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Consequences of violations of sanctions imposed on Russia and Belarus


by Rafał Szymański and Alicja Szyrner

24 May 2022

A penalty of up to 20 million zloty – such is the risk taken by those who do not fulfil the obligations arising from the EU regulations imposing sanctions as a result of Russia's aggression against Ukraine.

Obligations defined by the EU

  • freezing of funds or other economic resources of the entities included in the list kept by the minister competent for internal affairs;
  • ban on coal import from Russia or Belarus; 
  • providing without delay any information facilitating compliance with the EU regulations on sanctions.

In addition, sanctions are imposed on entities bidding in a public tender procedure despite being on the list kept by the minister competent for internal affairs, available at: https://www.gov.pl/web/mswia/lista-osob-i-podmiotow-objetych-sankcjami.

Other consequences

A breach of prohibitions specified in the EU regulations, such as:
  • supply of equipment that might be used as a means of domestic repression;
  • supply and provision of technical assistance related to a specific technology;
  • import of wood, iron, cement and rubber products originating from Belarus to the EU;

is additionally liable to imprisonment for at least 3 years. If such an act is committed as part of business operations, the person responsible for concluding a given transaction will be considered to be the perpetrator. 

Therefore, we recommend that you each time verify your contracting parties in terms of their potential relations with Russia or Belarus.

Please contact Rödl & Partner experts to identify the risk and check your actions.

Legal basis:
1. The Act of 13 April 2022 on Specific Steps to Counteract Supporting Aggression against Ukraine and to Protect National Security (Journal of Laws 2022.835).
2. Council Regulation (EC) No 765/2006 of 18 May 2006 concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine (OJ L 134, 20.05.2006, as amended).
3. 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.


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Rafał Szymański

Attorney at law (Poland)

Senior Associate

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