MSWiA Sanctions List — How to Screen a Counterparty Step by Step

The Polish sanctions list maintained by the Minister of Internal Affairs and Administration (MSWiA) is one of two registers you must check before entering into a contract or accepting a payment from a new client — alongside the EU Consolidated List.¹ Not sure where to find it or how to compare your counterparty’s details correctly? This article walks you through the entire process: from opening the gov.pl page, through matching identifiers, to what to record in the hits register when a check returns a CLEAR result.

Legal status as of: 2026-05-20.

TL;DR — the essentials in 90 seconds

• The MSWiA list is Poland’s official sanctions register, maintained by the Minister of Internal Affairs and Administration under the Act of 13 April 2022 (Journal of Laws 2022, item 835).²
• URL: gov.pl/web/mswia/lista-osob-i-podmiotow-objetych-sankcjami — download the PDF or XLSX file.¹
• The MSWiA list is not the same as the EU list — you must check both; neither substitutes for the other.
• Identifiers to match: NIP (Polish tax ID) or REGON (statistical number) for companies, or PESEL (national ID number) for individuals; when those are absent, use date of birth and country of residence.
• Ownership rule: also check ultimate beneficial owners — sanctions cover companies in which a listed person holds more than 50% of shares or exercises control.³
• On a hit: do not sign any contract, freeze funds already in your possession, and report to the Head of KAS (National Revenue Administration).⁴
• Failure to screen can result in an administrative fine of up to PLN 20 million (Art. 6(2) of the Act of 13 April 2022).⁵

What the MSWiA sanctions list is and who maintains it

The Polish sanctions list was established by the Act of 13 April 2022 on Special Solutions for Countering Support for Aggression against Ukraine and for the Protection of National Security (Journal of Laws 2022, item 835).² It is a domestic sanctions instrument — separate from the EU Consolidated List, though complementary to it. The register is maintained by the minister responsible for internal affairs, in practice the Minister of Internal Affairs and Administration (MSWiA).¹

The list may include individuals and entities against whom there is reasonable suspicion of supporting aggression against Ukraine or posing a threat to national security (Art. 2 of the Act). Applications for listing can be submitted by, among others, the Head of ABW (Internal Security Agency), the Head of AW (Foreign Intelligence Agency), the Head of KAS (National Revenue Administration), and KNF (Polish Financial Supervision Authority). The decision rests with the minister, and each listing is published — making the list a public document accessible to any company.

Being placed on the Polish list has specific consequences: freezing of the entity’s funds and economic resources, a prohibition on third parties making any funds available to them, and exclusion from public procurement procedures.² If you enter into a contract with an entity on the list, you risk not only a financial penalty — the contract itself may be void by operation of law.

It is worth distinguishing the MSWiA list from the EU list. Council Regulation (EU) No 269/2014 of 17 March 2014⁶ and Council Regulation (EU) No 833/2014 of 31 July 2014⁷ form the EU Consolidated List, maintained by DG FISMA of the European Commission.⁸ Both lists apply directly to your business — neither is optional. For more on what a sanctions list is and which lists apply to Polish companies, see our separate article on sanctions lists and the obligations of Polish businesses.

Where to find the MSWiA list on gov.pl — step by step

Accessing the list is straightforward and free — it only takes a few clicks on the government website.

Step 1. Go to the MSWiA page. Open a browser and enter the address gov.pl/web/mswia/lista-osob-i-podmiotow-objetych-sankcjami.¹ This is the official website of the Ministry of Internal Affairs and Administration — the only reliable source of the list. Do not rely on copies published by third-party portals, as these may be out of date.

Step 2. Download the current version of the list. On the page you will find a downloadable file in PDF and XLSX (spreadsheet) formats. For manual screening, XLSX is more practical — you can open it in Excel or LibreOffice Calc and use the search function. Note the download date — you will need it for documentation.

Step 3. Check the date of the last update. The list is updated after every ministerial decision — there is no fixed schedule. A file downloaded a week ago may therefore no longer reflect the current state. Always download a fresh version before each significant transaction. If you handle many counterparties on a recurring basis, consider automating this process.

