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Record fines and the upcoming 21st sanctions package – what should businesses expect?

23 June 2026 | Knowledge, News, Tax Focus, The Right Focus

The past year has brought a series of enforcement actions that clearly signal a tightening approach by the Polish customs and revenue authorities towards breaches of the sanctions regime.

In April, the Małopolska branch of the National Revenue Administration (Krajowa Administracja Skarbowa, KAS) uncovered an illegal scheme involving the export of cars to a market subject to EU sanctions, and imposed a fine of PLN 20 million on the company in question.[1] The Mazovia KAS detained three individuals suspected of participating in a scheme circumventing sanctions on the import of timber products from Belarus and Russia.[2] In June, the Silesia KAS imposed a further fine of PLN 20 million for trading with Russian entities in breach of EU restrictive measures.[3]

These are not isolated incidents, but rather a clear signal that the Polish authorities are taking a rigorous approach to sanctions compliance. Even minor shortcomings in counterparty screening or supply chain management may result in multimillion-zloty fines. Importantly, businesses should already be preparing for further changes, as the European Union has announced its 21st sanctions package and updated the list of designated persons and entities.

We examine the key developments and offer guidance on how to minimise the risk of non-compliance.

Update to the EU sanctions list

The latest package adds a total of 34 individuals and 47 entities to the sanctions lists: 7 individuals and 21 companies for supporting Russia’s military-industrial complex, and 2 individuals and 24 companies for their involvement in maritime shipment and the export of Russian crude oil and petroleum products. The aim is to further curtail the revenues of Russia’s energy sector.

For Polish and EU businesses, one fundamental rule applies: any form of commercial dealings, whether direct or indirect, with designated persons or entities is strictly prohibited. Breaching this prohibition results in administrative and criminal liability, regardless of whether the breach was intentional or the result of negligence in screening procedures.

However, this is not the only change. In parallel, the European Commission, together with the Member States, is working on a significantly broader 21st sanctions package, which is expected to cover additional sectors of the economy and extend the existing list of restrictions.

What does the EU’s 21st package of sanctions against Russia contain?

The proposed 21st sanctions package is set to target sectors that are particularly important for financing Russia’s war effort: finance, energy, trade, crypto-assets and transport.

Furthermore, the Commission has announced plans to extend export restrictions to goods and technologies critical to Russia’s defence industry, including metals and alloys used in the aerospace and defence sectors, as well as equipment used in the manufacture of drones, which is to be subject to an export ban.

Although the package has not yet formally entered into force, we recommend that businesses engaged in international trade closely monitor the progress of the legislative process and analyse the potential impact of the new regulations on their operations in advance.

Fines of up to PLN 20M for breaching sanctions regulations

Breaching sanctions regulations can have extremely serious consequences for businesses.

Fines of up to PLN 20 million may be imposed on those who:

  • Have failed to comply with the obligation to freeze financial assets
  • Have failed to provide the required information to the competent authorities
  • Have attempted to circumvent sanctions

Importantly, this is not the full extent of the consequences. The regulations also provide for criminal liability, with a minimum prison sentence of three years for breaching sanctions regulations.

Given the severity of the risks involved, preparation is key. It is advisable to work with specialists who can:

  • Review all international transactions to identify potential risk areas and links to designated persons or entities
  • Implement compliance procedures tailored to the company’s specific needs, enabling ongoing monitoring of regulatory compliance and minimising the risk of breaches
  • Provide professional representation in the event of administrative or criminal proceedings being initiated, ensuring protection at every stage of the process

Adequate preparation and implementation of compliance procedures is the most effective way to avoid heavy fines and criminal liability. This is why it’s important to take action now.

Have questions? Contact us

 

[1] https://www.gov.pl/web/kas/kas-nalozyla-kare-pieniezna-za-naruszenie-sankcji-w-wysokosci-20-mln-zl

[2] https://www.gov.pl/web/kas/kas-zatrzymala-3-osoby-podejrzane-o-naruszenie-unijnych-sankcji-i-oszustwo-celne

[3] https://www.gov.pl/web/kas/kas-nalozyla-na-lokalna-firme-20-mln-zl-kary-za-handel-z-rosjanami

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Contact us:

Jan Janukowicz

Jan Janukowicz

Advocate Trainee / Associate / Tax Law

+48 736 272 203

j.janukowicz@kochanski.pl