Poland is an EU member state that follows a dual sanctions regime. This member state enforces EU sanctions, in addition to enforcing national sanctions that go beyond them. Businesses holding the status of an “obliged entity” under Polish AML legislation must take into account a new list of financial sanctions released on 26 September 2023. With respect to sanctions that must be complied with by all persons subject to the Polish jurisdiction, two regimes apply:…
On 11 July 2023, Polish authorities announced that assets of three entities controlled by Vyacheslav Kantor were subjected to compulsory administration in Poland. The entities, two incorporated in Cyprus and one incorporated in Luxembourg, as well as Vyacheslav Kantor, have earlier been designated on the Polish sanctions list. The entities jointly hold 19.82% of publicly traded stock of Grupa Azoty S.A.. The estimated value of the administered assets is PLN 500 million. Poland’s State Treasury…
This week in our Sanctions Enforcement Around the World series, we bring you the view from Poland, an EU member state with a dual sanctions regime. Poland enforces the EU sanctions, in addition to enforcing national sanctions that go beyond the EU sanctions. This post incorporates data on local enforcement activity, as obtained by Baker McKenzie through access to government sources. Until April 2022, Poland did not have specific procedures for enforcement of sanctions, nor…
On 29 May 2023, Poland imposed sanctions on 365 citizens of Belarus, as well as other individuals and entities. Polish law requires an individual decision and scope of sanctions to be determined with respect to each designated person, however the measures typically include: Polish authorities declared that all designated individuals will also receive a Schengen zone entry ban. The designated persons include: The designations are linked to, inter alia, the sentencing of a Polish-Belarussian journalist…