What sanctions apply to Russia and what do they mean for your business?

Sanctions against Russia represent one of the broadest regimes of economic restrictions the European Union has ever imposed — and your business is bound by them by law, regardless of whether you trade directly with a Russian partner or merely use Russian raw materials or services. If you have arrived here following a query from a lawyer, bank, or freight forwarder — this article explains what EU, US, and UN sanctions against Russia cover, which of them apply to companies in Poland, and what you need to do in practice.

The EU sanctions list against Russia grows with every new package. Keeping track of its contents is no longer only the concern of banks and large corporations — today it also affects travel agencies, estate agents, leasing companies, and software providers.

TL;DR — the key points in 60 seconds

• The European Union has adopted 20 packages of sanctions against Russia to date, the most recent in April 2026.¹ Every Polish company is bound by these rules directly, with no exceptions for SMEs.²
• Sanctions fall into two types: personal (freezing the assets of specific individuals and entities listed on the EU list) and sectoral (embargoes on certain goods, services, energy, and transport).
• The export of many categories of goods to Russia is completely prohibited or requires a special licence — the prohibition applies not only to direct exporters but also to intermediaries and freight forwarders.
• Polish companies that settle transactions in US dollars or have counterparties in the United States must additionally take into account the SDN List maintained by OFAC (Office of Foreign Assets Control, U.S. Department of the Treasury).³
• Breaching sanctions carries a financial penalty of up to PLN 20,000,000 imposed by the Head of the National Revenue Administration (Szef Krajowej Administracji Skarbowej, KAS)⁴; since 2024, Directive (EU) 2024/1226 also introduces criminal liability.⁵
• To check your company’s obligations, two steps suffice: verifying a counterparty against the EU consolidated list and checking whether your goods or services are subject to an embargo.
• The Polish sanctions list maintained by the Minister responsible for internal affairs (MSWiA — Ministry of the Interior and Administration) supplements the EU list — both apply simultaneously.⁶

How sanctions against Russia came about — a brief background

The first EU sanctions against Russia appeared in spring 2014, immediately after the annexation of Crimea. On 17 March 2014 the EU Council adopted Regulation No 269/2014 — a set of personal sanctions targeting specific individuals and entities involved in actions that undermine the territorial integrity of Ukraine.² Four months later, on 31 July 2014, Regulation No 833/2014 entered into force — these are sectoral sanctions, covering certain categories of goods and technologies.⁷

On 24 February 2022, following Russia’s full-scale invasion of Ukraine, the escalation of sanctions took on an unprecedented scale. Successive packages were adopted in an accelerated procedure — each one expanded the lists of designated entities or the scope of the embargo. By May 2026 the EU had adopted a total of 20 packages of sanctions, the most recent entering into force on 23 April 2026.¹

Poland responded with a separate national act: the 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, Dz.U. 2022 poz. 835)⁸ introduced a national sanctions list and a national penalty regime. Sanctions are a living, expanding system — a company that checked a counterparty a year ago must check again.

Three sanctions regimes against Russia — a comparison

Not all sanctions against Russia are the same. Three separate systems exist, differing in the authority imposing the restrictions, the legal basis, and the scope of applicability for Polish companies. The table below shows which regime applies to you directly.

A Polish company applies the EU list first — it is the broadest and most important regime. The UN list and the MSWiA list are supplementary or implemented through EU law. OFAC arises separately when your transaction has a so-called US nexus.

EU sanctions — what applies to Polish companies

EU regulations have direct effect in every Member State — they require no transposition into national law and apply from the date they enter into force.⁹ For your company this means one thing: you cannot hide behind the argument that “Poland has not passed a separate act.”

EU sanctions against Russia rest on two pillars. Regulation 269/2014 governs personal sanctions: the freezing of all funds and economic resources owned by entities listed in Annex I — a prohibition not just on holding such resources, but also on making them available directly or indirectly.² Regulation 833/2014 governs sectoral sanctions: an embargo on dual-use goods and technologies, prohibitions on services, and restrictions on transport and energy.⁷

The EU consolidated list contains more than 2,500 individual entries (position after the 18th package, July 2025) — and successive packages consistently increase that number.¹⁴ A one-off check is therefore not enough.

A detailed discussion of the individual packages and their impact on your business can be found in the article How many EU sanctions packages against Russia are there and what do they change?. What the sanctions list itself is and what an entry looks like is explained in the article What is a sanctions list and why does it affect your company?

US sanctions (OFAC) — when must a Polish company take them into account

OFAC is the Office of Foreign Assets Control, U.S. Department of the Treasury³ — the agency that maintains the SDN List (Specially Designated Nationals and Blocked Persons) and enforces US sanctions. This is neither EU law nor Polish law. It operates on the principle of extraterritoriality: OFAC can hold companies outside the US accountable if a given transaction has a so-called US nexus — settlement in US dollars, involvement of a US person (a US citizen, resident, or company incorporated in the US), or goods with a US-origin component.

