UNICORN PRIVATE Sanctions compliance in Poland: which rules apply and what companies must do
In short
In Poland, EU sanctions regulations apply directly, and the Act of 13 April 2022 adds a national sanctions list.
The national list is kept by the Minister of the Interior and Administration, and the General Inspector of Financial Information (GIIF) handles financial matters.
Companies must not make funds or goods available to listed parties and should screen clients and suppliers against both lists.
Applicable rules and competent authorities
EU sanctions regulations are binding in Poland without national transposition.
The Act of 13 April 2022 on special solutions to counteract support for aggression against Ukraine and to protect national security created a national sanctions list, kept by the Minister of the Interior and Administration. Persons and entities on this list are subject to national measures, such as asset freezes.
The General Inspector of Financial Information (GIIF), at the Ministry of Finance, is involved in applying financial restrictive measures and in anti money laundering supervision.
Practical duties for companies
- Do not make funds or economic resources available, directly or indirectly, to persons and entities listed by the EU or on the Polish national list.
- Screen clients, suppliers, owners and banks against both lists, also when they change.
- Check whether your goods need an export licence, including dual use goods.
- Report frozen funds and request licences when the rules require it.
- Keep records of the checks you carried out and of the decisions taken.
Fines and penalties
Statutory maximums we verified on the official texts:
- European Union, Directive 2024/1226: fines on companies of at least 5% of worldwide turnover or €40,000,000, and prison terms of at least 5 years. (source)
Maximum amounts set by law, as published by the authorities linked, checked on October 29, 2026.
Official sources
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Frequently asked questions
Does Poland have its own sanctions list?
Yes. Since the Act of 13 April 2022 Poland has a national sanctions list, kept by the Minister of the Interior and Administration, in addition to the EU lists.
What is the GIIF?
The General Inspector of Financial Information (GIIF) is the Polish financial intelligence authority at the Ministry of Finance.
Do EU sanctions apply directly to Polish companies?
Yes. EU sanctions regulations are directly binding in Poland, and national measures apply on top of them.
The program can make mistakes. The final responsibility for compliance stays with your company. Unicorn Intelligence is an information tool. Decisions and legal obligations, including sanctions compliance, due diligence and tender participation, remain with the customer.
Unicorn Intelligence checks your clients and suppliers against the sanctions lists every day.