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Weronika Achramowicz

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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. Universally applicable sanctions With respect to sanctions that must be complied with by all persons subject to the Polish jurisdiction,…

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: freezing of funds and economic resources prohibition of making funds or economic resources available prohibition of knowing and voluntary participation in activities aiming at, or resulting in, circumvention of the above measures…

Poland has introduced significant amendments to the Act of 13 April 2022 on special measures relative to counteracting the support for the aggression against Ukraine and relative to national security protection (“Polish Sanctions Regulation”). See here for our previous blog post on the Polish Sanctions Regulation. The Act of 5 August 2022 that amends the Polish Sanctions Regulation and the Act on the National Revenue Administration (“Amendment”) was published on 17 August 2022 and entered…

On 30 June 2022, Polish government issued a note outlining amendments to the Polish Act of 13 April 2022 on special measures relative to counteracting the support for the aggression against Ukraine and relative to national security protection (“Polish Sanctions Regulation”). See here for our previous blog on the Polish Sanctions Regulation. The main changes to be introduced are: a) the institution of a temporary administrator for entities targeted by Polish national sanctions (“sanctioned entities”),…