EU Sanctions Against Belarus — a Practical Guide for Polish Companies

Legal status as of: 2026-05-20.

If your company uses Belarusian carriers, buys goods through Belarusian intermediaries, or serves Belarusian clients — you are subject to EU sanctions regardless of whether you are aware of their existence. The legal basis is Council Regulation (EC) No 765/2006 of 18 May 2006 concerning restrictive measures in respect of Belarus.¹ This is not a rule for banks — it applies to every company registered in the EU.

This article does not cover the history of the sanction packages or their political background — you will find that in the article EU Sanctions Against Belarus — Overview of Packages and Legal Basis. Here the focus is different: you get concrete steps for screening a business partner, a pre-transaction checklist, and answers to the questions company owners most often bring to us.

TL;DR — the key points in 30 seconds

• Sanctions against Belarus apply to your company directly by force of EU law — no separate Polish statute is required.²
• The legal basis is Council Regulation (EC) No 765/2006 — in force since 2006, extended repeatedly, especially after 2020.¹
• Sanctions cover not only listed entities by name, but also any entity in which a listed person holds more than 50% of shares or exercises control.³
• Belarus is actively used to circumvent sanctions against Russia — the risk affects you even if you do not trade directly with Belarus.
• The most exposed sectors in Poland: road transport, trade and e-commerce (import/export), real estate, corporate travel, insurance.
• For a breach of sanctions, the Head of the National Revenue Administration (KAS — Krajowa Administracja Skarbowa) may impose a financial penalty of up to PLN 20,000,000.⁴
• Conduct screening against three lists independently: the EU consolidated list (DG FISMA), the Polish MSWiA list, and the OFAC list (where you have USD-denominated transactions).

EU sanctions against Belarus in brief — basis and scope

Council Regulation (EC) No 765/2006 of 18 May 2006 is an act of EU law directly applicable in Poland — like every EU regulation, it requires no transposition into national law.² Your company is bound by EU law, not Polish law, so the argument “no Polish statute has been enacted” changes nothing.

Sanctions operate at two levels. The first comprises individual prohibitions: asset freezes and travel bans for specific natural persons and entities listed in the regulation’s annexes — persons responsible for repression, regime officials, and associated businesspeople. The second comprises sectoral prohibitions: restrictions on imports and exports of selected goods and a ban on providing certain services to Belarusian entities.

The key rule you must remember: sanctions cover not only the entity explicitly named on the list. They also cover any entity in which a listed person or entity holds more than 50% of shares or exercises effective control (the so-called ownership and control rule).³ In other words — your counterparty’s name may not appear anywhere on the list, yet a transaction with them may still constitute a breach of sanctions. You must check the ownership structure, not just the company name.

The consolidated list of all entities subject to EU sanctions — including those under the Belarus regime — is maintained by the European Commission through DG FISMA, the Directorate-General for Financial Stability, Financial Services and Capital Markets Union.⁵ The list can also be browsed via the EU Sanctions Map.⁶

Which Polish sectors are most exposed

EU sanctions against Belarus apply to every company registered in the EU — but in practice certain sectors are significantly more exposed by the nature of their business.

Road transport and logistics is currently the greatest area of risk for Polish companies. Belarus borders Poland, and Belarusian transit routes and Belarusian transport companies are part of many Polish supply chains. Every customer or subcontractor from Belarus requires screening — the person managing a transport company may be a designated individual. If you commission transport from a Belarusian carrier and have not checked them against the list, you risk being charged with participating in a transaction with a designated entity.

Trade and e-commerce — here the risk lies on both sides: imports (goods from Belarus or via Belarus) and exports (selling goods to Belarusian recipients). Sectoral prohibitions apply to specific product categories — check the CN code of your goods in the current consolidated text of Regulation 765/2006 on EUR-Lex. Trading through intermediaries does not remove your liability.