For a Polish company that does not settle in USD and has no US counterparties, the OFAC risk is marginal. However, companies with global supply chains or foreign-currency transactions in dollars should monitor the SDN List independently of the EU list. Even if your direct counterparty is not on the OFAC list, a correspondent bank clearing a USD transaction may block the payment as a precaution.

UN sanctions list — hierarchy of regimes

The UN Security Council has its own sanctions mechanisms (Security Council Sanctions Committees) that form the basis for multilateral sanctions. The EU implements Security Council decisions through its own regulations, and at the same time maintains its own, more broadly scoped list — covering entities designated autonomously by the EU that do not necessarily appear on the UN list.¹¹

The practical significance for your company: the EU list goes further than the UN list. When you verify a counterparty against the EU consolidated list, you automatically cover persons subject to UN sanctions as well. There is no need to check both lists separately — provided you are up to date with the current EU list.

Sectoral sanctions — embargo on goods and services

Beyond the lists of designated persons, there is a second, equally important arm of sanctions: prohibitions and restrictions on specific goods and services. Even if your counterparty does not appear on any sanctions list, the transaction itself may be prohibited. The primary legal basis is Regulation 833/2014 and its successive amendments added by successive packages.⁷

Goods subject to the embargo are listed by CN (Combined Nomenclature) codes in the annexes to the regulations — a precise technical mechanism that allows an unambiguous determination of whether a specific product is subject to a prohibition.¹⁵

A detailed discussion of the list of prohibited goods can be found in the article Embargo on Russia — which goods and services are prohibited.

Which categories of goods are covered by the embargo

The scope of the embargo is broad and covers several distinct categories. Regulation 833/2014 prohibits the sale, supply, transfer, or export — directly or indirectly — of dual-use goods and technologies that may be used for military purposes or by a military end-user.⁷ The prohibition covers both export to Russia and the provision of technical and financial services related to such goods.

Successive packages extended the embargo to further categories:

• Advanced technologies — electronics, semiconductor components, drones, elements of navigation systems
• Luxury goods — defined by value in the annexes to Regulation 833/2014; verify the specific value threshold and list of goods in the consolidated text of the regulation on EUR-Lex
• Military technologies and defence equipment — total export ban
• Energy commodities — prohibition on importing oil, petroleum products, and natural gas from Russia to the EU (an import ban, the opposite direction to the above)
• Steel and iron — prohibition on importing Russian metallurgical products to the EU

To check whether your specific goods are subject to a prohibition: find the CN code of the product, then verify it in the TARIC database (a European Commission tool available at https://ec.europa.eu/taxation_customs/dds2/taric/taric_consultation.jsp¹⁶) or in the consolidated text of Regulation 833/2014 on EUR-Lex. The list of goods expands with every new sanctions package — a check carried out a year ago may already be out of date.

Prohibitions on services

The sectoral embargo covers not only goods — restrictions also apply to a wide range of services. Article 5n of Regulation 833/2014 governs the prohibition on providing a range of services to the Russian government and entities established in Russia.¹⁷

Prohibited services include, among others:

• Transport: prohibition on Russian lorries and trailers entering EU territory, and prohibition on servicing Russian vessels in EU ports¹⁸
• Advisory, management, and PR services: prohibition on providing business consultancy, accountancy, public relations, and similar services to Russian entities¹⁷
• IT and software: prohibition on the sale and transfer of enterprise management software and industrial design software¹⁷
• Legal services: the prohibition covers certain categories of legal advisory services — with exceptions for representation before courts and access to justice; the details of exemptions are set out in the DG FISMA FAQ on Article 5n (finance.ec.europa.eu/publications/provision-services_en)¹⁷

If you run a travel agency, bear in mind that the prohibition on servicing Russian airlines and the closure of EU airspace to Russian carriers has a direct impact on your business. For more on the specifics of the travel sector in the context of sanctions: Sanction screening for travel agencies.

The no-re-export declaration — a new obligation for exporters

Since the 11th sanctions package, adopted on 23 June 2023, EU exporters have an additional obligation: obtaining a written declaration from the buyer confirming that specified goods will not be re-exported to Russia or Belarus. The legal basis is Article 12g of Regulation 833/2014, introduced by the 11th package as a tool to counter circumvention of sanctions.¹⁹²⁰

The obligation applies to the export of specified goods — in particular dual-use goods and items on the Common High Priority Items list — to third countries.[^src28]

Practical significance: if you export to countries that, owing to their trade links with Russia, create a risk of sanctions circumvention, you are obliged to obtain and retain such a declaration. The absence of a declaration constitutes a breach of a procedural obligation — the exporter bears the liability.

