Poland – publication of sanctions enforcement statistics including 138 fines imposed

The government of Poland has issued a press release detailing its efforts to date on the enforcement of the EU’s sanctions against Russia and Belarus.

My thanks to Dr Marcin Lukowski for drawing this release to the blog’s attention.

To date Poland has:

  • imposed fines of PLN 74.4m (c. €18m) across 138 separate fining decisions; and
  • in the first quarter of 2026 there are:
    • 191 pending cases;
    • 122 cases where an individual has been identified as a suspect (“charged” in Polish terminology);
    • 13 indictments filed; and
    • 10 final judgments.

The government also states that it has frozen €546.2m in assets, and that nearly 56% of all EU customs alerts originate from Poland.

As per our earlier post from September 2025 – at that stage Poland had imposed 42 fines for a total of PLN 26.6m or €6.2m, meaning the number of fines, and the value of fines imposed, has nearly tripled since September last year.

Poland – company exporting luxury cars to Russia fined c. €4.7m

Poland’s National Tax Administration has fined a company based in Małopolska and run by Belarusian citizens PLN 20,000,000 – or approximately €4,726,000. The fine is administrative, and was the maximum allowable fine.

The company had exported over 100 luxury cars to Russia via Lithuania and Belarus in breach of EU sanctions.

The total value of the cars is said to have been PLN 49m. The press release states that “The evidence gathered indicates that the company’s managers acted knowingly and deliberately participated in the circumvention of sanctions”.

The press release does not mention if proceedings are also being brought against the individuals involved or if the company will be subject to a confiscation of its profits.

Poland – six individuals charged with exporting drone-making machinery to Russia

Poland’s Internal Security Agency has issued a press release announcing that six individuals have been charged on suspicion of exporting machinery for the manufacture of drones to Russia, via Belarus, in breach of the EU’s sanctions.

The charges follow raids conducted on 18 February.

The individuals include 4 Belarus nationals and two Poles, and the machinery is described as a device for the production of integrated circuits.

Three of the suspects have been ordered to remain in custody, while the other three were released on bail subject to supervision and a ban on leaving Poland.

OLAF – investigation relating to the sanctioned export of 766 transport vehicles

The European anti-fraud agency OLAF has issued a press release on an investigation it has coordinated into the export of 766 transport vehicles to Russia despite the exporters claiming they were destined for one of Türkiye, Armenia, Georgia, Kazakhstan, Kyrgyzstan, and Moldova.

The investigation first arose after a report by the Polish authorities, with OLAF then tracking each individual vehicle to determine that it had been exported to Russia.

The press release notes that “OLAF’s findings led to criminal investigations in three different Member States”, but no further information is given on which member states or the current progress of those investigations.

The press release also thanks the various countries which were labelled as the destination for the trucks in providing assistance in confirming that the vehicles never arrived.

Poland – 5 arrested on suspicion of importing sanctioned Russian and Belarusian timber

Poland’s Customs and Tax Service has conducted raids and arrested five individuals suspected of importing Russian and Belarusian birch plywood under falsified papers to make it appear that the timber was of Kazakh or Turkish origin.

The five individuals have been named as:

  • Franciszek B. (64 years old, Polish citizen)
  • Marian K. (48 years old, Polish citizen)
  • Piotr K. (56 years old, Polish citizen)
  • Aleksander P. (43 years old, Russian citizen) and
  • Sergey M. (57 years old, Russian citizen).

The imports are alleged to have taken place between 2022 and 2024.

The investigation was aided by materials from OLAF (the European Anti-Fraud Office) and from the response to a mutual legal assistance request provided by Kazakhstan.

The suspects have all been charged but have been release pending trial.

Poland – 20 people detained for alleged luxury car exports to Russia and Belarus

Poland’s Central Bureau of Investigation of the Police has issued a press release relating to the arrest of 20 people for alleged involvement in a scheme to export of approximately 600 luxury cars to Russia and Belarus in breach of the EU’s sanctions.

The scheme is said to have involved a sequence of sales within the EU, followed by sales to customers in third countries such as Kazakhstan and Azerbaijan, followed by a further transfer to Belarusia or Russia.

Several of the defendants are being detained in custody while the investigation continues.

More than PLN 10m in bank accounts have been frozen as part of the investigation.

Poland – updated statistics on the 42 imposed sanctions fines

With grateful thanks to the Ministry of Finance and the Economy in Poland for the provision of the information, this blog can provide an up-to-date summary of the scale of financial penalties imposed by the Polish authorities in relation to Russian and Belarusian sanctions violations.

These figures relate to the period up to 28 August 2025.

In total the Polish authorities have imposed 42 financial penalties, broken down on the following basis:

  • 24 penalties in relation to breaches of EU Regulation 833/2014, with total fines of PLN 6,850,949 (just over €1.6m);
  • 6 penalties for breaches of EU Regulation 269/2014, with total fines of PLN 911,515 (just over €213,000);
  • 10 penalties for breaches of the Polish Sanctions Act of 13 April 2022, with total fines of PLN 18,886,441 (€4.42m);
  • 1 penalty under EU regulation 765/2006 in relation to Belarus, with a fine of PLN 7,367 (€1,727); and
  • 1 penalty relating to both Regulations 833/2014 and 765/2006, with a fine of PLN 36,272 (€8,506).

This updates the statistics previously published on this blog from July 2024.

It shows that Poland has imposed a 18 fines since that time. Of those 12 were under Regulation 833/2014, four were under Regulation 269/2014, and the two smaller fines relating to Belarus have also been imposed since July 2024.

 

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.

© 2009- Duane Morris LLP. Duane Morris is a registered service mark of Duane Morris LLP.

The opinions expressed on this blog are those of the author and are not to be construed as legal advice.

Proudly powered by WordPress