Is Trump Lifting Sanctions? What OFAC Means for Polish Companies | Sanqto

Headlines about Trump and US sanctions on Russia raise one very specific question in the minds of business owners and the people responsible for compliance: if Washington is changing course, can we ease off too? The question is understandable — but it is addressed to the wrong authority. A Polish company is not bound by the law of the White House, but by the regulations of the Council of the European Union and the Polish Act of 13 April 2022 — and none of those acts has changed to follow Trump’s rhetoric.

This is a good occasion to calmly explain, once and for all, what OFAC is (the Office of Foreign Assets Control, an agency of the US Department of the Treasury), how it differs from EU sanctions, and when decisions made in Washington actually concern a company registered in Poland.

TL;DR — the essentials in 30 seconds

• Trump and OFAC can change US sanctions, but those changes do not directly concern a Polish company — it is bound by EU and Polish rules, not by Washington’s.¹²³
• Council of the EU Regulations No 269/2014 of 17 March 2014 and No 833/2014 of 31 July 2014 have direct effect in all Member States and require no decision from the US.¹²
• The Act of 13 April 2022 (Journal of Laws 2022 item 835) is an act of Polish law — decisions of the US administration do not repeal it.³
• The Polish sanctions list maintained by the Ministry of the Interior (MSWiA) is updated by Polish authorities — OFAC does not replace it, nor does it replace the EU list.³
• OFAC matters for your company only when you settle in USD, have US counterparties or partners, or export goods containing US-made components.
• In 2025–2026 the EU is consistently tightening sanctions — the 18th package (July 2025), the 19th package (October 2025), and the 20th package (April 2026) all expand the bans rather than lift them.⁴⁵⁶
• The sanction-screening obligation in Poland flows from EU and national law — a change in Trump’s policy neither removes nor narrows it.
• The SDN (Specially Designated Nationals — the list of entities blocked by OFAC) and the EU lists are two separate registers, each based on a different legal basis.

What did Trump actually do with US sanctions on Russia?

US sanctions against Russia have existed since 2014. They rest on a sequence of presidential Executive Orders — including EO 13660 (of 2014, which introduced the Russia/Ukraine-Related program) and EO 14024 (of 2021, which broadened the scope to the financial and technology sectors, among others) — and are extended by successive presidents. The details of these acts are available on federalregister.gov and directly on the OFAC pages.

The second Trump administration, which took office in January 2025, has taken a series of decisions on sanctions against Russia — some loosened particular restrictions, others tightened or maintained them. For the current state of OFAC’s Russia/Ukraine-Related sanctions programs — including what has been added, reversed, or modified — check directly on ofac.treasury.gov/recent-actions, where OFAC publishes all of its recent enforcement actions and list changes.

OFAC’s decisions concerning Russia are renewed annually by successive US administrations — current details are on the OFAC website. The important point is this: throughout this period, EU sanctions against Russia have not been suspended or lifted. Brussels is heading in the opposite direction to the signals coming out of Washington.

The conclusion at this stage is a single one: if you are a company registered in Poland with no exposure to the US market, then Trump’s decisions are an interesting news story, but they do not translate directly into your legal obligations.

Two different worlds: OFAC vs EU sanctions

The basic mistake repeated by the Polish business press is to treat “sanctions on Russia” as a single global construct. In reality you are dealing with at least three separate legal systems, with three different authorities and three different scopes of jurisdiction. A decision in one system does not override the decisions of the others.

How EU sanctions work in Poland — why a separate statute is not needed for every ban

EU regulations have direct effect — they enter into force and are binding without transposition into national law. Council Regulation (EU) No 269/2014 of 17 March 2014 (CELEX 32014R0269) requires, among other things, the freezing of all funds and economic resources of the persons and entities listed in Annex I ¹. Council Regulation (EU) No 833/2014 of 31 July 2014 (CELEX 32014R0833) prohibits, among other things, the sale, supply, and export of dual-use goods and technology to any natural or legal person in Russia ². Both of these regulations bind your company directly, regardless of any events across the Atlantic.