Step 4. Open the file and familiarise yourself with the structure of an entry. Each entry on the MSWiA list contains: the entity’s full name or the individual’s full name, aliases and former names, identifiers (NIP, REGON, PESEL, passport number, date of birth), country of registration or residence, the legal basis for listing, and the date of listing. These are the fields you will compare against your counterparty’s data — explained in detail in our article on how to read a sanctions list entry.

How to screen a counterparty — a 6-step guide

Simply having the list saved to your drive is not enough. Accurate data matching is what matters — many companies make the mistake of searching by name alone. This is insufficient and can lead both to missing a genuine hit and to false positives that obstruct normal business.

Step 1. Collect complete identifying information on the counterparty. Before you start searching, make sure you have: the company’s full legal name or the individual’s full name, NIP (for entities registered in Poland), REGON (if available), PESEL or passport number and series (for individuals), and country of registration or residence. Incomplete data leads to uncertain results — POSSIBLE instead of CLEAR or MATCH.

Step 2. Search by name, including variants. Search using all name variants: full company name, abbreviation, former trading name. For individuals, check all known names — sanctions lists include transliterations from Cyrillic that can produce different spellings for the same person. For example, “Iwanow”, “Ivanov”, and “Ivanoff” are potentially the same individual. The Ctrl+F function in the XLSX file will search the entire spreadsheet — use short name fragments rather than full strings.

Step 3. Match identifiers, not just the name. When you find an entry with a similar or identical name, do not stop the verification at that point. Compare identifiers step by step: NIP or REGON (for Polish entities), PESEL or passport number (for individuals), date of birth and place of birth, country of registration or residence. Two entities may share the same name but have different NIP numbers — and be entirely different companies. Conversely, an entity on the list may be operating under a changed name, but the same NIP will identify it unambiguously.

Step 4. Check aliases and former names. Look at the aliases and former names columns in the list file. Sanctioned entities frequently change their names or operate simultaneously under several trading names — this is a deliberate tactic to hinder identification. If your counterparty has recently changed its name or undergone restructuring, make sure to verify both names.

Step 5. Apply the ownership rule. EU sanctions cover not only entities listed directly, but also companies in which a listed person or entity holds more than 50% of shares or exercises control over them.³ This means you must check your counterparty’s ownership structure — who its ultimate beneficial owner (UBO) is. If your counterparty’s owner appears on the MSWiA list or the EU list, the transaction is prohibited just as if the counterparty itself were listed. Information on beneficial owners can be verified in the Central Register of Beneficial Owners (CRBR — Centralny Rejestr Beneficjentów Rzeczywistych).

Step 6. Determine the result and document it. Once the screening is complete, assign a result: MATCH (identifiers confirm a hit — same person or entity), POSSIBLE (name or other data coincides but certainty is lacking — requires further manual verification), or CLEAR (no hit found). Whatever the result, record it in the hits register — details below.

What to do on a hit (MATCH / POSSIBLE / CLEAR)

CLEAR result

A CLEAR result means the counterparty does not appear on any list checked. You may proceed with the transaction — but bear in mind that the screening is only valid as of the date the list was downloaded. For the next transaction with the same counterparty you must repeat the check, because the list may have changed. Document the result in the hits register: date, list version, CLEAR result, name of the person who conducted the check.

POSSIBLE result

A POSSIBLE result arises when you have found an entry with a similar name or partially matching data, but cannot definitively determine whether it is the same entity. This is not a signal to automatically block the transaction, but to conduct enhanced verification. Contact the counterparty and request additional identity-confirming documents — for example, a current extract from the National Court Register (KRS), a copy of an identity document, or confirmation of NIP. Document the course of this additional verification and the conclusion reached. If doubts remain after analysis, consult a lawyer or compliance adviser before signing a contract.

MATCH result

A MATCH result means the identifiers confirm: this is the same person or entity listed on the register. You must take several immediate steps. First, do not sign any contract and do not carry out any transactions with that entity — the prohibition follows from law.² Second, if the entity’s funds are already in your possession (for example, an advance payment already received), you are required to freeze them — you may not return or use them without authorisation from the competent authority. Third, report the hit to the Head of KAS (Krajowa Administracja Skarbowa — National Revenue Administration).⁴ The competent authority for domestic sanctions matters is the Head of KAS; for AML matters it is GIIF (Generalny Inspektor Informacji Finansowej — General Inspector of Financial Information).⁹ Fourth, keep full documentation: when you discovered the hit, what steps you took, and in what order.

