New sanctions act in Poland: penalties, obligations and corporate liability

The freezing of bank accounts, suspension of deliveries, administrative fines of up to PLN 20 million, and personal liability of management board members are direct risks for businesses, exporters and importers. The draft legislation significantly tightens the rules on liability for non-compliance with sanctions regulations. For companies engaged in international trade, this means the need to verify their supply chains and review their internal compliance procedures.

Changes to polish sanctions regulations: what will the new act change?

Currently, businesses are directly required to comply with EU regulations and the Polish sanctions act (the Act of 13 April 2022 on special measures to counteract support for aggression against Ukraine), while the current Polish sanctions list is limited exclusively to entities sanctioned in connection with the aggression against Ukraine.

The new draft act consolidates the above framework into a single legislative instrument, implements EU Directive 2024/1226 and introduces a new sanctions list, expanded to include, among other things, the FIMI criterion (addressing foreign interference and disinformation targeting state security). The consolidation of the relevant provisions is intended to make them easier for businesses to apply.

National restrictive measures will apply to entities included on the sanctions list, including:

• freezing of funds and economic resources;
• prohibition on making funds or economic resources available to such entities;
• deeming a foreign national’s stay in Poland undesirable;
• exclusion from certain public procurement proceedings.

As a result, businesses operating in international markets will be required to conduct thorough checks of their contractors’ ownership structures and beneficial owners.

Protection against sanctions: how can a company prepare for the new obligations?

The draft act provides for a significant tightening of liability rules and introduces severe penalties for violations of or attempts to circumvent restrictive measures. To protect a business against financial sanctions and potential criminal liability, companies should consider taking the following steps:

• verifying the beneficial owners and ownership structure of contractors;
• verifying the end-use of goods and including clauses in export agreements prohibiting the re-export of goods to sanctioned countries;
• reviewing public procurement agreements. The draft provides for a 120-day period during which the contracting authority may withdraw from an agreement if the contractor is added to the sanctions list;
• establishing a procedure for providing the relevant authorities with information held by the company concerning sanctioned entities, including information on assets held by such entities or transactions carried out by them.

Penalties for violating sanctions: up to PLN 20 million and criminal liability

The draft act introduces three separate types of liability for non-compliance with sanctions regulations.

1. Administrative fines. A fine of up to PLN 20,000,000 may be imposed for violating prohibitions or failing to comply with sanctions-related obligations.
2. Liability of collective entities. In implementing EU Directive 2024/1226, the draft introduces into the Act on the Liability of Collective Entities a financial penalty for companies ranging from PLN 10,000 to PLN 200,000,000 or up to 5% of revenue.
3. Liability of individuals. The draft act introduces a structured catalogue of sanctions-related offences, with prison sentences ranging from 3 months to 12 years. The most severe penalties (2 to 12 years’ imprisonment) will apply to the illegal trade in sanctioned goods of significant value and violations of prohibitions concerning trade in arms or dual-use items.

The draft act is currently being considered by Sejm committees, with the final deadline for submitting the committee report set for 20 October 2026. Businesses therefore still have time to thoroughly review their verification procedures and prepare for the upcoming regulations.

New sanctions act: time to prepare your business and compliance procedures

The proposed regulations will increase the importance of screening contractors, beneficial owners and supply chains, while violations may result in significant financial penalties and criminal liability. Businesses should already assess whether their sanctions compliance procedures and commercial agreements are aligned with the proposed changes.

Our law firm advises businesses on economic sanctions, contractor screening and adapting compliance procedures. Contact our team to discuss the risks associated with the new regulations.