SCENARIO 01
Long-term office lease
Brokerage of a 600 m² lease to an "advisory firm" whose UBO is on the annex. A 5-year contract worth PLN 2.1M. The broker provides the service → liability.
Brokering the rental of a unit to a company whose UBO is on the list is a prohibited service. Liability sits with the broker and the property manager — regardless of who owns the property.
Yes — and for two independent reasons. Real-estate brokerage is an obliged entity under AML law, and the sanctions ban applies to every company regardless of that status.
First: Regulation (EU) 269/2014 prohibits making economic resources — and a property, along with brokerage of it, plainly falls within that — available to entities on the EU list. Second: real-estate agents are an obliged entity within the meaning of the Anti-Money Laundering Act of 1 March 2018, which imposes additional customer due diligence duties. Even without the second basis, the first is enough.
Liability rests with whoever provides the service. In long-term lettings, sale brokerage and letting management, that is the broker and the manager — regardless of who owns the unit. You have to check the principal, the target party to the transaction and the buyer's UBO, especially with offshore companies and non-resident clients.
Cash transactions and payments from foreign accounts are a particular flashpoint. With a notarial deed, the duty to verify falls on both the broker and the notary. Re-screening the UBO just before the deed is signed catches listings that appeared after the brokerage agreement.
For making resources available to a listed party, the Act of 13 April 2022 provides for an administrative penalty of up to PLN 20M, while AML law adds separate sanctions for the absence of procedures. Directive (EU) 2024/1226 adds criminal liability for sanctions violations (in Poland, draft bill UC92). A documented screening is at the same time evidence of due diligence.
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.
Brokerage of a 600 m² lease to an "advisory firm" whose UBO is on the annex. A 5-year contract worth PLN 2.1M. The broker provides the service → liability.
Cash transaction above the EUR 10,000 threshold. Buyer — an individual on the OFAC list. Both the broker and the notary are liable.
Deployed in 3 days. Process integrated with the client file — screening mandatory before signing the brokerage agreement. Package: Business — 5 900 EUR one-time.
No salesperson, no slide deck. We'll show the install and answer the legal questions.