Many businesses still mistakenly believe that sanctions apply only to companies trading directly with Russia or Belarus. In reality, the situation is very different.
Sanctions today are a real business obligation, not a political issue. Across the European Union, the number of sanctions-related cases is increasing sharply. At the same time, the EU does not accept the excuse of “I didn’t know”. Due diligence is a legal requirement, and failures in this area can prove extremely costly.
Who do sanctions apply to?
Sanctions risk now affects almost every link in the supply chain, including:
- Importers, who are responsible for declarations of origin and for ensuring compliance of the entire product and its components. They must be able to prove that neither the goods nor any of their elements originate from sanctioned sources.
- Exporters, who must verify that goods are not supplied to entities or countries subject to sanctions, even when selling via intermediaries based in countries considered “safe”.
- Carriers and logistics operators, who may be held liable for transporting sanctioned goods or for failing to respond to warning signs.
- Manufacturing companies, which must control the origin of raw materials and semi-finished products, even if these are purchased from verified European suppliers.
Infrastructure, intermodal, rail, energy and technology companies are also exposed to sanctions-related risks, even if they do not trade in high-risk goods themselves. The activities of suppliers and subcontractors may still create legal exposure.
Rising pressure around sanctions
Several factors are making sanctions an increasingly serious issue for Polish companies. One is the ongoing expansion of EU sanctions lists, with new goods, technologies, entities and services regularly being added.
Another is the growing number of attempts to circumvent sanctions via transit countries. So-called “origin laundering” occurs when goods from Russia or Belarus are issued with documentation suggesting a different country of origin.
As a result, criminal proceedings are becoming more frequent. The roughly 6,000 cases currently under investigation in Germany are likely only part of a much wider trend. Similar developments are visible across the EU, including in Poland. Responsibility does not fall solely on companies: board members and owners may also face personal liability.
The ‘no Russian input’ obligation
The “no Russian input” declaration confirms that neither a product nor any of its components originates in Russia or Belarus. Without this documentation, companies have no evidence that they have exercised due diligence.
Failure to provide such proof increases the risk of goods being detained, customs inspections being launched and financial penalties being imposed. The requirement applies not only to direct imports but to the entire supply chain.
If a European manufacturer uses components derived from Russian raw materials, responsibility for verification rests with the company placing the product on the market. The origin of materials must therefore be checked and properly documented.
Consequences of sanctions violations
Companies that violate sanctions face serious consequences, including:
- Administrative penalties – refusal to accept customs declarations, detention or confiscation of goods.
- Criminal proceedings – multimillion-euro fines and personal liability for board members and managers.
- Financial consequences – payment blocks, termination of contracts, and loss of certificates and customs authorisations, including AEO (Authorised Economic Operator) status.
- Reputational damage – loss of trust among customers, business partners and financial institutions.
- Operational disruption – supply chain paralysis, delays, and increased storage and transport costs.
There are already companies that, due to a single failure in due diligence, have lost key customers and been forced to restructure their entire operations.
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