A brief summary for Crypto Asset Service Providers starting up in Poland regarding sanctions:

As you might already know, sanctions are restrictive measures imposed by governments or international bodies to penalize and deter undesirable activities, ensuring compliance with international laws and norms.

• Specific restrictive measures in Poland should not only be applied when a person or entity is under international sanctions such as those introduced by the UN, but also when they have been sanctioned by General Inspector of Financial Information in Poland (“GIIF”) and includedin the list conducted by GIIF, based on Article 120(1) of the Polish AML Act. 

• The application of specific restrictive measures by an obligated institution amounts to the freezing of assets and the withholding of assets without prior notification to the persons and entities subject to sanctions, but does not finalize the process. 

• All information held relating to the freezing or withholding of assets shall be transmitted by CASP to GIIF without delay, but no later than 2 working days after the freezing or withholding of assets. 

• CASP shall also ensure compliance with both the European Union's broad sanctions and Poland's specific legislative measures in response to Russia's aggression against Ukraine.

In Poland, decisions of the Minister of the Interior and Administration on the subject of these kinds of sanctions are made in line with the Act of 13 April 2022 on special solutions to prevent support for aggression against Ukraine and to protect national security. 

☂️To explore how we can support your AML reporting obligations or other AML initiatives, do not hesitate to contact us.