Do not decide to “wait and see” or to “continue quietly under an exception” — any breach of the prohibition, even an unwitting one, may result in an administrative fine of up to PLN 20 million imposed by the Head of KAS under Art. 6(2) of the Act of 13 April 2022.⁵ For more on the penalties for breaching sanctions in Poland, see our separate article on sanctions violations and their consequences.

How to document screening — the hits register

The hits register is your evidence of due diligence. If the Head of KAS carries out an inspection and asks whether you were screening counterparties — without a register you have no way of proving that you were. “We checked but did not record it” is not an argument that carries any weight in administrative proceedings.

Minimum content of a hits register entry for each screening carried out:

• Date of screening — the day on which the check was performed.
• Counterparty identification data — full company name or individual’s full name, NIP, REGON or PESEL, country of registration.
• List(s) checked — MSWiA list (file download date), EU Consolidated List (download date or version), and where applicable OFAC SDN and UK OFSI.
• List version/date — e.g. “MSWiA list downloaded 2026-05-20”, “Consolidated List DG FISMA ver. 20260518”.
• Screening result — CLEAR / POSSIBLE / MATCH.
• Name of the person who conducted the check — who specifically performed the screening.
• Notes — for POSSIBLE: what further steps were taken and what the final conclusion was; for MATCH: what actions were taken and when.

The register may be maintained in an Excel spreadsheet, dedicated compliance software, or any CRM system — what matters is that each entry is either immutable once closed or at least carries a full change history. A hits register template is included in the Sanqto implementation document package. For more on whether your company must carry out sanction screening and what procedures to put in place, see our separate article on the subject.

The MSWiA list and the EU lists — why you must check both

This question comes up regularly: if I check the EU list, do I still need to check the Polish one? The answer is yes, and for several specific reasons.

Separate legal basis. The EU Consolidated List is based on EU regulations — primarily Regulation No 269/2014⁶ and Regulation No 833/2014⁷ — which are directly applicable in all Member States without the need for transposition.¹⁰ The Polish MSWiA list derives from the domestic Act of 13 April 2022.² It is a separate instrument with its own listing procedure, its own maintaining authority, and its own catalogue of entities.

Different entities on each list. The MSWiA list may contain entities that do not appear on the EU list — and vice versa. The minister may list on the national register an entity operating in Poland or linked to Poland even when the EU Council has not yet issued a corresponding decision. Checking only the EU list may therefore return a CLEAR result while the same counterparty is already on the MSWiA list.

Different update frequencies. The EU list is updated after each sanctions package, which may add dozens of new entries at once. The MSWiA list changes after each individual ministerial decision. Both schedules are independent — you cannot assume that one reflects the other.

Legal consequences. Breaching a prohibition derived from the EU list and breaching a prohibition derived from the Act of 13 April 2022 are two separate grounds of liability — they may be cumulated. The authority enforcing one is not the same as the authority enforcing the other.

In practice: your screening procedure should always include two checkpoints — the MSWiA list and the EU Consolidated List (DG FISMA¹¹). If your company has dealings with entities outside the EU or settles transactions in USD, it is worth adding the OFAC SDN List¹² and the UK OFSI List.¹³ A detailed comparison of all four main sanctions lists can be found in our article on the overview of EU, UN, OFAC, and MSWiA sanctions lists.

How Sanqto can help

Manually downloading two or more lists before every transaction, scrolling through an XLSX file with hundreds of entries, matching identifiers by hand, and recording results in a spreadsheet — this is a process prone to human error, particularly when dealing with a large number of counterparties or when screening is carried out under time pressure. Sanqto automates this process: the software runs on-premise, within your company’s network — counterparty data never leaves your infrastructure. The system downloads current versions of the MSWiA¹ and DG FISMA⁸ lists automatically, and returns the screening result in three states — MATCH, POSSIBLE, or CLEAR. The implementation package also includes a ready-made sanctions policy, a hits register template, and a role-specific procedure guide — the documents you will need in the event of an inspection by the Head of KAS. If you run a travel agency, an estate agency, or operate in the insurance sector, the relevant industry pages contain details specific to your sector.