The Polish Act of 13 April 2022 on special measures to counter support for aggression against Ukraine and to protect national security (Journal of Laws 2022 item 835) adds to this a national enforcement apparatus and its own list of entities, maintained by the Ministry of the Interior (MSWiA) ³. For breaching the prohibitions set out in that Act, the Head of the National Revenue Administration (KAS) may impose a financial penalty of up to PLN 20,000,000 ³. Criminal liability — for an intentional breach — is a term of imprisonment of not less than 3 years ³. You can read more about the financial consequences in the article on penalties for breaching sanctions in Poland.

How OFAC works — US jurisdiction and the nexus test

OFAC operates on the basis of US territorial jurisdiction and the so-called nexus test. This means that OFAC applies to entities that have a connection to the US through the settlement currency (USD), the identity of a participant in the transaction (a US person), or the origin of the goods (US-origin goods).

The concept of a “US person” covers US citizens, permanent residents, entities formed under US law, and all persons physically present on US territory — a definition set out in 31 CFR and the analogous provisions of OFAC’s individual sanctions programs. If your subsidiary is registered in Delaware, or your CEO is a US citizen, OFAC may apply to that company’s or that person’s transactions even when the transaction itself takes place in Poland.

OFAC also has a tool called secondary sanctions — the ability to penalise non-US entities for supporting sanctioned parties. This tool is rarely applied to European companies that have no exposure to the US, but it exists and is an element of risk for those who settle in dollars. You will find a detailed discussion of the OFAC and SDN lists in the article on the OFAC list explained — what the SDN list is, and the legal bases of EU sanctions explains where the individual regimes come from.

When is a Polish company subject to OFAC?

Not always — but there are four specific situations in which you have to take it into account.

USD clearing through correspondent banks

Every payment in US dollars, no matter where it is initiated, passes through the network of correspondent banks in the US. A correspondent bank in New York is obliged to check the participants in a transaction against the OFAC lists — and it may block the transfer without prior warning if one of the participants appears on the SDN list. If you issue or pay invoices in USD, that blocking risk exists regardless of where you and your counterparty are registered.

A practical rule: if the invoice is in dollars, check both the EU Consolidated List and the OFAC SDN list. Not because you have such a legal obligation under EU law, but because the correspondent bank will do it for you and freeze the funds.

A US person in the ownership structure or management

If a US citizen, permanent resident, or entity registered in the US is part of your company’s ownership structure or that of its subsidiary, transactions involving that person or entity may fall under OFAC jurisdiction. The risk extends across the whole structure — a US person taking part in a transaction with an SDN-listed entity exposes all participants to consequences.

Exporting dual-use goods subject to the EAR

If you export goods that contain US-made components or US-origin technology, you are subject to the EAR (Export Administration Regulations, 15 CFR Parts 730–774). Exporting such products to Russia requires a licence from the Bureau of Industry and Security (BIS) — regardless of what EU sanctions prohibit. It is a separate regime that overlaps with the bans flowing from Reg. 833/2014. There is more context in the article on the Russia embargo.

The 50% rule — entities controlled by an SDN

The 50% ownership rule means that an entity controlled by a person or company on the SDN list to at least 50% is treated by OFAC as an SDN — even if it does not itself appear explicitly on the list. The EU applies a similar consolidation approach. You will find the details of this rule and its practical consequences in the article on the 50% ownership rule in sanctions. It means that checking only the immediate counterparty may not be enough — you have to reach deeper into the ownership structure.

The EU keeps tightening sanctions — the opposite direction to the US

To judge whether your company can “ease off” sanctions monitoring, it is worth looking at what the EU is doing — because it is the EU that is your direct regulator.

In July 2025 the European Union adopted the 18th package of EU sanctions against Russia ⁴. It lowered the price cap on Russian crude oil from USD 60 to USD 47.6 and introduced an automatic adjustment mechanism. Transactions with Nord Stream 1 and 2 were banned. A total of 444 so-called shadow-fleet vessels were added to the list.

In October 2025 the 19th package of EU sanctions was adopted ⁵. It introduced a ban on imports of LNG from Russia (long-term contracts from 1 January 2027, short-term ones after 6 months). It imposed a full ban on transactions with Rosneft and Gazprom Neft. Sanctions on the cryptocurrency sector were introduced for the first time. The shadow-fleet list grew to a total of 557 vessels.

