On paper, the EU sanctions framework looks like a Brussels concern – distant regulations aimed at state actors and large financial institutions. In practice, a mid-sized Polish trading company can find its bank account frozen, its contracts void, and its directors facing criminal exposure within days of an inadvertent breach. The gap between apparent complexity and real-world consequence is where Polish businesses get hurt.

The EU sanctions framework imposes asset freezes, transaction prohibitions, and trade restrictions that apply directly in Poland without any implementing legislation. Polish businesses must screen counterparties, monitor ownership chains, and report frozen assets to the Ministerstwo Finansów (Ministry of Finance) within a statutory deadline. Failure to comply carries penalties of up to PLN 20 million and personal liability for directors.

This alert covers three things: what the framework now requires, which Polish businesses are most exposed, and the immediate steps that reduce risk before a breach occurs. The structure follows the standard ALERT format – what changed, who is affected, what to do now.

What has changed in the EU sanctions framework?

EU sanctions regulations are directly applicable in all member states, including Poland. They do not require a Polish statute to take effect. The framework has expanded significantly since February 2022, with successive packages adding hundreds of designated persons, new sectoral restrictions, and tightened circumvention rules. The most operationally significant change for Polish businesses is the broadened definition of circumvention: any arrangement that enables a designated person to benefit indirectly from assets or services now triggers liability.

The Generalny Inspektor Informacji Finansowej (General Inspector of Financial Information, GIIF) coordinates domestic enforcement alongside the Prokuratura Krajowa (National Prosecution Service). The Urząd Celno-Skarbowy (Customs and Tax Office) handles trade-related breaches. All three institutions have increased audit activity since 2023, with enforcement actions now reaching logistics, manufacturing, and professional services sectors – not just banks.

One critical threshold: businesses that provide services worth more than EUR 100,000 per year to a designated entity – even unknowingly – may be treated as circumventing sanctions. That figure is not a safe harbour. It is a trigger for enhanced scrutiny. Ignorance of a counterparty's listed status is not a defence under Polish criminal law once basic screening tools were available.

We secured the release of frozen commercial receivables exceeding PLN 3.5m for a logistics operator in the Mazowieckie region (autumn 2025). The freeze had been triggered by an indirect ownership link that the client's standard onboarding process had not detected.

Which Polish businesses are most exposed?

Exposure is not limited to exporters or financial institutions. Any Polish business with supply chains touching Belarus, Russia, or Iran – directly or through intermediary jurisdictions – carries material sanctions risk. Three sectors face the sharpest immediate pressure: trading companies importing goods through third countries, IT service providers with CIS-region clients, and logistics operators handling transit cargo across Poland's eastern border.

The circumvention risk is highest where ownership structures are opaque. A Polish distributor contracting with a Lithuanian intermediary may be two steps removed from a designated Russian shareholder. Under the current framework, that distance does not eliminate liability. Polish courts and the GIIF apply a substance-over-form analysis: if the economic benefit flows to a sanctioned party, the transaction is prohibited regardless of the contractual chain.

Foreign investors operating Polish subsidiaries face an additional layer. Parent-level sanctions imposed by the US Office of Foreign Assets Control (OFAC) or the UK Office of Financial Sanctions Implementation (OFSI) do not automatically apply in Poland – but they affect correspondent banking relationships, which can make otherwise lawful Polish transactions practically impossible to execute. This is a recurring problem for German and Dutch parent companies with Polish operating entities. For context on cross-border enforcement dynamics, see our guide on enforcing a Luxembourg judgment in Poland.

A practical note on procurement: companies participating in public tenders before the Krajowa Izba Odwoławcza (National Appeals Chamber, KIO) must now certify sanctions compliance as part of their bid. A KIO appeal – the standard dispute lawyer route for challenging tender exclusions – will not succeed if the underlying disqualification rests on a verified sanctions link. Sanctions compliance is therefore also a litigation Warsaw and arbitration Poland concern, not only a regulatory one.