More on transit risk and intermediary countries: Circumventing sanctions through third countries — risk for exporters.

The Polish MSWiA sanctions list — what it is and how it relates to the EU list

In addition to the EU consolidated list, Poland maintains its own national sanctions list. It is maintained by the Minister responsible for internal affairs — on the basis of the Act of 13 April 2022 on special solutions to counter support for aggression against Ukraine and to protect national security (Dz.U. 2022 poz. 835).⁸⁶ The Minister issues decisions on adding entities to the list and removing them from it.

The relationship to the EU list is straightforward: the EU list always applies to your company directly. The Polish MSWiA list is supplementary — entities against which restrictive measures have been applied under this Act, and which may not yet appear on the EU list, are added to it. Both lists apply simultaneously, so a company should verify counterparties against both.

The current list is available at gov.pl/web/mswia/lista-osob-i-podmiotow-objetych-sankcjami¹³. The total number of entries is not published in aggregate — the current full list is available directly on the MSWiA website.

A comparison of all sanctions lists (EU, UN, OFAC, MSWiA) in one place can be found in the article EU, UN, OFAC, and MSWiA sanctions lists — how they differ and how to check them.

What your company must do in practice — 5 steps

The steps below represent the minimum compliance scope for a company that trades with entities outside the EU or deals in goods that may be subject to restrictions. Carrying them out and documenting them significantly reduces legal risk.

Step 1 — Check whether your counterparties appear on the EU sanctions list

The EU consolidated financial sanctions list file is available on the DG FISMA page of the European Commission: https://webgate.ec.europa.eu/fsd/fsf#!/files¹⁰. You can also use the interactive sanctions map at sanctionsmap.eu.

Do not check only the name of your direct counterparty — check its owners as well. If an entity is more than 50% owned by a person or company on the sanctions list, that entity is automatically treated as being subject to sanctions.²¹ This rule also applies to indirect ownership links.

More on how to use the sanctions list step by step: What is a sanctions list and why does it affect your company?.

Step 2 — Check whether your goods or services are subject to an embargo

Find the CN code for your goods and check whether it appears in the annexes to Regulation 833/2014 and its amendments. The TARIC tool (European Commission)¹⁶ allows you to check the trade restrictions associated with a specific customs code. If you provide services — check the list of prohibited service categories under Article 5n of Regulation 833/2014.¹⁷

Step 3 — If you export to third countries, check the risk of sanctions circumvention

The European Commission identifies third countries with a continued and particularly high risk of re-export to Russia.²² If you export specified goods to such countries, you are obliged to obtain a no-re-export declaration under Article 12g of Regulation 833/2014.²⁰ Retain this declaration together with the transaction documentation.

Step 4 — Implement a regular sanction screening procedure

A one-off check is not enough — sanctions lists are updated after every new package, and packages have been adopted several times a year in 2022–2026. Set a minimum verification frequency: at every new transaction and after every new sanctions package. Automating this process significantly reduces the risk of missing an update.

If you are unsure whether your company has an obligation to conduct sanction screening at all, read: Does my company have to carry out sanction screening?

Step 5 — Document the verification and maintain a register

Documentation is your proof of due diligence in the event of an inspection or proceedings. Record: the date of verification, the source (name and date of the list), the result (no match or a match), and the person responsible for the verification and the decision. The AML Act of 1 March 2018 (for obligated institutions within the meaning of that Act) stipulates a 5-year obligation to retain documentation from the end of the business relationship (Article 49).²³ Even if your company is not an obligated institution within the meaning of the AML Act, maintaining an equivalent retention period is sound compliance practice.

Penalties for breaching sanctions against Russia

Breaching sanctions is not merely a reputational risk — it carries concrete financial consequences and, since 2024, criminal liability. The table below shows the main types of violation and the associated penalties.

Directive (EU) 2024/1226 of the European Parliament and of the Council of 24 April 2024⁵ obliges EU Member States to introduce criminal liability for intentional breaches of sanctions. The transposition deadline was 20 May 2025.²⁵ In Poland the legislative process is under way — the implementing bill is in progress (legal status: May 2026).

Criminal liability applies to natural persons — which means it can apply directly to members of a management board or company owners if the breach of sanctions resulted from their decision or omission. The authority imposing the administrative financial penalty is the Head of the National Revenue Administration (KAS) (Art. 6(2) of the Act of 13.04.2022)⁴²⁶. GIIF (Generalny Inspektor Informacji Finansowej — General Inspector of Financial Information) fulfils the role of the AML authority — it is not the principal supervisory body for sanctions violations by companies outside the financial sector.²⁷

A detailed analysis of penalties, including management board liability and a comparison of criminal regimes across the EU, can be found in the article What penalties apply for breaching sanctions in Poland and the EU?. On the state of transposition of Directive 2024/1226 in nine EU countries, read: Transposition of Directive 2024/1226 — 9 EU countries.