Timber and wood products — Belarus is a significant exporter of timber, wood-based panels, and wood products. Polish sawmills, timber wholesalers, and furniture manufacturers face particular exposure to the risk of purchasing goods subject to sectoral restrictions or from entities linked to designated owners.

Fertilisers and agricultural chemicals — Belarus is one of the world’s largest producers of potash, a component of fertilisers. Post-2022 import restrictions have directly affected this sector. Polish agricultural companies and agri-trade businesses purchasing fertilisers through intermediaries should check their supply chain for Belarusian origin of goods or ownership.

Real estate — a real estate agency acting in a transaction on behalf of a designated person or entity commits a breach, even if it was unaware of the client’s status. Persons on the Belarusian list may hold property in Poland and attempt to sell or lease it through an agent.

Corporate travel and OTAs — a travel agency organising corporate trips for Belarusian entities or serving groups funded by a designated company should screen the contracting party, particularly when the agreement is concluded with a legal entity rather than a private individual.

Insurance — the prohibition on providing financial services to listed entities also applies to insurance brokers and agents. Insuring property belonging to a designated entity or a company linked to such an entity constitutes a breach that requires no malicious intent — negligence in screening is sufficient.

How to screen a Belarusian business partner — step by step

The process described below applies to every transaction: a new contract, a new order, and equally to the renewal of a long-standing relationship with a counterparty you screened a year ago. Lists are updated regularly and a past screening does not protect you against a breach today.

Step 1. Download the current EU consolidated list.

The European Commission maintains the consolidated list of EU financial sanctions covering all sanction regimes — including the Belarus regime under Regulation 765/2006.⁵ Download the list from the DG FISMA website in XML or CSV format. You can also use the EU Sanctions Map (sanctionsmap.eu) as a search interface.⁶ Search the full company name, name variants, names of owners, and all known identification numbers (Polish NIP, REGON, and foreign equivalents).

Step 2. Check the counterparty’s ownership structure (UBO).

A “no hit” result against the company name alone is not sufficient. EU sanctions cover entities in which a listed person holds more than 50% of shares or exercises effective control.³ Establish who is the ultimate beneficial owner (UBO) of your Belarusian counterparty and check that person against the list. The obligation to identify the UBO also arises from the Act of 1 March 2018 on Counteracting Money Laundering and Financing of Terrorism (Journal of Laws 2018, item 723 — the Polish AML Act).⁷

Step 3. Check the Polish MSWiA list.

The Polish sanctions list is maintained by the Minister of Internal Affairs and Administration (MSWiA — Ministerstwo Spraw Wewnętrznych i Administracji) and is available at gov.pl/web/mswia/lista-osob-i-podmiotow-objetych-sankcjami.⁸ The Polish list supplements the EU list — it may include persons and entities not yet listed at EU level. Check it independently and in parallel with the EU list.

Step 4. Check the CN code of goods, if the transaction involves goods.

If you are importing from Belarus or exporting to Belarus — check the CN (Combined Nomenclature) code of your goods in the current consolidated text of Regulation 765/2006 on EUR-Lex. Sectoral prohibitions are set out through CN codes in the regulation’s annexes. The CN is an eight-digit code — search the first four or six digits in the current text of the regulation.

Step 5. Document every screening.

Record every check in an internal register: date of screening, entity details, list/source consulted, result (CLEAR / POSSIBLE / MATCH), responsible person. Documentation is evidence of due diligence in the event of an inspection by the Head of KAS or MSWiA. No documentation means no evidence — and in the absence of evidence, an inspection works against you.

For more on how to build a screening procedure from scratch and what it should contain, see the article Sanctions Screening of Business Partners — How to Do It Right.

Trade via Belarus — re-export and transit risk

This is the section that companies who do not trade directly with Belarus — but may be doing so indirectly — should read carefully.

