SCENARIO 01
A B2B framework agreement for connectivity
The operator signs a contract for connectivity and data transmission for a company whose UBO is in Annex I of Reg. 269/2014. Providing the service means making it available.
Activating a subscriber service for a company linked to the sanctions list is the provision of a service — and it's prohibited. The duty applies to the operator regardless of AML status.
Yes. Activating a subscriber service, leasing infrastructure or wholesale resale to an entity on the sanctions list is the provision of a service — and it is prohibited.
Regulation (EU) 269/2014 prohibits making funds, economic resources and services available to entities on the EU list. Providing connectivity, data transmission or leasing infrastructure is a service within its meaning. The duty binds the operator regardless of any AML obliged-entity status — the mere fact of providing a service to a listed entity is enough for a breach to occur.
Mass servicing of individual subscribers carries low risk, but framework agreements and B2B contracts carry significant risk. The client may be a company whose UBO is on the list. Verification before signing a corporate contract should cover both the subscriber and its ownership structure, especially with clients backed by foreign capital.
The harder area is wholesale resale, roaming and leasing infrastructure — optical fibre or rack space in a data centre. The operator may provide a service to a partner who then serves a listed client, or lease a resource to a company controlled by a listed person. Without verifying the chain of counterparties, the risk stays invisible.
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. Some telecom equipment and services are also covered by the sectoral sanctions under Regulation 833/2014, which creates an additional layer of duties.
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 operator signs a contract for connectivity and data transmission for a company whose UBO is in Annex I of Reg. 269/2014. Providing the service means making it available.
Leasing optical fibre or rack space in a data centre to a company controlled by a listed person is making an economic resource available — which is prohibited.
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