow fleet, crypto-assets, LNG

What the 20th package changes (April 2026) — the latest

The twentieth sanctions package was published on 23 April 2026. The Commission emphasises its strong “anti-circumvention” character and its robust energy measures.¹

Three elements worth knowing:

1. 36 energy-sector listings — covering both the upstream segment (extraction) and the downstream segment (distribution).¹
2. The first-ever activation of the “anti-circumvention” tool — a formal mechanism allowing sanctions to be imposed on entities from third countries actively circumventing EU bans.¹
3. 46 additional shadow-fleet vessels + one significant maritime insurer — the total number of vessels on the list rose to 632.¹³⁴

What next. The Commission is working on further measures — the direction is the continued tightening of anti-circumvention, bringing in intermediaries from third countries and clarifying due diligence obligations for industries trading in CHP (Common High Priority) goods.³⁸

Full breakdown of the 20th sanctions package

Which non-financial companies the packages affect — industries

Sanctions packages are not a problem for banks alone. Each of the non-financial industries below has specific obligations with each new package — sometimes obvious, sometimes hidden in a single article of Regulation 833/2014.

Travel agencies and OTAs

There is no ban on trips to Russia — that is a myth. There are, however, three real obligations: do not sell bookings or services to persons on the 269/2014 list; do not cooperate with Russian tour operators subject to sanctions; be careful when handling visa support for people whose names appear on the list. Package 7 introduced additional restrictions on the provision of services to Russian entities (Art. 5n of Reg. 833/2014).³⁷

Details: Sanction screening for travel agencies and OTAs.

Real-estate brokerage

A ban on intermediation in real-estate transactions for persons and entities on the 269/2014 list — whether they are buyers, sellers or ultimate beneficiaries of purchasing companies. The obligation to check the beneficial owner of companies (UBO) is real: an agent who ignores a sanctioned beneficiary may be liable criminally and administratively.

Details: Sanction screening obligations for estate agencies.

Insurance (brokers, agents, reinsurance)

A ban on providing marine insurance for tankers on the shadow-fleet list — after packages 17, 18, 19 and 20 that is over 600 vessels.^31323334 Sanctions exclusion clauses in policies are now standard, but every broker must have an up-to-date mechanism for verifying ship owners and charterers.

Details: Sanction screening in the insurance industry.

Leasing

A ban on supplying certain vehicles and equipment to Russia — including luxury cars and dual-use equipment. You will find the price threshold for luxury items and the specific CN codes in the annexes to Reg. 833/2014.⁸

A leasing company concluding contracts with business counterparties has a sanction screening obligation — it should check whether the sanction screening obligation applies to its activity.

E-commerce

Three obligations for an online shop selling abroad: do not ship goods from the CN list to Russia or Belarus (luxury goods, electronics, dual-use); check buyers against the 269/2014 and 765/2006 (Belarus) lists; apply the “No re-export to Russia” clause (Art. 12g of Reg. 833/2014) in contracts with counterparties from third countries, if the goods are on the list covered by the clause obligation.²⁵

Re-export to Russia through third countries is today the main risk for exporters — how to recognise it is described in the article circumventing sanctions through third countries.

Telecoms

A ban on broadcasting selected Russian state media in the EU (Art. 2f of Reg. 833/2014) — cable TV operators and OTT platforms must block transmission.³⁹ Plus a ban on providing certain telecommunications services to entities on the list, plus export bans on telecommunications equipment under certain CN codes. Operators concluding corporate contracts should check what penalties apply for breaching sanctions.

The “Not to Russia” clause (No re-export to Russia clause)

One of the most frequently overlooked obligations for Polish exporters. The “Not to Russia” clause was introduced in the 11th sanctions package (23 June 2023) as Art. 12g of Regulation 833/2014.²⁴²⁵ It requires an EU operator exporting certain goods to a third country (e.g. Turkey, Kazakhstan, Armenia, Georgia, the UAE, China) to include in the contract with the counterparty a written clause prohibiting the re-export of those goods to Russia — together with a contractual penalty for a breach and an obligation to notify the competent authority if a breach is detected.

