Poland

Global sanctions guide

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  1. Does Poland have a sanctions regime in place?

Yes

  1. Does Poland implement UN sanctions?

Yes.  Poland is a member of the European Union, which implements UN sanctions in all member states by way of directly applicable regulations.

  1. Does Poland implement an autonomous sanctions regime?

Yes.  Poland implements its own sanctions regime by passing domestic regulations.

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

To the extent that international sanctions are not directly effective in Poland, they are implemented 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?

No.  Poland relies on UN and EU sanctions lists.

  1. Are there any other lists related to sanctions?

No.

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

Yes.  Authorisation can be obtained from the relevant public authority – for example the competent Minister of Economy for export controls, 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?

The consequences for a breach of sanctions are set out in the Polish Criminal Code and the AML/CTF Act 2000.  They 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.  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 10 years for individuals. Corporate entities can be issued with a fine amounting to 200,000 PLN.

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

The Ministry of Foreign Affairs co-ordinates the implementation and enforcement of international sanctions in Poland.

Department of Law and Treaties
Al. J. Ch Szucha 23
00-580 Warsaw
Poland

Telephone: (+48) 22 523 9427
Website: http://www.msz.gov.pl/en/ministry_of_foreign_affairs

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

ul. Świętkorzyska 12
00-916 Warsaw
Poland

Telephone: (+48) 22 694 5555
Website: http://www.mf.gov.pl/en/news

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

Department of Finance Control
Ministry of Finance
ul. Świętkorzyska 12
00-916 Warsaw
Poland

Telephone: (+48) 22 694 3060

Contributor law firm

Krysztof Haladyj, Wierzbowski Eversheds, Centrum Jasna, ul. Jasna 14/16A, 00-041, Warsaw, Poland