Are sanctions against Russia effective?

This is a question many readers ask themselves in the background — and it is worth addressing briefly. Assessing the effectiveness of sanctions is complex and depends on the criterion adopted. In the short term, Russia employed various adaptive mechanisms: trade via intermediary countries, alternative supply chains, a shadow fleet in shipping. In the long term, technological isolation, restricted access to advanced components, and financing difficulties have real economic consequences.

More important from your company’s perspective, however, is a different point: the effectiveness of the sanctions system depends in part on whether companies comply with it. Every transaction with a designated entity or a prohibited good weakens the system and — what matters from your risk perspective — constitutes a breach of the law regardless of any political assessment of the effectiveness of sanctions. The legal obligation exists regardless of what you think of sanctions as an instrument of foreign policy.

How Sanqto can help

Sanqto is sanction screening software installed within your company’s own infrastructure — data never leaves your servers. The system automatically verifies counterparties against the EU, UN, OFAC, and MSWiA lists and returns a result in one of three states: MATCH, POSSIBLE, or CLEAR, in under 30 ms. For every verification, an entry is generated in the match register — ready to present during an inspection. The implementation package also includes a sanctions policy, operational instructions, and templates for export declarations. If you would like to see how this works in practice for a company in your sector, start with the page for travel agencies and OTAs.

Frequently asked questions

Does a small company have to comply with sanctions against Russia?

Yes. EU regulations introduce no minimum threshold for company size or transaction value — they apply to all entities in EU territory.² Article 2(1) of Regulation 269/2014 applies to everyone on EU territory who holds, controls, or makes available funds or economic resources to sanctioned entities.

How do I check whether my counterparty is on the sanctions list?

Go to the DG FISMA page of the European Commission and download the current EU consolidated financial sanctions list file: https://webgate.ec.europa.eu/fsd/fsf#!/files¹⁰. You can also use the EU Sanctions Map search engine (sanctionsmap.eu). Remember the 50% ownership rule — if an entity’s owner appears on the list, the entity is also subject to sanctions.²¹

Do sanctions against Russia apply to purchasing Russian software?

Yes. Article 5n of Regulation 833/2014 introduces a prohibition on the sale and transfer of enterprise management software and industrial design software — this applies to both export and purchasing from Russian entities.¹⁷

What happens to a company that breaches sanctions unintentionally?

The Act of 13.04.2022 provides for financial penalties regardless of intent — due diligence is the key factor. If a company can document that it carried out verification against the available lists, the risk of an administrative penalty is lower, though not zero. Directive 2024/1226 draws a clear distinction between an intentional violation and a violation through negligence for the purposes of criminal classification.⁵

Do sanctions against Russia also apply to imports from Russia?

Yes — the prohibition applies in both directions. Regulation 833/2014 prohibits the import to the EU of, among other things, oil, petroleum products, steel, and iron from Russia.⁷ Sanctions are not one-sided — they cover both export to Russia and import from Russia.

Do I have to check my counterparties every month?

There is no statutory requirement for monthly verification, but sanctions lists are updated several times a year. Recommended practice is to verify at every new transaction and immediately after the entry into force of each new sanctions package. Automated sanction screening eliminates the need to manually track updates.

Does OFAC apply to a Polish company that does not settle in USD?

In the absence of a US nexus (no USD transactions, no US person, no goods with a US-origin component), the risk of direct application of OFAC rules is marginal. Companies with global supply chains, foreign-currency transactions, or counterparties linked to the US should, however, monitor the SDN List independently.¹²

Legal basis

Legal status as of: 2026-05-20.

• Council Regulation (EU) No 269/2014 of 17 March 2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty, and independence of Ukraine — CELEX 32014R0269

• 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

• 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, Dz.U. 2022 poz. 835) — ISAP / ELI

• 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 and amending Directive (EU) 2018/1673 — CELEX 32024L1226

• Implementing bill for Directive 2024/1226 in Poland (UC92) — implementing bill in the course of the legislative process (status: May 2026); track progress at legislacja.rcl.gov.pl

• Act of 1 March 2018 on countering money laundering and terrorist financing — ELI — Article 49 (documentation retention period)

• DG FISMA — Russia sanctions page: finance.ec.europa.eu — package timeline, FAQs, list files

• OFAC SDN List: ofac.treasury.gov

• Polish MSWiA sanctions list: gov.pl/web/mswia

Footnotes

Information, not legal advice. This article is for informational and educational purposes only. It does not constitute legal advice. Legal status as of: 2026-05-20. Your company’s specific obligations depend on its business profile and require individual assessment — if in doubt, consult a solicitor or compliance adviser.