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For hotels and long-term rentals

Accommodating or renting property to a company linked to the sanctions list is the provision of a service and of a resource — and it's prohibited.

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Works offline

GDPR-aligned

EU / UN / OFAC lists

Auditable reports

Legal status for this industry

The duty not to provide services or funds applies regardless of AML status. Brokerage, advisory, leasing, insurance — each is a "service" within the meaning of Reg. 269/2014.

Reg. 269/2014 · 833/2014 · Polish Act of 13.04.2022

Legal obligation

Do a hotel and a long-term rental company have to run sanction screening?

Yes. Providing accommodation services and renting property to an entity on the sanctions list are prohibited acts — the service provider and the landlord are liable.

Accommodation and rental are provisions covered by the ban

Regulation (EU) 269/2014 prohibits providing services to listed entities and making economic resources available to them. A hotel service is a provision to the guest, and renting out a property is making available a resource from which the tenant derives a benefit. The duty does not depend on AML status — it follows directly from sanctions law.

The risk is highest in the B2B segment

A single booking by an individual guest is low risk. The real exposure is corporate bookings, long-term lettings to companies, conference packages and contracts with property-management firms. Here the party to the contract is a business entity that may be controlled by a UBO on the list.

The payer is often not the guest

In corporate bookings and lettings, the contract is signed and the payment made by an entity other than the person actually using the service. Verification should cover the party placing the order, the payer and the tenant — making funds or a service available to any listed party breaches the ban.

What skipping the check risks

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 the contract funds being frozen and of liability for the property's management and owner.

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.

Risk scenarios

What this looks like in your work.

SCENARIO 01

A long-term let to a company

A company rents out an apartment for 12 months to a company whose UBO is in Annex I of Reg. 269/2014. Making the property available = making an economic resource available.

SCENARIO 02

A corporate booking with a company payment

A hotel takes a stay-package booking paid from the account of a company on the sanctions list. Providing the service to it is covered by the ban.

Hot spots

Where the risk is highest.

01
Corporate bookings and conference packages
02
Long-term lettings to companies
03
Payments made by third parties
04
UBOs of tenants and the parties placing orders

Tailored workflow

When exactly to screen the customer.

On a B2B booking or a rental contract

Screen the party placing the order, the tenant and the payer

Before the stay or the tenancy begins

Verify the ultimate beneficial owner

Periodically for long-term rentals

Monitor for sanctions-list changes

Mini-case

"Apart Stay" group, 320 rental contracts / year

Deployed in 4 days, tenant and payer screened when the contract is signed. Monitoring of the long-term rental portfolio catches list changes. Package: Business — 5 900 EUR one-time.

typical persona

Service-side SMB

1–20 staff · deployed in 7 days

Most-asked questions

Truth first, technology second.

Does this really apply to my industry?

Yes. The ban on making funds available or providing services to listed persons (Art. 2 of Reg. 269/2014) applies to all economic operators — regardless of whether the industry is formally under AML obligations. For sectors like travel or real estate, criminal and administrative liability already exists today.

What if the customer doesn't agree to be screened?

Screening uses data you already hold from the contract or invoice (first name, last name, company name, tax ID, optionally date of birth). It does not require customer consent — it is the business's discharge of a legal obligation (GDPR Art. 6(1)(c)).

What do I do when there's a hit?

The app flags the result red, generates a justified report, and surfaces the procedure: pause the service, freeze funds, notify the FIU within 24 hours. Nothing is reported automatically — the decision sits with you.

Are the reports accepted by the FIU and tax authority?

Each report carries a timestamp, the reference-list version, the operator identifier and a hash of the input file — a format aligned with regulator expectations. Local archival for 5 years (the required retention period).

How often are the lists updated?

Every hour, plus immediately after publication of changes in the Official Journal of the EU. The app pulls reference files itself — it never sends customer data the other way.

Does this integrate with my CRM?

Yes. The Business and Enterprise tiers expose a REST API and ship integrations for popular CRMs (Pipedrive, HubSpot, Salesforce, Bitrix). On Starter you use the manual form.

Where is my data physically?

Wherever you install the app — your machine, your server, your network. There is no "Sanqto cloud" for customer data. Consequence: no data-processing agreements, no third-country transfers.

What's the fine if I don't screen?

Up to PLN 20,000,000 in administrative fines (Art. 15(1)(2) of the Act of 13 Apr 2022) and criminal liability up to 15 years for making funds available. Liability sits with the business — not the customer.

Contact

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Demo on your data (locally, on your hardware).

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