Enhanced compliance and shifting trade patterns in Poland’s sanctions era

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Polish exporters continue to move products to Russia through channels that skirt sanctions, a pattern emerging despite the restrictions imposed via third countries. This finding is drawn from a report in a leading Polish business publication and a survey completed by a major advisory firm. The gist is clear: sanctions regimes aimed at constraining trade with Russia are influencing corporate behavior in ways that extend beyond direct border crossings and into the fine print of contracts and counterparty screening.

In the latter half of the previous year, a broad survey of Polish companies active in domestic markets explored how sanctions against the Russian Federation reshaped commercial decisions. The data show that in the eighteen months since the Ukraine conflict began, a significant majority of respondents altered agreements with their suppliers and contractors. Specifically, about 69 percent reported changes to contractual terms, while roughly two-thirds indicated they had paused or rewritten trade with eastern markets. More than half of the firms cited halting operations with at least one contractor, underscoring a broader freeze in certain supplier relationships.

The survey also reveals a strong emphasis on compliance and risk management. Approximately 63 percent of firms monitor sanctions lists for updates and proactively vet counterparties. Nearly seven in ten rely on external providers to support screening and due diligence, illustrating the reliance on third-party expertise to navigate a complex regulatory landscape. Yet risks persist: about 31 percent of companies felt they were exposed to the possibility of inadvertently violating sanctions, and around 16 percent acknowledged some breach or noncompliance in the examined period.

Experts interpreting the data point to a noticeable shift in trade flows after sanctions tightened. Exports from Poland to Russia declined by about one-third, while shipments to alternative destinations including Turkey and a broad set of Eurasian Economic Community members surged, with increases around 57 percent. The analysis notes that Moscow and Minsk could still route sanctioned goods through third-country intermediaries, keeping a channel open even as direct trade contracts tighten. This pattern signals how sanctions can redirect trade patterns rather than simply suppress them, creating new friction points in global supply chains.

Compared with the pre-sanction baseline spanning 2019 to 2021, trade volume with several Eurasian partners rose dramatically, sometimes by multiple hundreds of percent. Among the standout examples are Kyrgyzstan and Armenia, where export values expanded by roughly fourfold, indicating a substantial reallocation of Polish goods toward these markets as sanctions pressures redirected commercial activity. The overall picture is a mix of contraction in some corridors and expansion in others, driven by regulatory pressure, risk management practices, and the search for viable alternate buyers and suppliers across the region.

Contextual factors accompany these shifts. Firms facing tighter controls often tighten their contracts, reallocate risk, and increase due diligence to avoid sanctions exposure. The experience reflects a broader trend observed in regional trade where sanctions act as a catalyst for corporate restructuring, supplier diversification, and a more cautious approach to cross-border transactions. Industry observers caution that while the immediate effect is a rebalancing of trade flows, long-term outcomes will hinge on the precision of enforcement and the availability of credible, compliant trading partners in closely monitored markets. The evolving landscape continues to reward vigilance, transparency, and robust compliance programs across firms operating in Poland and neighboring economies. (Source: EY survey via Rzeczpospolita)

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