Sanctions on Russia and Belarus – legal advice

The European Union has been slapping economic, business and personal sanctions against Russia, its citizens and business entities since 2014.

It is very important to regularly check the current legal status whenever you make transactions and do business to see if the deal breaks or circumvents any sanctions.

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Sanctions – legal advice

Thanks to our international experience and in-house tools, we are happy to help you:

in checks and verifications;
assess transactions in terms of sanctions imposed on Russia and Belarus.

Our experts

Rafał Szymański
Attorney at law (Poland)
Senior Associate

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Alicja Szyrner
Attorney at law (Poland)

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Sanctions on Russia and Belarus

The sanctions are designed to weaken the economy of Russia by, among other things, denying it access to critical technologies and markets, and thus limit the Russian government’s economic capacity to run the war in Ukraine. The economic sanctions target mainly the Russian financial, trade, power, transport, technology and defence industries as well as services performed for Russia or Russian entities and citizens.

The EU has also adopted sanctions against Belarus, Iran and North Korea for supporting Russia in its aggression against Ukraine.

Regardless of the EU sanctions, Poland has adopted its own laws that supplement the Community's sanction packages.

Obligations for enterprises

The sanctions include bans on exports to and imports from Russia and Belarus of certain goods and technologies, as well as a ban on performing certain services for Russia and Russian entities and citizens.

If you work with individuals or businesses included on the sanction list, you are obliged to freeze their assets and you must not provide them with economic resources they could use to e.g. carry on trading.

The EU takes a number of anti-circumvention actions. In particular, it has prohibited to transit dual-use goods and technologies as well as combat products to third countries through Russian territory, and has banned re-export and use of goods and particularly vulnerable technologies in Russia.

The scope of sanctions is growing and new sanction packages are adopted along the protracted war in Ukraine.

Liability

Individuals or entities are subject to a fine – imposed by the Head of the National Revenue Administration by means of an official administrative decision – of up to 20 million zloty if they fail to:

freeze money and economic resources;
immediately provide information required by EU regulations;
comply with the prohibition of participating, knowingly and intentionally, in activities the object or effect of which is to circumvent the measures referred to in EU regulations.

Polish sanction laws also stipulate criminal liability of individuals who violate sanction laws in their business or function.