Global sanctions guide

  1. Does Poland have a sanctions regime in place?

As a member of the UN and EU, Poland is required to comply with all sanctions implemented by the UN and EU.

  1. Does Poland implement UN sanctions?


  1. Does Poland implement an autonomous sanctions regime?

Yes, Poland can implement sanctions in addition to those brought into effect by the UN/EU, through the use of domestic regulations.

  1. What is the nature of the sanctions regime in Poland?

Sanctions are implemented in Poland through a number of Acts, including the Anti-Money Laundering and Anti-Terrorist Financing Act (“AML/CTF Act 2000”) and the Act on the Trading Goods, Technology and Services of Strategic Importance to the State Security and the Maintenance of International Peace and Security.

The restrictive measures in force include arms embargoes, export controls, asset freezes, financial sanctions on designated individuals/entities and travel bans on named individuals.

  1. Does Poland maintain a list of sanctioned individuals and entities?

Poland relies on the consolidated list maintained by the EU.

  1. Are there any other lists related to sanctions?


  1. Does Poland have a licensing or authorization system in place?

Yes, authorization can be obtained from the relevant public authority, eg the competent Minister of Economy for export controls/trade sanctions or the Ministry of Foreign Affairs and competent Minister of Finance for economic sanctions.

  1. What are the consequences for a breach of sanctions in Poland?

Breach of the various restrictive measures can constitute a criminal offence by corporate entities and/or individuals (as set out in the Polish Criminal Code and the AML/CTF Act 2000). Penalties for such offences can include imprisonment, fines and temporary or permanent disqualification from pursuing specified business activities.

Failure to freeze an account and dealing with funds of a designated individual/entity is deemed to be a prohibited act pursuant to the AML/CTF Act 2000. Such failures are subject to imprisonment of up to three years. Trading in specified goods without a permit or contrary to the conditions in a permit is also a prohibited act pursuant to the Act on the Trading of Goods, Technology and Services of Strategic Importance to the State Security. Such offences carry a term of imprisonment of up to ten years for individuals. Corporate entities can be issued with a fine amounting to Polish Zloty (“PLN”) 200,000.

  1. Who are the relevant regulators in Poland and what are their contact details?

Ministry of Foreign Affairs co-ordinates issues related to imposing and implementing international sanctions.

Ministry of Foreign Affairs
Department of Law and Treaties
Al. J. Ch Szucha 23
00-580 Warsaw

T: (+48) 22 523 9427

Ministry of Finance coordinates international cooperation in respect of capital markets.

Ministry of Finance
ul. Świętkorzyska 12
00-916 Warsaw

T: (+48) 22 694 5555

The Inspector General of Finance Information is responsible for pursuing actions regarding money laundering and financing of terrorism.

Inspector General of Finance Information
Department of Finance Control in Ministry of Finance
ul. Świętkorzyska 12
00-916 Warsaw

Telephone: (+48) 22 694 3060

Contributor law firm

Grzegorz Kott, Wierzbowski Eversheds Sutherland, Centrum Jasna, ul. Jasna 14/16A, 00-041, Warsaw, Poland