Frequently asked questions (FAQ)

Is the MSWiA list public and free of charge?

Yes. The MSWiA sanctions list is a public document, available free of charge on the gov.pl website.¹ Anyone can download it in PDF or XLSX format without logging in or registering. Listing is by design public — it is a pressure instrument that only works when widely known.

How often do I need to screen a counterparty?

At a minimum, before every new transaction or when signing a new contract. For ongoing counterparties, periodic re-screening is recommended, because the list can change at any time. There is no statutory fixed frequency — market compliance practice suggests at least once per quarter for continuing relationships. Automating list downloads and screening resolves this systematically — for more on how sanctions list updates work, see our separate article.

What if a counterparty shares the same name as a person on the list?

This is the classic POSSIBLE scenario. A name match alone is not sufficient to confirm a hit — you must compare identifiers: NIP, PESEL, date of birth, passport number, country of residence. If the identifiers differ, you may document the result as CLEAR following enhanced verification. If the identifiers match or you lack sufficient data for comparison — treat the matter as POSSIBLE and do not finalise the transaction without further analysis.

Do I need to check the EU lists as well, or is the MSWiA list enough?

You must check both. The MSWiA list and the EU Consolidated List are separate registers, based on separate legal instruments, and potentially containing different entities.²⁶ Neither is a subset of the other. EU regulations — including Regulation No 269/2014⁶ — are directly applicable to every company in Poland without any further transposition.¹⁰

Does the counterparty’s ultimate beneficial owner (UBO) also need to be screened?

Yes. EU sanctions cover entities in which a listed person or company holds more than 50% of shares or exercises control (the ownership rule).³ Screening only the counterparty’s name without checking its ownership structure may be insufficient — particularly for companies with complex holding structures or registered in jurisdictions with non-transparent registers.

Is there a penalty for failing to document screening?

The Act of 13 April 2022 provides for an administrative fine of up to PLN 20 million for breaching obligations related to freezing funds or the prohibition on making funds available to sanctioned entities.⁵ The absence of screening documentation is not in itself a separate ground for a fine, but it makes it impossible to demonstrate due diligence — which works against you in any dispute with the supervisory authority. The Head of KAS⁴ may take the view that, since you have no evidence of screening, you did not in fact carry it out.

Legal basis

• Act of 13 April 2022 on Special Solutions for Countering Support for Aggression against Ukraine and for the Protection of National Security (Journal of Laws 2022, item 835) — ISAP
• Council Regulation (EU) No 269/2014 of 17 March 2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine — CELEX 32014R0269
• Council Regulation (EU) No 833/2014 of 31 July 2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine — CELEX 32014R0833
• Directive (EU) 2024/1226 of the European Parliament and of the Council of 24 April 2024 on the definition of criminal offences and penalties for the violation of Union restrictive measures — CELEX 32024L1226
• Act of 1 March 2018 on Counteracting Money Laundering and Financing of Terrorism (Journal of Laws 2018, item 723) — ISAP
• Polish MSWiA Sanctions List — gov.pl/web/mswia/lista-osob-i-podmiotow-objetych-sankcjami
• EU Financial Sanctions Database (DG FISMA) — finance.ec.europa.eu/eu-and-world/sanctions-restrictive-measures_en
• EU Consolidated List — finance.ec.europa.eu/eu-and-world/sanctions-restrictive-measures_en
• OFAC Specially Designated Nationals List (SDN) — ofac.treasury.gov
• UK OFSI Consolidated List of Financial Sanctions Targets — gov.uk/government/publications/financial-sanctions-consolidated-list-of-targets

Footnotes

Information, not legal advice. This article is for informational and educational purposes only. It does not constitute legal advice. Legal status as of: 20 May 2026. The specific obligations applicable to your company depend on your business profile and require individual assessment — if in doubt, consult a lawyer or compliance adviser.