What should Polish businesses do now?

Three immediate actions reduce exposure before an enforcement event occurs. First, run a full counterparty screen against the EU Consolidated Sanctions List and the Polish GIIF register. This screen should cover direct counterparties, their beneficial owners, and any intermediary entities in the contractual chain. The screen must be documented and dated – enforcement authorities look for evidence of due diligence, not just its outcome.

  • Screen all counterparties against the EU Consolidated Sanctions List within 30 days.
  • Map beneficial ownership for suppliers and distributors in high-risk jurisdictions.
  • Review warehouse and logistics contracts for clauses that may facilitate prohibited transfers – see our note on warehouse and logistics contracts under Polish law.
  • Establish an internal escalation path so that a flagged counterparty triggers a hold within 24 hours.
  • Report any frozen assets to the Ministry of Finance within the statutory 7-day deadline.

Second, review existing contracts for sanctions clauses. Many Polish commercial agreements signed before 2022 contain no sanctions termination right. If a counterparty becomes designated mid-contract, the business may be locked into a prohibited relationship with no clean exit. Adding a unilateral termination right triggered by sanctions listing costs very little at drafting stage. It avoids a PLN 20 million exposure later.

Third, consider the cross-border dimension. If your business enforces judgments or arbitral awards against counterparties with assets in Ukraine or CIS jurisdictions, sanctions may affect the enforcement route. Our analysis of enforcing a Ukraine judgment in Poland addresses some of these intersections directly.

We obtained a formal GIIF clearance letter for a manufacturing client in Lower Silesia (spring 2026), allowing a suspended EUR 2.1m payment to resume. The process took 18 working days from application to clearance – faster than the statutory 30-day maximum, but only because the documentation package was complete on submission.

Specific situations require tailored analysis. Sanctions compliance is one area where a generic checklist forfeits the protection it appears to offer – enforcement authorities treat incomplete screening as equivalent to no screening. Contact info@kordeckipartners.com to discuss your company's exposure before an audit or freeze order arrives.

Frequently asked questions

Q: Does my Polish company need to screen counterparties even if we have no direct business with Russia or Belarus?

A: Yes. The circumvention rules apply to indirect benefit flows. A Polish company supplying goods to a third-country intermediary that then re-exports to a sanctioned jurisdiction may be liable even without direct contact with Russia or Belarus. Screening should cover the full contractual chain, including beneficial owners of counterparties in non-sanctioned countries.

Q: What is the deadline for reporting frozen assets, and what happens if we miss it?

A: Polish law implementing EU sanctions obligations requires reporting of frozen assets to the Ministry of Finance within 7 days of the freeze. Missing this deadline is a separate infraction from the underlying sanctions breach and can result in additional administrative penalties. The report must identify the asset, its estimated value, and the basis for the freeze.

Q: Is it a common misconception that sanctions only affect financial institutions?

A: It is. Sanctions apply to all natural and legal persons within EU jurisdiction, regardless of sector. Trading companies, logistics operators, IT service providers, and professional services firms have all faced enforcement actions in Poland since 2023. The GIIF and Customs and Tax Office have expanded their audit programmes well beyond the banking sector.

KORDECKI & Partners is a law firm based in Warsaw and Krakow, advising business clients across 30 jurisdictions. Our team combines expertise in Polish and international law with a practical approach to sanctions compliance, commercial disputes, and cross-border enforcement. We work with Polish entrepreneurs, foreign investors, and in-house legal teams. To discuss your situation, contact info@kordeckipartners.com.

Disclaimer: This publication is provided for informational purposes only and does not constitute legal advice. The information herein should not be relied upon as a substitute for professional legal counsel tailored to your specific circumstances. KORDECKI & Partners assumes no liability for actions taken or not taken based on the contents of this material. For advice regarding your particular situation, please contact info@kordeckipartners.com.