In practice: a Polish online shop sells electronics to a company in Kazakhstan. If the goods are on the list covered by the clause obligation, and the Polish seller does not have the required “No re-export” clause in the contract, they are liable for a sanctions breach — even if they did not themselves send the goods to Russia. The Polish administrative penalty can reach PLN 20 million (Article 6(2) of the Act of 13.04.2022).³

For industries trading in CHP goods (Common High Priority items — electronics, semiconductors, dual-use components) an obligation of enhanced due diligence has been added under Art. 12gb of Reg. 833/2014.³⁸ That means: it is not enough to have a clause in the contract — you must also prove that you have checked the counterparty, its supply chain and the end user.

EU sanctions packages against Belarus — the link to the Russian packages

Belarus has its own legal order: Council Regulation (EC) No 765/2006 of 18 May 2006 concerning restrictive measures against President Aleksandr Lukashenko and certain officials of Belarus.⁴⁰ After 2020 (the rigged presidential election) and after 2022 (Belarus’s involvement in supporting the aggression against Ukraine), the scope of Regulation 765/2006 was extended many times.

The Belarusian packages have separate numbering, but they are often adopted in parallel with the Russian packages (e.g. in the same week). The list of Belarusian persons and entities is a separate annex to 765/2006 — you check it independently of the 269/2014 list, but within the same sanction screening procedure.

EU sanctions packages against Belarus — the full chronology.

Why new packages take a long time to weigh up — vetoes, compromises, derogations

Typically 4–12 weeks pass between the announcement of a proposal and a package entering into force. The reason: each package requires unanimity in the Council of the EU (Art. 215 TFEU and Art. 29 TEU) — it is enough for one state to block it for negotiations to drag on for weeks.

The history of recent years: Hungary and Slovakia blocked sanctions on Russian gas and pipeline oil (the result: derogations for Druzhba); Malta and Cyprus negotiated exceptions concerning shipping and maritime transport; Austria sought exemptions for Raiffeisen Bank International. For your company this means a practical piece of advice: do not wait for a package to start due diligence — the compliance process must be set up regardless of the political cycle.

The second mechanism: phase-out periods. Most bans enter into force with a transitional period (3–12 months) for the wind-down of existing contracts. Example: the ban on importing LNG in the 19th package has 6 months for short-term contracts and applies from 1 January 2027 for long-term ones.³³ Every company in a transitional period should have a schedule: when it terminates the contract, when it reports a freeze, when it updates its records.

Step by step — how to check whether a new package affects your company

A procedure of 30 minutes’ work after each new package:

1. Download the text of the package from EUR-Lex or the DG FISMA website. Enter the regulation number on EUR-Lex or go to the DG FISMA page “Sanctions adopted following Russia’s military aggression against Ukraine” — you will find there links to all acts together with the chronology.²
2. Search for your CN codes in the annexes. Open the goods annexes of Reg. 833/2014 (key: annex numbers are listed in Articles 3, 3a, 3i, 3k etc.), Ctrl+F → enter the first 4–6 digits of your CN code. If you find it — check whether the ban concerns imports, exports or both directions, and whether it requires the “No re-export” clause (Art. 12g).²⁵
3. Check your counterparties against the updated lists. Lists to check: 269/2014 (Russian persons and entities)⁵, 765/2006 (Belarus)⁴⁰, the Polish MSWiA list⁹¹⁰, OFSI (UK) and OFAC (US) if you have USD touchpoints⁴¹⁴². In practice: download the current lists in CSV or XML format and compare them with your counterparty database.
4. Update the internal hit register. Enter the “last screened” date, the package number, the result (CLEAR / POSSIBLE / MATCH). The register is an obligation flowing from the Act of 13.04.2022 — during a KAS or MSWiA inspection you must show evidence that you check counterparties systematically.⁴³
5. Notify the management board and lawyers if a contract becomes covered. Options: suspending the transaction, applying for a national derogation, a wind-down within the transitional period, reporting an asset freeze to MSWiA. The decision must be documented — a record, a dated email, a management-board decision.

