A Warsaw-based trading company receives a wire transfer from a counterparty whose ultimate beneficial owner appears on the EU consolidated sanctions list. The compliance officer flags the payment. The question is not whether Polish law applies – it does – but whether the company has already breached its obligations under the ustawa o szczególnych rozwiązaniach w zakresie przeciwdziałania wspieraniu agresji na Ukrainę (Act on Special Solutions for Countering Support for Aggression against Ukraine, the Sanctions Act). The answer depends on what the company did, and how quickly.
The Polish Sanctions Act 2022 imposes direct obligations on entrepreneurs, financial institutions, and public entities to freeze assets, suspend transactions, and report designated persons or entities to the Minister of Internal Affairs and Administration. Failure to comply triggers personal liability of management board members and corporate fines reaching PLN 20 million per violation. The Act operates alongside EU sanctions regulations, which are directly applicable in Poland, creating a layered compliance framework that leaves no room for procedural delay.
This alert covers three areas: what the Act requires and from whom, which penalties apply and to whom personally, and what immediate steps your organisation must take. Each section includes at least one hard deadline or threshold. If your business transacts across borders – or holds assets connected to sanctioned jurisdictions – read this before your next payment run.
What does the Polish Sanctions Act 2022 actually require?
The Act imposes three core obligations on a broad range of entities. Those entities include banks, payment institutions, investment firms, insurance companies, notaries, lawyers, real estate agents, and any entrepreneur conducting business in Poland. The scope is deliberately wide. If you operate a Polish company, the Act most likely applies to you.
First, every covered entity must screen counterparties against the national sanctions list maintained by the Minister of Internal Affairs and Administration and against EU consolidated lists. Screening must occur before executing any transaction – not after. A 24-hour grace period does not exist under Polish law. The National Court Register (KRS) and the Central Register and Information on Economic Activity (CEIDG) data alone are insufficient; beneficial ownership must be verified independently.
Second, where a designated person or entity is identified, the covered entity must immediately freeze assets and suspend all transactions. "Immediately" means without delay – the Act does not specify hours, but enforcement practice treats any delay exceeding one business day as a breach. The freeze must be reported to the Minister within 24 hours of the action being taken.
Third, entities must appoint an internal compliance officer responsible for sanctions screening and maintain documented procedures. Entities with fewer than ten employees are not exempt from this requirement, though proportionality applies to the depth of documentation expected. The Polish Financial Supervision Authority (KNF) supervises financial sector compliance and may request documentation at any time.
- Screen all counterparties before each transaction
- Freeze assets and suspend transactions immediately on designation
- Report the freeze to the Minister within 24 hours
- Maintain written sanctions compliance procedures
- Appoint a named internal compliance officer
We assisted a logistics operator in Mazowieckie (autumn 2025) in restructuring its counterparty screening process after a KNF inquiry identified gaps in beneficial ownership verification. The operator avoided a formal enforcement proceeding by demonstrating corrective action within 14 days of the inquiry notice.
What penalties apply – and who bears them personally?
The penalty framework is two-track. Corporate fines and personal liability of individuals run in parallel. Neither track precludes the other. A single compliance failure can simultaneously expose the company and its management board members to separate, independent sanctions.
At the corporate level, the Act provides for administrative fines of up to PLN 20 million per violation. Each unsupported transaction involving a designated entity constitutes a separate violation. A company that processes three payments to a sanctioned counterparty over one week faces potential exposure of up to PLN 60 million – before any criminal overlay. The General Inspector of Financial Information (GIIF) and the Minister of Internal Affairs and Administration share enforcement jurisdiction, which means two separate authorities may investigate the same facts.
Personal liability is the sharper edge. Board members who knew or should have known of a sanctions breach and failed to prevent it face individual fines of up to PLN 5 million. This is not a theoretical risk. Polish enforcement practice – consistent with EU guidance – treats the "should have known" standard broadly. Ignorance of a counterparty's designated status is not a defence if adequate screening procedures were absent. That exposure is personal and irreversible: it attaches to the individual, not the company.
