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.
2. Does Poland implement UN sanctions?
3. 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.
4. What is the nature of the sanctions regime in Poland?
Sanctions are implemented in Poland through the Anti-Money Laundering and Anti-Terrorist Financing Act (“AML/CTF Act 2018”) 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.
5. Does Poland maintain a list of sanctioned individuals and entities?
The Polish AML regulator (the General Inspector of Financial Information) can maintain such a list but currently it relies on the UN and EU sanction lists. Moreover, the Council of Ministers can issue a list of countries with a ban or limitation on trading in dual-use units.
6. Are there any other lists related to sanctions?
7. 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 Development, Labour and Technology for export controls/trade sanctions or the General Inspector of Financial Information in the Ministry of Finance for economic sanctions.
8. What are the consequences for a breach of sanctions in Poland?
Failure to freeze an account and dealing with funds of a designated individual/entity is penalized pursuant to the AML/CTF Act 2018. Such failures are subject to an administrative fine up to EUR 5,000,000 or 10% of the annual turnover. In some circumstances they may also be considered as an offense under the criminal code.
Breach of the various restrictive measures can constitute a criminal offense (as set out in the Polish Act on the Trading Goods, Technology and Services of Strategic Importance to the State Security and the Maintenance of International Peace and Security 2000). Penalties for such offenses can include imprisonment, fines and temporary or permanent disqualification from pursuing specified business activities.Trading in dual-use items 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 offenses 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.
9. Who are the relevant regulators in Poland and what are their contact details?
The Council of Ministers is responsible for sanctions related to trading in dual-use items
Council of Ministers Chancellery of the Prime Minister Al. Ujazdowskie 1/3 00-583 Warsaw Poland T: +48 22 250 01 15
Ministry of Development, Labour and Technology co-ordinates issues related to trading in dual-use items.
Ministry of Development, Labour and Technology
Department of Sensitive Goods Trading and Technical Security Pl. Trzech Krzyży 3/5 00-507 Warsaw Poland T: +48 22 411 96 65
The General Inspector of Financial Information coordinates actions related to preventing money laundering and financing of terrorism.
General Inspector of Financial Information
Department of Financial Information in the Ministry of Finance ul. Świętkorzyska 12 00-916 Warsaw Poland T: +48 22 694 59 70
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