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Placing a policy for a vehicle owned by a company controlled by a listed person is a prohibited brokerage service. The penalty falls on the broker — not just on the carrier.

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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

Does an insurance broker have to run sanction screening?

Yes. Brokering a policy for a person or company on the sanctions list is a prohibited service — the broker and the agent are liable too, not just the carrier.

The ban covers brokerage, not just the payout

Regulation (EU) 269/2014 prohibits making funds and economic resources available to listed entities, as well as providing services to them. Concluding and renewing a policy, advisory work and brokerage itself all fall within that concept. Part of the insurance market is also an obliged entity under AML law, but the sanctions duty applies regardless of that status and reaches every link in the chain: the agent, the broker and the insurer.

Where the risk is highest

The greatest exposure comes from corporate and fleet policies, high-value property insurance, and foreign and non-resident clients. The real problem is the UBO: the policyholder may be a "clean" company, yet a listed person controls it. Screening should cover the policyholder, the property owner and — when a claim arises — the payout beneficiary.

The timing of the check matters

Sanctions lists change every week. A client who is "clean" when the policy is taken out may be added to the list before it is renewed, or before a claim is paid. That is why screening is not a one-off act at signing but a process: at conclusion, at every renewal, and on any payout above a set threshold.

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. Penalties aside, a payout to a listed entity carries a real risk of frozen funds and management liability.

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

Motor policy for a fleet

Brokerage of liability/comprehensive cover for a 12-vehicle fleet whose UBO is in Annex I of 269/2014. Issuing the policy = providing a financial service.

SCENARIO 02

Property insurance on a residence

Property cover on an PLN 8M villa. Owner — a Cypriot company; the UBO is on the list. Fine up to PLN 20,000,000.

Hot spots

Where the risk is highest.

01
Corporate and fleet policies
02
High-value property cover
03
Foreign and non-resident clients
04
UBOs of offshore companies

Tailored workflow

When exactly to screen the customer.

Before issuing the policy

Screen the policyholder and the property owner

At renewal

Re-screen the portfolio

On a claim above the threshold

Screen the payout beneficiary

Mini-case

"NordPolisa" agency, 3,400 policies / year

Deployed in 6 days, integrated with the agency system over CSV. From week one, two UBO links detected, two policies paused. 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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