SCENARIO 01
A new client with a foreign structure
The firm takes on a company backed by foreign capital whose UBO is in Annex I of Reg. 269/2014. Keeping its books is the provision of a prohibited service.
Keeping the books or handling the accounts of a company linked to the sanctions list is the provision of a service — and it's prohibited. The accounting firm is liable.
Yes. Keeping the books and accounts of an entity on the sanctions list as a service is a provision covered by the ban — and an accounting firm is also an obliged entity under AML law.
Regulation (EU) 269/2014 prohibits providing services to entities on the list and making funds and economic resources available to them. Keeping the books, tax accounting and payroll all fall squarely within that. Sectoral sanctions — Regulation (EU) 833/2014 — separately restrict the provision of accounting and tax-advisory services to Russian entities.
Entities that keep accounting books as a service, and tax advisers, are obliged entities within the meaning of the Anti-Money Laundering Act of 1 March 2018. This carries a duty to apply customer due diligence measures. The sanctions duty, however, is a separate basis — screening against sanctions lists is necessary regardless of AML procedures.
An accounting firm takes on clients based on basic registration data, often without insight into the ownership structure. A newly serviced company may be controlled by a UBO on the list, and links also arise through the client's owners and counterparties. Verification should cover the serviced entity and the people who run it.
The Act of 13 April 2022 provides for an administrative penalty of up to PLN 20M for breaching the ban. Directive (EU) 2024/1226 requires EU states to criminalise sanctions violations — in Poland it is being transposed by draft bill UC92. On top of that comes the risk of liability for the firm's owner and of losing the trust of the remaining clients.
This material is educational and does not constitute legal advice. Legal status: May 2026. Basis: Council Regulations (EU) 269/2014 and 833/2014 and the Polish Act of 13 April 2022.
The firm takes on a company backed by foreign capital whose UBO is in Annex I of Reg. 269/2014. Keeping its books is the provision of a prohibited service.
An existing client changes hands — the new UBO has been added to the sanctions list. Without re-screening, the firm keeps providing a service to a listed entity.
Deployed in 3 days, client base imported from the accounting software via CSV. Periodic portfolio monitoring catches ownership changes and new listings. Package: Business — 5 900 EUR one-time.
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