What KAS, MSWiA, GIIF and other authorities oversee — penalties

In Poland, responsibility for enforcing sanctions is divided among several authorities — this often surprises SME owners.

• MSWiA maintains the Polish sanctions list. The decision on entry or removal is issued by the minister responsible for internal affairs — on their own initiative or on the application of the Head of the ABW (Internal Security Agency), AW (Foreign Intelligence Agency), CBA (Central Anti-Corruption Bureau), the Police, GIIF, the KNF or KAS.⁹
• The National Revenue Administration (KAS) controls goods and CN codes at the border and imposes most administrative penalties for breaching sanctions. A financial penalty of up to PLN 20,000,000 for breaching the obligation to freeze funds or the ban on making funds available (Article 6(2) of the Act of 13.04.2022) is imposed by the Head of KAS.³ The Head of KAS imposes the same maximum penalty for breaching the ban on importing coal from Russia or Belarus (Article 12(2) of the Act of 13.04.2022, covering CN codes 2701 and 2704).⁴⁴
• The President of the Public Procurement Office imposes a financial penalty of up to PLN 20,000,000 for the participation of a person or entity from the list in a public procurement procedure (Article 7(7) of the Act of 13.04.2022).⁴⁵
• GIIF (the General Inspector of Financial Information, within the Ministry of Finance) — supervision of obliged institutions under the AML Act (Anti-Money Laundering; in Poland: the Act of 1 March 2018, covering, among others, banks, currency exchange offices, accounting offices, notaries).⁴⁶ Most non-financial SMEs are not directly subject to GIIF, but some industries are (e.g. real-estate agents, accounting offices).
• Confiscation of property covered by sanctions — possible under the Act of 13.04.2022 and new mechanisms at EU level (including the mechanism for using Russian assets for a reparations loan to Ukraine).

Criminal liability — an important change from 2024. Directive (EU) 2024/1226 of the European Parliament and of the Council on the definition of criminal offences and penalties for the violation of Union restrictive measures introduces ranges of penalties that Member States must implement into national law.¹¹ The full catalogue of penalties — administrative and criminal — is discussed in the article what penalties apply for breaching sanctions.

In Poland, the draft implementing Directive 2024/1226 (designation UC92) is in progress in the Sejm (as at May 2026).

How Sanqto can help

Sanqto is sanction screening software installed on-premise — within your company’s network, so your counterparties’ data does not leave your infrastructure. The system works in a three-state MATCH / POSSIBLE / CLEAR model — instead of a binary “green/red” it gives the compliance officer a third state (POSSIBLE), that is, decision-making space for ambiguous hits rather than just a green and a red light. The declared response time is sub-30 ms under typical operating conditions , so verifying a counterparty does not block the sales, booking or leasing-offer process. We automatically pull the current lists from DG FISMA, the EU Sanctions Map, the Polish MSWiA list and the OFSI and OFAC lists — you do not have to track the Official Journal of the EU every week. With the software we include a package of implementation documents (a sanctions policy, a job instruction, a hit register, a risk assessment) ready for a KAS or MSWiA inspection. More in our overview which sanctions lists apply to Polish companies and in the legal basis of sanctions packages.

FAQ

How many EU sanctions packages against Russia are there?

The EU has adopted 20 sanctions packages against Russia (as at 17 May 2026). The first was published on 23 February 2022 — in response to Russia’s recognition of the Donetsk and Luhansk oblasts, two days before the full-scale invasion. The latest (the 20th) was adopted on 23 April 2026.⁴¹²

When did the 19th sanctions package enter into force?

The nineteenth EU sanctions package against Russia was published on 23 October 2025. Key changes: a full ban on importing Russian LNG (long-term from 1.01.2027, short-term after 6 months), a full transaction ban for Rosneft and Gazprom Neft, 557 shadow-fleet vessels, the first sanctions on the crypto sector, sanctions on banks from third countries.³³

What does the 19th sanctions package contain?

