Poland – seizure of 5 tons of aviation tyres bound for Russia/Belarus

Poland’s National Tax Administration has issued a press release, announcing the seizure of 5 tons of aviation tyres.

The discovery was made through a routine inspection of a truck by the Lublin Customs and Tax office.

The declared goods were automobile tyres. The sender of the tyres was an unnamed company in Spain, and the declared recipient was said to be in Azerbaijan.

The goods were detained and criminal proceedings have been instituted.

Poland – multiple raids and arrests for suspected import of timber in breach of Russia and Belarus sanctions

Poland’s National Tax Administration yesterday issued a press release detailing raids and arrests in three provinces.

The three arrested individuals have been charged and are in pre-trial detention. They are suspected of importing birch plywood from Belarus and Russia in breach of EU sanctions.

The Tax Administration has conducted a number of similar investigations in recent months, which have not previously been included in this blog:

24 April 2025 – The Pomeranian branch of Poland’s National Tax Administration has conducted raids in Gdynia. Thirty pallets of timber suspected to have been imported from Belarus and Russia were seized.

9 April 2025 – The Pomeranian branch of Poland’s National Tax Administration has conducted inspections of timber purportedly imported from Tunisia at the Baltic Container Terminal in Gdansk, and seized over PLN 1 million in timber on suspicion that it was imported from Belarus and Russia in breach of EU sanctions.

28 February 2025 – The Lublin branch of the National Tax Administration has seized 1800 pallets of plywood suspected of being imported from Belarus and Russia via China and Kazakhstan. The press release adds that 15 sets of proceedings are being prepared as a result of the seizures valued at PLN 3.2m.

November 2024 – raids were conducted in seven provinces in relation to an ongoing investigation into suspected imports of timber from Belarus and Russia in breach of Eu sanctions.

Poland – German national charged with exporting dual-use goods to Russia

It is being reported that Polish authorities have arrested and charged a German national with exporting dual-use technology to Russia in breach of EU sanctions.

The arrest was in the Lubusz province and relates to the export of machinery which can be used in weapons manufacture. It is also said that the exports were directed at “Russian military plants involved in weapons production”.

The individual is reported to have admitted his guilt.

The press release is here.

Poland – investigation and charge in relation to dual-use exports to Iran

It is being reported by Reuters that the Polish state-owned company WSK Poznan is being investigated by the National Prosecutor’s Office and the Internal Security Agency on suspicion of supplying parts to Iranian manufacturer, Motorsazan Company, which were then incorporated into drones used by Russian combat forces in Ukraine.

The National Prosecutor’s Office is also reported to have charged the CEO of the company in relation to the export of dual-use goods.

Another report states that the investigation has been ongoing for two years, and notes that the Polish National Prosecutor has denied evidence that parts were used for drones and stated that the investigation relates more to the sale of fuel pumps to Iran.

 

Poland – updated enforcement statistics with new proceedings and new fines

The Polish authorities have released updated enforcement statistics showing changes since those release just a few weeks ago.

The new data confirms:

    • 51 administrative proceedings commenced (up from 48 on 1 July)
    • 37 final decisions taken (up from 33 on 1 July)
    • 24 fines imposed to date (up from 22 on 1 July)

Further, in response to a Freedom of Information request made on behalf of this blog, the Polish Ministry of Finance has provided  the following data (available here: MF do M. Handley’a odpowiedź na wniosek 2879.2024):

    • 12 of the fines imposed for breaches of EU Regulation 833/2014 with a total of fines of 1,513,244.00 zloty (c. €353,326);
    • 2 of the fines imposed for breaches of EU Regulation 269/2014 with a total of fines of 451,946 zloty (c. €105,000); and
    • 10 of the fines imposed for breaches of the Polish 2022 sanctions regulation for total fines of 18,868,137 zloty (c. €4,405,000).

No other European country has imposed so many fines for breaches of Russian sanctions.

Poland – sanctions enforcement statistics including 20 fines to date

As part of the press article (behind a paywall) on the recent fines against Novatek Green Energy and Geleo (see our post here), the Polish authorities have also provided an update on their enforcement activity more broadly.

      • Total administrative proceedings commenced: 48
      • Final decisions to date: 33
      • Declination or waiver of fine or finding of no breach: 13
      • Fines imposed to date: 20
      • Ongoing proceedings: 15
      • Total fines to date: 4.8m zloty (c. $1.2m)

Certainly the figure for total fines does not include the fine against Novatek Green Energy (which was 12 million zloty), but it is also a little unclear whether or not the figure includes the fine against Geleo (which was 4m zloty).

The report also notes that most of the 20 penalties have been imposed in 2024, with only two imposed by the end of 2023 for a combined total of 71,000 zloty (c. $17,700).

These enforcement actions appear to relate to a mix of EU and the separate Polish sanctions.

No information has been provided as to the conduct which gave rise to the fines, or who the fines were imposed on.

Poland – fines imposed on two companies for circumvention of Russian sanctions

Now updated from the post first published on 28 June.

It is being reported (behind a paywall) that the Malopolska Customs and Tax Office of Krakow has imposed fines of 12 million zloty (c. €2.78m) against Novatek Green Energy and 4 million zloty (c. €927,000) against employee-owned company Geleo.

The fine against Geleo was imposed on 31 May. It was for breach of the relevant asset freeze and for circumvention of Polish sanctions. The transaction in question was the purchase, for €1, of 100% of the shares in Novatek Green Energy from the Swiss company Novatek Gas and Power GmbH, which in turn is a direct subsidiary of the Russian company OAO Novatek.

The fine against Novatek Green Energy was imposed on 25 June, and was imposed for multiple transactions in breach of the imposed asset freeze.

With particular thanks to Dr Marcin Łukowski who provided a copy of the relevant article.

European Sanctions Enforcement – milestone of over 2000 announced and active investigations reached

With the recent news that Finland has increased the number of its ongoing investigations, Europe (meaning the EU, the UK, Switzerland, etc) has reached the milestone of over 2,000 ongoing and public sanctions enforcement investigations being undertaken by regulators and prosecutors.

No doubt there are other investigations which are ongoing in the countries shown on the graph, and no doubt there are investigations ongoing in countries not shown and which remain confidential.

How many of these will be dropped due to inconclusive evidence or exculpatory evidence, and how many will lead to a conviction or fine or acquittal is impossible to say.

It is, without question, an unprecedented level of enforcement.

 

Poland – sanctions investigation commenced into state-controlled oil trading company

After first being reported by Polish radio station Radio Zet, it is now being reported in the press that the Polish Special Services has commenced an investigation into whether the Swiss oil trading subsidiary of a state-controlled oil company has breached the EU’s Russian sanctions in relation to oil.

The Polish parent company is Orlen, which is 49% owned by the Polish state, and the Swiss subsidiary is Orlen Trading Switzerland.

It is alleged that the Swiss subsidiary was incorporated in Switzerland in late 2022 ahead of the relevant changes to EU sanctions which came into effect in early 2023 as a means of continuing to purchase and trade in oil of Russian origin.

The companies are reported as having denied the allegations.

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