After 2022, Belarus became one of the main routes through which goods subject to Russia sanctions reach the Russian market. The mechanism is simple: a Polish company sells goods to a Belarusian intermediary, who re-exports them to Russia. The European Union responded by expanding anti-circumvention clauses — mechanisms designed to prevent evasion of sanctions. In the Russia regime (Council Regulation (EU) No 833/2014 of 31 July 2014), there is a requirement to include a written “No re-export to Russia” clause in contracts with third-country counterparties for specific product categories.⁹ A comparable approach is being extended to the Belarus regime.

The practical consequence for your company: if you export goods to Belarus, you have a due-diligence obligation regarding end use and the end user. It is not sufficient to confirm that your direct counterparty is not listed. If there is a reasonable risk that the goods will be re-exported to Russia — you are in breach of the sanctions framework as a whole.

It is also worth knowing that an increasing number of measures within the Belarus regime are being constructed in parallel to Russian measures — a prohibition covering exports to Russia often applies equally to exports to Belarus, albeit on a different legal basis. Check both regimes independently. An overview of sanctions against Russia, which will help you understand the links between the two regimes, is available in the article What Sanctions Apply to Russia and What Do They Mean for Your Company?

An additional risk is Belarusian transit: if your goods are transported via Belarus on the way to the Russian market — even without your knowledge — they may be intercepted or form the basis of a charge of sanctions evasion. When selecting a logistics route and freight forwarder, ask about the transport route and document the answer.

Checklist — what to do if you have a counterparty from Belarus

Below is a control checklist to be completed before every new transaction with a Belarusian entity or through a Belarusian supply chain. Complete all points and retain confirmation of each.

1. Establish the full name and all identification details of the counterparty — trading names, previous names, registration numbers.
2. Check the counterparty against the EU consolidated list (DG FISMA) — download the current file and search it manually or using a tool.⁵
3. Check the counterparty against the Polish MSWiA list — the list maintained by the minister responsible for internal affairs, available at gov.pl.⁸
4. Identify the UBO of the counterparty — who ultimately holds more than 50% of shares or controls the entity?³
5. Check the UBO against the EU list and the MSWiA list — a hit on the owner equals a hit on the counterparty.
6. Check the CN code of the goods (if the transaction involves goods) — verify sectoral prohibitions in the text of Regulation 765/2006 on EUR-Lex.¹
7. Assess re-export risk — could the goods reach Russia via a Belarusian intermediary? If so, obtain a written end-use declaration.
8. Document the entire screening — date, source, result, responsible person. Retain the documentation.
9. Set up alerts for list updates — or implement an automated screening tool so you do not have to track every update to the EU Official Journal manually.
10. Repeat the screening before renewing a contract — a past screening is not sufficient.

If you are unsure whether your company is obliged to conduct sanctions screening, you will find the answer in the article Does My Company Have to Conduct Sanctions Screening?

Penalties for breaching Belarus sanctions

A breach of Regulation 765/2006 or the related implementing acts constitutes a breach of EU sanctions. In Poland, liability for such a breach is governed primarily by the Act of 13 April 2022 on Special Solutions for Counteracting Support for Aggression Against Ukraine and for the Protection of National Security (Journal of Laws 2022, item 835).¹⁰

Administrative penalty. The Head of the National Revenue Administration (KAS) may impose a financial penalty of up to PLN 20,000,000 for a breach of the obligation to freeze funds or of the prohibition on making funds available to designated persons and entities, pursuant to Article 6(2) of that Act.⁴ The Head of KAS imposes the same penalty for other breaches of the prohibitions arising from that Act. The penalty is administrative in nature — meaning it can be imposed without a court decision and irrespective of whether the breach was intentional, although the degree of fault influences the amount.

Criminal liability. Directive (EU) 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 EU Member States to introduce criminal liability for intentional breaches of sanctions.¹¹ The transposition deadline was 20 May 2025. Poland is processing a national implementing bill — the specific penalty ranges will be known once the implementing act is enacted and published.

Personal liability. It is worth bearing in mind that criminal liability applies to natural persons — meaning it may extend directly to the company owner, chief executive, authorised signatory (prokurent), or the person responsible for the relevant area of operations, if the breach resulted from their decision or omission.