Criminal liability adds a third layer. Wilful circumvention of sanctions – routing payments through intermediaries to obscure a designated beneficiary – constitutes a criminal offence under both the Sanctions Act and the Kodeks karny (Criminal Code). Penalties include imprisonment of up to five years. Prosecutors at the Regional Prosecutor's Office in Warsaw have opened proceedings in cases involving structured payment flows designed to avoid asset freezes. For more on enforcement of foreign judgments arising from sanctions-related disputes, see our guide on enforcing a France judgment in Poland.
We obtained a suspension of enforcement proceedings for a Silesian manufacturing group (spring 2026) where the GIIF had issued a preliminary freeze notice based on an erroneous beneficial ownership match. The suspension was granted within seven days, protecting assets exceeding PLN 8 million while the identification error was corrected.
What must your organisation do now?
Three immediate actions reduce exposure. Each has a practical deadline. None requires external legal counsel to initiate – but each benefits from one.
First, conduct a gap review of your current screening procedures within the next 30 days. Map every transaction flow against the obligation to screen before execution. Identify whether your compliance officer has formal written authority to halt a transaction pending verification. If that authority is undocumented, the procedure does not exist in the eyes of an enforcement authority. For businesses with transfer pricing arrangements involving related parties in sanctioned jurisdictions, cross-reference your exposure with our analysis of transfer pricing safe harbours under Polish law.
Second, test your beneficial ownership verification process against at least five existing counterparties. The KRS extract is a starting point, not a conclusion. Ultimate beneficial owners must be traced through ownership chains to natural persons. Where a counterparty is domiciled outside Poland, verification must extend to foreign registry data and, where available, EU or OFAC records.
Third, document your compliance officer's appointment in a board resolution dated no later than the date of this review. The resolution should specify the officer's authority, reporting line, and the frequency of list-screening updates. Monthly updates are the minimum; weekly is the standard adopted by supervised financial institutions under KNF guidance.
If your company is already subject to a GIIF inquiry or has received a freeze notice, the 24-hour reporting window may have passed. That forfeits the opportunity to demonstrate voluntary compliance – a factor enforcement authorities weigh heavily in penalty calculations. Immediate legal advice is the only path that does not foreclose options. Our disputes practice covers sanctions enforcement proceedings, KIO appeals, and cross-border asset protection. See the full scope at our disputes practice page.
Frequently asked questions
Q: Does the Polish Sanctions Act 2022 apply to small businesses with no direct exposure to Russia or Belarus?
A: Yes. The Act applies to all entrepreneurs operating in Poland, regardless of size or primary market. Exposure arises not only through direct counterparties but through beneficial ownership chains. A Polish SME supplying goods to an EU-based distributor may unknowingly transact with a company ultimately controlled by a designated person. The obligation to screen applies at every tier of the transaction.
Q: How long does a GIIF investigation typically take, and what are the costs?
A: Preliminary GIIF inquiries typically conclude within 30 to 90 days. Formal administrative proceedings may extend to 12 months. Legal costs for responding to a GIIF inquiry range from PLN 15,000 to PLN 80,000 depending on complexity. Early voluntary disclosure and documented corrective action consistently reduce both the duration and the final penalty amount in enforcement practice.
Q: Is it a common misconception that EU sanctions regulations make the Polish Act redundant?
A: It is. EU sanctions regulations are directly applicable in Poland but they do not replace the Polish Act. The Act adds national-level obligations – including the 24-hour reporting requirement, the compliance officer appointment duty, and the PLN 20 million corporate fine – that have no direct EU equivalent. Both frameworks apply simultaneously. Compliance with EU regulations alone does not satisfy Polish law.
Specific circumstances require specific advice. A sanctions inquiry, a freeze notice, or a gap identified in your screening procedures each carries consequences that compound quickly. Acting within the first 30 days preserves options that later become unavailable.
To receive an expert assessment of your sanctions compliance exposure, contact info@kordeckipartners.com. If your company has received a GIIF notice or a freeze order – and the 24-hour window is approaching – we will conduct an immediate triage review, identify the corrective steps available, and represent you in any enforcement proceedings that follow.
About KORDECKI & Partners
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, dispute resolution, 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.