Five areas: (1) a full ban on importing Russian LNG (CN code 2711 11 00) with a phase-out to 1.01.2027 for long-term contracts; (2) a full transaction ban with Rosneft and Gazprom Neft; (3) extension of the shadow-fleet list to 557 vessels; (4) the first sanctions on the crypto sector (Russian VASPs); (5) sanctions on selected banks from third countries helping to circumvent the restrictions.³³

When will the 21st sanctions package come?

As at 17 May 2026 there is no official proposal for a 21st package. The practice of the cycle is that the Council of the EU adopts a new package every 4–6 months — so, roughly, the second half of 2026. It is decided by the situation on the Ukrainian front and internal negotiations in COREPER.

Do sanctions packages concern banks only?

No. The packages cover every company in the EU that has any point of contact with a person or entity from the 269/2014 or 765/2006 list, or with goods covered by a ban in 833/2014. Banks have additional, more stringent AML obligations, but the obligation not to conclude transactions with persons from the list and not to trade banned goods applies to all companies — including travel agencies, online shops, estate agencies, leasing, insurance and telecoms.

How do I check whether my product is covered by a package?

Download the text of the current Regulation 833/2014 from EUR-Lex (the consolidated version) or the current package from the DG FISMA website². Open the goods annexes and search for your CN code (the first 4–6 digits). Check whether the ban concerns imports, exports or both. If you sell through a third country — check whether the goods are covered by the “No re-export to Russia” clause obligation (Art. 12g).²⁵

What are the penalties for breaching sanctions in Poland?

In Poland, up to PLN 20,000,000 of administrative penalty (Article 6(2) of the Act of 13.04.2022 — the penalty is imposed by the Head of KAS and concerns a breach of the obligation to freeze funds).³ Additional administrative penalties of up to PLN 20 million are imposed by the President of the Public Procurement Office (public procurement, Article 7(7))⁴⁵ and by the Head of KAS for the coal import ban (Article 12(2)).⁴⁴ Once Directive 2024/1226 is implemented — also criminal liability; the detailed ranges will be known once the Polish implementing act is enacted (draft UC92).¹¹

Where can I find the current lists of persons and entities subject to sanctions?

Three basic sources: the EU Sanctions Map (sanctionsmap.eu) — an interactive map of EU sanctions regimes maintained by the General Secretariat of the Council of the EU⁴⁷; EUR-Lex (CELEX 32014R0269 for persons, CELEX 32014R0833 for sectoral bans)⁵⁶; the Polish MSWiA list published at gov.pl/web/mswia¹⁰. For comparison with the USA and the UK, it is also worth tracking OFAC (the Specially Designated Nationals List)⁴¹ and OFSI.⁴²

Legal basis and sources

Base EU acts (sanctions against Russia):

• Council Regulation (EU) No 269/2014 of 17 March 2014 — lists of persons and entities → CELEX 32014R0269
• Council Regulation (EU) No 833/2014 of 31 July 2014 — sectoral and goods bans → CELEX 32014R0833
• Council Decision 2014/512/CFSP — the act accompanying 833/2014.
• Council Decision 2014/145/CFSP — the act accompanying 269/2014.

Base EU act (Belarus):

• Council Regulation (EC) No 765/2006 of 18 May 2006 → CELEX 32006R0765.

EU directives:

• Directive (EU) 2024/1226 of the European Parliament and of the Council of 24 April 2024 (criminalisation of sanctions breaches) → CELEX 32024L1226

Polish legal acts:

• Act of 13 April 2022 on special measures to counter support for aggression against Ukraine and to protect national security → ISAP, Journal of Laws 2022, item 835
• Act of 1 March 2018 on counteracting money laundering and terrorist financing — for context.

Institutions and reference materials:

• DG FISMA — sanctions against Russia — chronology + links to each package.
• EU Sanctions Map — an interactive map of regimes.
• The Polish MSWiA sanctions list.
• OFAC — Ukraine-/Russia-related Sanctions.
• OFSI — Office of Financial Sanctions Implementation.

Information, not legal advice. This article is informational and educational in nature. It does not constitute legal advice. Legal status as of: 18 May 2026. Your company’s specific obligations depend on its business profile, the CN codes of its goods, its counterparties and require an individual assessment — if in doubt, consult a lawyer or compliance adviser.