In April 2026 the 20th package of EU sanctions was adopted — Regulations 2026/506 (amending Reg. 833/2014) and 2026/511 (amending Reg. 269/2014) — on 23 April 2026 ⁶. A new anti-circumvention tool was used for the first time. The lists gained 36 entities from the energy sector and a further 46 vessels (a total of 632 shadow-fleet units). You will find broader context on the legal changes across all the packages in the article on EU sanctions packages against Russia.

In parallel, the process of criminalising sanctions breaches is under way across the whole EU. Directive (EU) 2024/1226 of 24 April 2024 (CELEX 32024L1226, OJ L 2024/1226, 29.4.2024) requires Member States to penalise intentional breaches of EU restrictive measures ⁷. The minimum terms of imprisonment range from 1 to 5 years depending on the type of offence (Article 5(3)) ⁷. The transposition deadline expired on 20 May 2025 ⁷ — in Poland, work on an implementing bill is under way. The details are in the article on Directive 2024/1226 — the criminalisation of sanctions breaches.

The conclusion is simple: a Polish company cannot base its compliance strategy on decisions made in Washington. EU regulations have no automatic expiry date — the list of entities is reviewed at least every 12 months ¹, and the acts themselves may be suspended or repealed only by an active decision of the Council of the EU ². Lifting EU sanctions would require a unanimous decision of all Member States. As of May 2026 there is no indication whatsoever of any such direction.

Three scenarios — how this looks in your company

E-commerce store: delivery to Russia via a third country

A Polish company ships goods to Russia via Turkey or Kazakhstan, claiming “it’s a neutral country.” The problem is that Regulation 833/2014 prohibits the export of certain categories of goods to Russia regardless of the country of transit ². Circumventing sanctions through third countries is a breach and is expressly covered by EU rules — there is more on this mechanism in the article on circumventing sanctions through third countries. If, on top of that, the goods contain US-origin components, there is the added risk of breaching the EAR and drawing the attention of the BIS.

What you do: screen counterparties and verify that the goods are not covered by the export ban under the annexes to Reg. 833/2014. The country of transit does not relieve you of responsibility.

Importer: the supplier has a sanctioned entity in its structure

You import raw materials from a Russian trading company. It turns out that 60% of it is owned by an entity on the OFAC SDN list. Under the 50% rule — applied both by OFAC and, in a similar way, by the EU — the trading company is automatically treated as a sanctioned entity. If payment goes in USD, the correspondent bank may block it. If the owner entity is also on the EU Consolidated List, the obligation arises not from OFAC but from Reg. 269/2014.

What you do: you suspend the transactions and consult a lawyer. You do not assume that “since it isn’t explicitly on the EU list, it’s OK” — you check the entire ownership structure.

The bank rejects a transfer — how do you know why?

A bank in Poland suspends your transfer to a supplier without explanation. Such situations arise when the counterparty appears on the OFAC SDN list, the EU Consolidated List, or the Polish MSWiA list. The bank does not always state the reason for the block. What you do: you check the counterparty yourself in four registers — the EU Consolidated List, the OFAC SDN list, the UN list, and the MSWiA list — before you make another payment attempt. Which lists specifically bind a Polish company is described in the article on which sanctions lists apply to a Polish company.

What exactly to do — 5 decision questions

1. Do you settle with counterparties in USD? If so — include the OFAC SDN List as an additional source alongside the EU Consolidated List and the MSWiA list. Not because you have such a legal obligation under EU law, but because the correspondent bank will do it for you.

2. Is any counterparty registered in the US or does it have a US person in its ownership structure or management? If so — check the consequences of OFAC jurisdiction and consider legal advice for that specific relationship.

3. Do you import or export goods with US-made (US-origin) components? If so — check the EAR and the BIS licensing requirements (15 CFR Parts 730–774) regardless of EU sanctions.

4. Have you screened your counterparties against the EU Consolidated List and the Polish MSWiA list? If not — that is your legal obligation, flowing from Reg. 269/2014 and Reg. 833/2014 ¹² and from the Act of 13 April 2022 ³ — regardless of everything that is happening with OFAC. Check whether you even have a screening obligation: the sanction-screening obligation — who and when.

5. Do you know whether your counterparty has, in its structure, an entity controlled more than 50% by a sanctioned party? If not — check the entire ownership structure, not just your immediate trading partner.

