Knowledge base
Goods sanctions vs screening of persons and entities, how they differ
Updated: 26 June 2026
Goods sanctions concern what you ship and are based on CN codes in Regulations 833/2014 and 765/2006. Screening of persons and entities concerns who you trade with and relies on lists of entities subject to asset freezes. These are two different mechanisms, and a compliant transaction requires checking both.
Two axes of the same control
Sanctions compliance works along two axes. The first is the goods. You ask whether the CN code of the item in the transaction is subject to an export, import or transfer ban under a given regime. The second is the party to the transaction. You ask whether the recipient, the buyer, the intermediary or the beneficial owner appears on the list of entities subject to sanctions.
These two checks are independent of each other. Goods free of a ban will not help if the recipient is on the list. A clean recipient will not help if the goods themselves are subject to a ban. A safe transaction is one that passes both checks.
How a goods sanction works
A goods sanction identifies a product by its CN code in an annex to the regulation. You check the code, establish the regime, the annex, the article and the direction of the ban, and then look at exemptions and cut-off dates. This is exactly the area this tool covers.
Goods sanctions against Russia stem from Regulation 833/2014, and against Belarus from Regulation 765/2006. Each has its own annexes and its own logic, so the same goods may have a different status under each of these regimes.
How entity screening works
Entity screening consists of checking the counterparty against lists of persons and entities subject to restrictive measures, above all asset freezes and the ban on making funds available. At EU level there is a consolidated sanctions list, and in Poland additionally a national list maintained under the act of 13 April 2022.
Screening covers not only the direct counterparty, but also the ownership structure and the persons controlling the entity. This is a separate process, usually carried out in a different tool than CN code verification, and it requires regular updates as the lists change.
Why you must not skip either axis
A KAS inspection and a compliance audit look at the whole transaction. A failure to check the goods or a failure to check the recipient is a gap that is hard to explain afterwards. The simplest safeguard is a procedure that forces both checks at every shipment and records their result.
This tool covers the goods axis, that is the status of the CN code. You handle the entity axis through screening against sanctions lists. Combining both in a single procedure gives consistent proof of due diligence.
Where does CBAM fit in all this
Alongside sanctions there is a third, separate mechanism based on CN codes, the Carbon Border Adjustment Mechanism (CBAM). CBAM is not a sanction and does not prohibit trade. Instead it imposes reporting and, ultimately, payment obligations on imports of carbon-intensive goods, for example iron and steel, aluminium, cement, fertilisers, electricity and hydrogen.
So the same CN code may have a status in three orders at once: goods sanctions, entity sanctions and CBAM. That is why an importer of steel products checks both sanctions and CBAM coverage. You verify the CBAM status of a code in a separate section of the tool.
Frequently asked questions
Is CBAM a kind of sanction?
No. CBAM is a carbon border mechanism with reporting and payment obligations, based on CN codes but independent of the 833/2014 and 765/2006 regimes. Goods may be covered by CBAM and not by sanctions, and the other way round.
Does checking the CN code exempt me from checking the recipient?
No. These are two different mechanisms. The status of goods by CN code says nothing about whether the recipient is on a sanctions list. You have to carry out both checks.
Where do I find the list of entities subject to sanctions?
At EU level there is a consolidated sanctions list, and in Poland additionally a national list maintained under the act of 13 April 2022. Screening also covers owners and persons controlling the entity.
Does this tool check persons and entities?
No. Restrikt answers the question about the status of goods by CN code. You carry out screening of persons and entities separately, in a tool for verifying sanctions lists.
Can the same goods have a different status for Russia and Belarus?
Yes. The 833/2014 and 765/2006 regimes have separate annexes. Goods subject to a ban under one regime need not be subject to it under the other, which is why you check both.
More in the knowledge base
- How to check whether goods are subject to EU sanctions, step by step
- CN code and sanctions: how to read the annexes to Regulation 833/2014
- Exemptions and derogations in the sanctions against Russia, when trade is allowed
- Exporter obligations after the 2025 amendment (end-user statement)
- Penalties for breaching sanctions in Poland (up to PLN 20 million)
- The most commonly checked CN codes covered by EU sanctions against Russia
- CBAM versus EU sanctions, how they differ and why you check both
Informational content based on EU regulations (833/2014, 765/2006) and the act of 13 April 2022 (Journal of Laws 2022 item 835). It does not constitute legal or customs advice. The binding source is the text of the act in EUR-Lex and the decision of the customs authorities. In case of doubt, consult an adviser.