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Good to know Amended Polish Sanctions Act

Amended Polish Sanctions Act

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​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​by Alicja Szyrner

4 February 2025​, update: 20 February 2025​


The Act on Specific Steps to Counteract Supporting Aggression against Ukraine and to Protect National Security (the Sanctions Act) became law on 16 April 2022.

Back then, the Sanctions Act imposed criminal liability on persons who, acting on their own behalf or representing their businesses, violated the sanctions. Since then, prohibitions and restrictions on business with Russia and Belarus have become much wider through successive sanctions packages imposed by the European Union. As a result, a number of sanctioned prohibitions have not been effectively enforced by criminal liability for their violation, thus creating a large gap in legislation. Therefore, it has become necessary to amend the Sanctions Act to bring national laws in line with the amended EU regulations. ​

The amended Polish Sanctions Act became law on 20 February 2025.

Major amendments to the Sanctions Act


The amended Sanctions Act brings a number of changes that may affect businesses. The most important ones include:

Obligation to attach a statement to a customs declaration


Traders exporting sanctioned goods to countries at risk of being involved in circumventing sanctions, or transporting goods in transit through Russia or Belarus will be required to attach a statement to their customs declaration confirming that:

  • transit through Russia or Belarus is only a part of the transport route and the beginning and end of that route are outside Russia and Belarus,
  • the goods will not be resold, processed or stored and no services will be provided by sanctioned entities during the transit,
  • final destination of the goods is a third country other than Russia or Belarus.

In addition, the statement must specify the details of the end user of the goods and must say that the trader is aware of his criminal liability for making a false statement.

Traders will also be required to submit to the head of revenue and customs office a document confirming the customs clearance of goods from the country of destination within 45 days of the goods leaving the EU customs territory. Failure to do so carries the risk of a fine of up to 500,000 zloty.

Statement by the goods manufacturer


Where a risk analysis done by a National Revenue Administration authority indicates a high risk of circumvention of sanctions through:

  • export of goods to countries at risk of being involved in circumventing sanctions,
  • transit through Russia or Belarus,​

the head of revenue and customs office may require the trader exporting the sanctioned goods to submit a statement issued by the goods manufacturer that he has taken steps to ensure that end users will use the goods without violating sanctions laws.

Import of wood, charcoal and articles of wood


​Traders importing wood, charcoal and articles of wood (CN Chapter 44) from countries at risk of being involved in circumventing sanctions are required to submit evidence to the customs authority confirming the country and region of harvest and details of supplier.

​​
Extended criminal liability for violating sanctions

The amended Sanctions Act significantly broadens the scope of criminal liability of persons who violate sanctions or are involved in activities aimed at or resulting in circumventing prohibitions. Violation of the prohibitions will be punishable by imprisonment for no less than three years and, in minor cases, imprisonment from three months to five years. Importantly, if such an act is committed as part of business operations, the person responsible for concluding the transaction will be considered the perpetrator.

Once the amended Sanctions Act is in force, among others, the following actions will face criminal liability:

  1. sale to any natural or legal person, entity or body in Russia and Belarus, or for use in Russia or Belarus, of firearms and other weapons, maritime goods and technology, luxury goods, whether or not originating in the EU, including but not limited to horses, caviar, truffles, cigars, carpets, goods and technology suitable for use in oil refining and natural gas liquefaction,
  2. import, purchase and transport to the EU of iron and steel products, crude oil and petroleum products, Ukrainian cultural property and other goods of archaeological, historical, cultural, religious or exceptional scientific interest.
  3. provision, directly or indirectly, of the following services to the Government of Russia and/or legal persons, entities or bodies based in Russia:

  • accounting services, 
  • audit services (including statutory audits),
  • bookkeeping services,
  • tax advisory services,
  • business and management consulting services, or public relations services,
  • architectural and engineering services, 
  • legal advisory services and IT advisory services,
  • market research and opinion polling services, technical research and analysis services.​

In this context, businesses dealing with Russian or Belarusian entities, or exporting sanctioned goods to countries at risk of being involved in circumventing sanctions, or transporting goods in transit through Russia or Belarus, will be required to exercise the utmost caution. 

If you have any questions about the economic sanctions imposed by the EU – contact​ our experts.

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Alicja Szyrner

Attorney at law (Poland)

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