How Sanqto can help

Sanqto is sanction-screening software installed within the client’s own network — your data never leaves the company’s infrastructure (on-premise). It screens simultaneously against the EU Consolidated List, the Polish MSWiA list, the UN list, and optionally OFAC SDN — in a single query, with a result in the MATCH / POSSIBLE / CLEAR model. Regardless of what is happening in Washington, your company has an up-to-date view of the status of all the required registers. The solution helps reduce operational risk and automates the counterparty-verification process that would otherwise have to be carried out by hand across four separate databases. If you run a travel agency, a real-estate agency, or an insurance company — see the industry pages (tourism, real estate, insurance). You will find ready-made templates for the implementation documents in the sanctions policy — document templates.

FAQ — frequently asked questions

If Trump lifts US sanctions, can my company resume business with Russia?

No. The EU sanctions flowing from Regulation 269/2014 and Regulation 833/2014 ¹² and the Polish Act of 13 April 2022 ³ apply regardless of any decision by the White House. Trump’s decision does not repeal acts of the Council of the EU or acts of the Polish Sejm. Resuming trade with Russia in full would require a unanimous decision of all EU Member States — and in 2025–2026 the EU has been consistently tightening the sanctions regime, not loosening it.

Does a small Polish company have to check the OFAC list?

Directly — only when it has USD exposure, US partners, or exports goods with US-origin components. Indirectly — the bank handling your dollar payments will check it for you and may block the transfer without warning. The obligation to check the EU Consolidated List and the Polish MSWiA list, however, applies to every company conducting transactions within the scope of Reg. 269/2014 and Reg. 833/2014 ¹² — regardless of size and sector.

What is the OFAC 50% rule and why does it matter?

The 50% ownership rule means that an entity in which a sanctioned person or company holds at least 50% of the shares is treated by OFAC as an SDN — even if it does not itself appear on the list. It applies to the entire ownership chain, not just the immediate counterparty. The EU applies a similar consolidation approach. So checking only the immediate trading partner may not be enough — the details are in the article on the 50% ownership rule.

What is the EU Consolidated List and how does it differ from the OFAC SDN?

The EU Consolidated List is the list of entities subject to EU sanctions, maintained by the European External Action Service (EEAS). The SDN List (Specially Designated Nationals and Blocked Persons List) is the OFAC list, maintained by the US Department of the Treasury. They are two separate lists — partly overlapping in terms of the entities covered, but based on different legal bases and with a different scope of application. You will find a detailed comparison in the article on which sanctions lists apply to a Polish company.

When do EU sanctions against Russia expire?

EU Regulations 269/2014 and 833/2014 have no automatic expiry date (no sunset clause). The list of entities in Reg. 269/2014 is reviewed at least every 12 months ¹, and the measures described in Reg. 833/2014 may be amended or repealed only by an active decision of the Council of the EU ². The successive packages — the 18th, 19th, and 20th — expand the scope of the bans, they do not narrow it ⁴⁵⁶. As of May 2026 there is no indication whatsoever of any intention to lift EU sanctions against Russia.

Legal basis

• 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 — OJ L 78/6, 17.3.2014 — 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 — OJ L 229/1, 31.7.2014 — CELEX 32014R0833
• Act of 13 April 2022 on special measures to counter support for aggression against Ukraine and to protect national security — Journal of Laws 2022 item 835 — ISAP
• 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 — OJ L 2024/1226, 29.4.2024 — CELEX 32024L1226
• 18th EU sanctions package — adopted 18 July 2025 — DG FISMA statement
• 19th EU sanctions package — adopted 23 October 2025 — DG FISMA statement
• 20th EU sanctions package — Regulation 2026/506 (amending 833/2014) and Regulation 2026/511 (amending 269/2014) — adopted 23 April 2026 — CELEX 32026R0506 / CELEX 32026R0511
• US Executive Orders (Russia/Ukraine-Related Sanctions) — details at federalregister.gov
• OFAC Russia/Ukraine-Related Sanctions — current information at ofac.treasury.gov/recent-actions
• Polish MSWiA sanctions list — lista.gov.pl (MSWiA)
• EAR (Export Administration Regulations) — 15 CFR Parts 730–774 — ecfr.gov

Footnotes

Information, not legal advice. This article is for information and educational purposes only and does not constitute legal advice. The specific legal assessment of an individual case should be carried out with a qualified lawyer specialising in sanctions and export-control law. Legal status: 2026-05-27.