A Warsaw-based trading company wins a contract with a new supplier. The deal looks clean. Then, three weeks later, a routine bank check flags the counterparty against the EU consolidated sanctions list – and the transaction is frozen. The company faces not only a blocked payment but potential criminal exposure for its directors. That scenario is no longer hypothetical. It is happening with increasing frequency across Poland.

Polish companies are subject to EU sanctions regulations directly applicable in Poland, as well as domestic enforcement rules under the Act on Counteracting Money Laundering and Terrorism Financing. Failure to screen counterparties before entering a transaction can trigger criminal liability for board members and forfeiture of the transaction proceeds. The obligation applies regardless of company size – there is no minimum revenue threshold for screening duties.

This alert covers three areas: what has changed in the sanctions framework, which companies are most exposed, and what concrete steps must be taken now. Deadlines are short. Some consequences are irreversible.

What has changed in the Polish sanctions framework?

EU sanctions packages have expanded at a pace that outstrips most internal compliance calendars. Each new package adds designated individuals, entities, and sectors. The Office of Foreign Assets Control (OFAC) lists, while not directly binding in Poland, are increasingly referenced by Polish banks as a condition of correspondent relationships. Polish companies that ignore OFAC exposure risk losing banking access – a practical consequence that arrives faster than any court ruling.

Domestically, the Financial Intelligence Unit (Generalny Inspektor Informacji Finansowej, GIIF) has intensified its oversight of obligated institutions. Banks, payment processors, and leasing companies now report suspicious transactions more aggressively. That means your counterparty's bank may flag a payment before your own compliance team does. The National Court Register (KRS) data alone is no longer sufficient due diligence. Beneficial ownership must be traced and screened.

The Polish Financial Supervision Authority (KNF) has also issued guidance requiring regulated entities to implement automated screening tools. Non-regulated companies are not formally required to use automation – but manual screening of large counterparty lists is demonstrably inadequate and creates evidentiary problems if a breach is later investigated.

  • EU consolidated sanctions list – updated multiple times per month
  • UN Security Council consolidated list – incorporated by EU regulation
  • OFAC SDN list – indirectly relevant via banking relationships
  • Polish domestic list – maintained by GIIF, updated irregularly

Who is affected and what are the thresholds?

Every Polish legal entity conducting business with non-Polish counterparties carries screening obligations. The obligation is not limited to financial institutions. Manufacturing companies, IT service providers, logistics operators, and real estate developers all fall within scope if they transact with entities that could appear on a sanctions list. The relevant question is not sector – it is counterparty geography and ownership structure.

We secured a reversal of a sanctions-related contract freeze for a manufacturing client in the Mazowieckie region (autumn 2025). The company had screened the direct counterparty but missed a 25% beneficial owner who appeared on the EU list three months after the contract was signed. Rescreening obligations – not just pre-contract checks – are what most companies overlook.

Threshold figures matter here. Under EU sanctions law, a designated person's ownership or control of 50% or more of an entity triggers the same restrictions as if the entity itself were listed. Control can be indirect. A chain of three holding companies, each below 50%, may still constitute control under the aggregation rules. That analysis requires legal review, not a database click.

Criminal exposure for directors is personal. Under Polish criminal law, a board member who authorises a transaction with a sanctioned entity faces up to 5 years' imprisonment. That consequence is irreversible once proceedings begin. For a foreign investor's Polish subsidiary, the reputational damage in the parent jurisdiction compounds the domestic legal risk. For guidance on cross-border enforcement issues that arise when sanctions disputes reach courts, see our analysis of enforcing a France judgment in Poland.

What must Polish companies do now?

Three immediate actions apply to virtually every Polish company with international counterparties. First, conduct a full retroactive screen of all active contracts against current EU and GIIF lists. This is not a one-time exercise – it must be repeated at least monthly, and immediately following each new sanctions package. Second, implement a rescreening trigger for any change in counterparty ownership. Third, document every screening decision with a timestamp and the list version used.

We obtained interim protection for a technology client in Lower Silesia (spring 2026) whose payment processor froze accounts following an automated sanctions flag. The flag was a false positive – a name-match with no ownership link. Resolving it required formal written representations to both the processor and the GIIF within 14 days. Companies without documented screening records had no basis to contest the freeze quickly.

For companies involved in procurement or public tenders, the Public Procurement Office (Urząd Zamówień Publicznych, UZP) has clarified that a KIO appeal – a challenge before the National Appeals Chamber (Krajowa Izba Odwoławcza, KIO) – does not suspend sanctions-related exclusion grounds. Sanctions compliance is a threshold condition, not a procedural one. For investors structuring their Polish operations to minimise exposure, our guide on tax structuring for Poland investors addresses related entity-structure considerations. Companies with UAE counterparties should also review our step-by-step on enforcing a UAE judgment in Poland for enforcement context.

Immediate compliance checklist:

  • Screen all active counterparties against EU consolidated list – within 7 days
  • Trace beneficial ownership to the 50% control threshold for all non-EU counterparties
  • Establish a monthly rescreening schedule with documented timestamps
  • Assign a named compliance officer responsible for sanctions screening
  • Brief board members on personal criminal liability exposure

Specific situations carry additional urgency. A company that has already transacted with a counterparty now appearing on a sanctions list must take legal advice immediately. Voluntary disclosure to the GIIF within a short window – typically 30 days from discovery – is treated more favourably than a disclosure prompted by investigation. Waiting forfeits that advantage permanently.

Your company's specific exposure depends on counterparty geography, ownership structure, and transaction history. Delay in addressing a known sanctions risk is itself an aggravating factor under Polish enforcement practice – and it precludes the voluntary disclosure benefit that remains available today.

If your company transacts with non-EU counterparties, has not conducted a retroactive screen in the past 30 days, or lacks documented screening procedures, contact info@kordeckipartners.com. We will assess your exposure, identify rescreening priorities, and implement a defensible compliance record: info@kordeckipartners.com.

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 arbitration in Poland. 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.