A Warsaw-based trading company receives a payment instruction from a long-standing supplier. Before processing, the finance team runs a routine check – and finds the counterparty's name on the Central Register of Beneficial Owners. The transaction freezes. The compliance officer has 24 hours to notify the relevant authority. That window is not a guideline. It is a hard statutory deadline under Polish sanctions law.

Poland's Ustawa o szczególnych rozwiązaniach w zakresie przeciwdziałania wspieraniu agresji na Ukrainę (Act on Special Solutions for Counteracting Support for Aggression against Ukraine, the Sanctions Act) entered into force in April 2022 and has been amended several times since. It imposes direct obligations on Polish entities and foreign businesses operating in Poland: asset freezing, transaction blocking, and mandatory reporting within 24 hours of identifying a listed person or entity. Failure to comply carries criminal liability for individuals and fines of up to PLN 20 million for legal entities.

This alert covers three things: what the Sanctions Act requires, who is caught by its thresholds, and what your organisation must do right now. The structure follows the Act's own logic – identification, freezing, notification – so compliance teams can map obligations directly to internal procedures.

What does the Polish Sanctions Act 2022 actually require?

The Sanctions Act imposes three distinct obligations on any entity conducting business in Poland. First, screen counterparties against the list maintained by the Minister of Internal Affairs and Administration. Second, freeze any funds, economic resources, or financial services connected to a listed person immediately on identification. Third, notify the Head of the Financial Intelligence Unit (Generalny Inspektor Informacji Finansowej, GIIF) within 24 hours of the freeze. Each obligation is independent. Completing one does not discharge the others.

The screening obligation applies continuously – not only at onboarding. Polish law requires entities to re-screen existing counterparties whenever the sanctions list is updated. The list is published in the Official Journal of the Republic of Poland (Monitor Polski) and can be amended at any time. There is no grace period between publication and the obligation taking effect. This creates an operational challenge for companies with large counterparty databases.

The freezing obligation is immediate and unconditional. Once a match is identified, no transaction may proceed. This includes payments already in the pipeline. The Act does not permit a "wind-down" period. Entities that discover a listed counterparty mid-transaction must halt the transfer and document the moment of identification precisely – because that timestamp determines whether the 24-hour notification window was met.

  • Screen all counterparties against the Polish sanctions list on each update
  • Freeze funds and economic resources immediately on identification
  • Notify GIIF within 24 hours of the freeze
  • Document the identification timestamp and all steps taken
  • Retain records for at least five years

For cross-border transactions, the Sanctions Act interacts with EU Regulation 269/2014 and subsequent amending regulations. Where both regimes apply, the stricter obligation governs. Sanctions compliance in Poland therefore requires mapping both the Polish list and the EU consolidated list – two separate screening exercises. Entities with exposure to Ukrainian or CIS counterparties should also note the procedural framework for enforcing a Ukraine judgment in Poland, which may be affected by asset-freeze measures.

Who is affected and what are the penalty thresholds?

The Sanctions Act applies to any natural person, legal entity, or organisational unit conducting activity in Poland – regardless of where they are incorporated. A German holding company with a Polish subsidiary is caught. So is a foreign investor leasing commercial property in Warsaw. The Act does not limit its scope to financial institutions. Real estate developers, logistics operators, and IT service providers are all within its reach. (This surprises many clients who assume sanctions compliance is a banking concern only.)

The penalty framework is tiered. For legal entities, the fine reaches PLN 20 million per violation. For individuals – including directors and compliance officers – criminal liability applies: up to three years' imprisonment for knowingly facilitating a transaction with a listed person. The Act also provides for administrative penalties imposed by the Minister of Internal Affairs, which can be applied in parallel with criminal proceedings. There is no cap on the number of violations that can be charged in a single enforcement action.

We secured a reversal of an administrative freeze order for a logistics client in the Mazowieckie region (autumn 2025). The original decision had been issued within hours of a false-positive match on a common surname. Prompt documentation of the screening methodology and a formal challenge to the GIIF resolved the matter within 30 days – avoiding a PLN 2 million exposure.