FAQ

What is the difference between the article on Belarus sanction packages and this guide?

The article EU Sanctions Against Belarus — Overview of Packages and Legal Basis describes the history of how the sanctions framework has expanded, the successive packages, and the legal background of Regulation 765/2006. This guide is operational — it explains what you specifically need to do: how to screen a counterparty, where to find the lists, what to watch out for when trading via Belarus, and how to build screening documentation.

Do small companies also have to apply Belarus sanctions?

Yes. Regulation 765/2006 is directly applicable in every EU Member State with no minimum threshold for company size or transaction value.² A sole trader and a company with a few employees are subject to the same obligations as large corporations. The absence of a screening procedure is not a mitigating circumstance — it is an additional argument in favour of imposing a penalty.

How do I check whether my goods are subject to an export or import ban?

Check the CN (Combined Nomenclature) code of your goods in the current consolidated text of Council Regulation (EC) No 765/2006 on EUR-Lex (CELEX 32006R0765).¹ The CN code is an eight-digit number — search the regulation’s annexes using the first four or six digits. You can also use the European Commission’s TARIC tool, which aggregates trade restrictions linked to individual customs codes.

What is the 50% rule and how do I apply it?

The ownership and control rule states that an entity is treated as being subject to sanctions if a listed person or entity holds more than 50% of its shares or exercises effective control over it.³ In practice, this means you must identify the ultimate beneficial owner (UBO) of your counterparty — checking only the company name on the invoice is not enough. Ownership links may be multi-layered: Company A is owned by Company B, which is owned by a listed person — and that is sufficient to make Company A subject to the prohibition.

What are the consequences of an unintentional breach?

The administrative penalty of up to PLN 20,000,000 imposed by the Head of KAS can be applied regardless of whether the breach was intentional — the determining factor is the fact of the breach, while the degree of fault influences the penalty amount.⁴ Documented, thorough screening prior to a transaction is the most effective risk-mitigation strategy: it demonstrates due diligence and materially reduces the likelihood of a penalty being imposed.

Where can I find the current list of Belarus sanctions?

Three places: first — EUR-Lex (CELEX 32006R0765), where the consolidated text of Regulation 765/2006 with its current annexes is available.¹ Second — DG FISMA of the European Commission (finance.ec.europa.eu), where the consolidated list of EU financial sanctions for all regimes, including Belarus, is available.⁵ Third — the EU Sanctions Map (sanctionsmap.eu) as a search and visualisation interface for EU sanctions regimes.⁶

How Sanqto can help

Sanqto is a sanctions screening software installed on-premise — within your company’s own infrastructure, so that counterparty data never leaves your network. The system automatically pulls the current lists — including the Belarus regime under Regulation 765/2006, the DG FISMA consolidated list, the Polish MSWiA list, and the OFAC list — and screens each counterparty using a three-state model: MATCH / POSSIBLE / CLEAR. Every screening generates a register entry ready to be presented during an inspection by the Head of KAS. The software is accompanied by an implementation document pack — a sanctions policy, a job-level instruction, and template export declarations. If you would like to see how it works in practice for your sector, start with the industry pages: travel agencies and OTAs or real estate agencies.

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 833/2014 of 31 July 2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine — CELEX 32014R0833
• Directive (EU) 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 — CELEX 32024L1226
• Act of 13 April 2022 on Special Solutions for Counteracting Support for Aggression Against Ukraine and for the Protection of National Security (Journal of Laws 2022, item 835) — ISAP
• Act of 1 March 2018 on Counteracting Money Laundering and Financing of Terrorism (Journal of Laws 2018, item 723) — ISAP
• Polish sanctions list maintained by MSWiA — gov.pl/web/mswia
• DG FISMA — EU consolidated financial sanctions list — finance.ec.europa.eu
• EU Sanctions Map — interactive tool for browsing EU sanctions regimes — sanctionsmap.eu

Information, not legal advice. This article is informational and educational in nature. 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.