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 holds 33% of stock in Grupa Azoty S.A.

The state-appointed administrator has the right to manage business of the entities subjected to the measure, and to sell the entities’ assets. Polish authorities have already declared the intent to use Polish law provisions allowing the state to acquire, or the administrator to sell, the administrated business, upon reimbursement.

Poland enforces the EU sanctions, in addition to enforcing national sanctions that go beyond the EU sanctions. National sanctions include a local sanctions list, with designated individuals and entities being subject to, inter alia, asset freezes, entry bans, and prohibition of making economic resources available. The local sanctions list currently consists of over 480 designations.

Poland-designated entities may be subjected to compulsory administration. The measure has already been imposed on PAO Gazprom (with respect to shares in EuRoPol Gaz S.A., the owner of Polish length of the Yamal gas pipe) and Novatek Green Energy sp. z o.o.  Per Polish authorities, over 20 bidders have already expressed interest in the acquisition of Novatek’s Polish business or specific portions thereof. Sale of Gazprom’s stake in EuRoPol Gaz is under preparation.

For more information, see our earlier blog posts on Polish national sanctions, compulsory administration and sanctions enforcement in Poland, or contact Piotr Jaskiewicz at Piotr.Jaskiewicz@bakermckenzie.com.


Piotr heads Baker McKenzie’s International Trade Practice in Poland. He is a counsel in the International Commercial & Trade and Mergers & Acquisitions Practice Groups, and a member of the Investigations, Compliance and Ethics practice. Educated in Poland and France, he has worked in the Firm's offices in Warsaw, Chicago, and London, as well as at a Munich-based client, and advised on commercial, trade, corporate/M&A and compliance mandates. He is admitted to practice in Poland and California.