Entities in the construction and real estate sector face an additional layer of complexity. Sanctions obligations interact with permit and licensing requirements. A project financed partly by a sanctioned investor may trigger both the Sanctions Act and procurement rules enforced through the National Appeals Chamber (Krajowa Izba Odwoławcza, KIO). For context on how KIO appeal procedures operate, see our analysis of BREEAM and LEED certification legal implications in Poland, which addresses overlapping regulatory frameworks in construction projects.

The National Court Register (KRS) and the Central Register of Beneficial Owners (CRBR) are primary data sources for screening. However, neither register updates in real time. Relying solely on registry data without cross-referencing the Monitor Polski list is a compliance gap that enforcement authorities have flagged in several post-inspection reports.

What must your organisation do immediately?

Three actions are time-sensitive. First, audit your current screening process. If your organisation screens counterparties only at onboarding or on an annual cycle, that process does not meet the Sanctions Act standard. The obligation is triggered by each list update – and the list has been updated more than 15 times since April 2022. Second, verify your notification chain. The 24-hour window to notify GIIF runs from the moment of identification, not from when the compliance team escalates internally. Internal escalation delays do not pause the statutory clock. Third, document everything. Enforcement authorities assess whether the entity acted promptly and in good faith. A clear paper trail – showing the screening date, the match identified, and the steps taken – is the primary defence in any administrative or criminal proceeding.

For foreign investors, the interaction between the Sanctions Act and cross-border enforcement mechanisms deserves attention. Asset-freeze measures imposed in Poland can affect the enforceability of foreign judgments. Our guide on enforcing a United Kingdom judgment in Poland sets out how Polish courts treat assets subject to regulatory restrictions – a practical concern for creditors holding UK judgments against Polish-registered debtors.

We assisted a Silesian manufacturing group in restructuring its counterparty screening programme in spring 2026. The project covered 1,400 active suppliers, mapped dual EU and Polish list obligations, and established an automated alert protocol triggered within two hours of any list update. The group's compliance exposure dropped from a potential PLN 20 million liability to a documented, defensible process.

Immediate action checklist:

  • Confirm screening covers both the Polish Monitor Polski list and the EU consolidated list
  • Test the 24-hour notification chain end-to-end
  • Appoint a named individual responsible for GIIF notifications
  • Retain all screening records for a minimum of five years

Specific situations – particularly where a false-positive freeze has already been issued, or where a counterparty dispute involves a potentially sanctioned party – require individual legal assessment. The consequences of a missed notification are irreversible: criminal proceedings cannot be undone by later compliance improvements.

To receive an expert assessment of your organisation's sanctions compliance posture, contact info@kordeckipartners.com.

Frequently asked questions

Q: Does the Polish Sanctions Act apply to our company if we are incorporated outside Poland but have a branch here?

A: Yes. The Act applies to any entity conducting activity in Poland, regardless of place of incorporation. A foreign company with a Polish branch, registered office, or even a regular place of business in Poland is subject to the full screening, freezing, and notification obligations. The Polish Financial Supervision Authority (KNF) and GIIF have both confirmed this interpretation in guidance documents.

Q: How quickly must we notify GIIF after identifying a listed counterparty?

A: The statutory deadline is 24 hours from the moment of identification. This clock starts when any employee of the entity identifies the match – not when the compliance officer is informed. Building internal escalation procedures that operate within two to four hours is strongly advisable to preserve a buffer before the statutory deadline expires.

Q: What is the most common misconception about the Polish sanctions list?

A: Many organisations assume the Polish list mirrors the EU consolidated list exactly. It does not. Poland maintains a separate national list published in the Monitor Polski. Persons and entities may appear on one list but not the other. Screening only the EU list creates a compliance gap under Polish law and does not constitute a defence against enforcement action by Polish authorities.

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 litigation, and dispute resolution. 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.