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Leasing a vehicle or a machine to a company linked to the sanctions list is the provision of an economic resource — and it's prohibited. Liability sits with the lessor.

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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 a leasing company have to run sanction screening?

Yes. Leasing a vehicle, a machine or equipment to an entity on the sanctions list is the provision of an economic resource subject to an absolute ban.

The leased asset is an economic resource

Regulation (EU) 269/2014 prohibits making economic resources available to listed entities — and a car, a machine or IT equipment handed over under a lease is exactly such a resource. The ban covers not only the transfer of ownership but any act of making available an asset from which the user can derive a benefit. Financing a listed entity breaches the rules regardless of the leasing company's AML status.

Special-purpose vehicles and ownership structure

In leasing you rarely meet a lessee who appears directly on the list — the risk is hidden in the ownership structure. A special-purpose vehicle (SPV), a subsidiary or a lessee with foreign capital may be controlled by a listed person. That is why verification has to reach the UBO and not stop at the name of the applicant and the guarantors.

An assignment of the contract is a new risk point

A lease often changes its party mid-term — through assignment or takeover. Every such change is a new counterparty that has to be verified afresh. Without that, the lessor may unknowingly keep financing an entity that was added to the list after the original contract was signed. The lists change every week, so periodic monitoring of the portfolio is also justified.

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 frozen instalments and of the leased asset itself, and of liability for the lessor's management.

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

Fleet leasing through a special-purpose vehicle

A special-purpose vehicle (SPV) leases 8 delivery vehicles. Its UBO is in Annex I of Reg. 269/2014. Handing over the leased assets = making an economic resource available.

SCENARIO 02

Assignment of the contract to a new entity

The current lessee transfers the contract to another company. Without re-screening the new party, the lessor may keep financing a listed entity.

Hot spots

Where the risk is highest.

01
Leasing of vehicles, machinery and IT equipment
02
Special-purpose vehicles (SPVs) and subsidiaries
03
Assignments and takeovers of lease contracts
04
Lessees with foreign capital

Tailored workflow

When exactly to screen the customer.

On the lease application

Screen the lessee, the guarantors and the UBO

Before handing over the asset

Re-screen just before delivery

On assignment or amendment of the contract

Screen the new party to the contract

Mini-case

"LeasePro", 600 contracts / year

Deployed in 5 days, portfolio imported from the leasing system via CSV. Round-the-clock periodic monitoring catches list changes between instalments. 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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