The UN Sanctions List — what it is and whether a Polish company must check it

When sanctions lists are mentioned, the first thing that comes to mind is usually the European Union — regulations, packages targeting Russia, the EU list. But above all of that sits yet another level: the UN sanctions list, maintained by the Security Council of the United Nations.¹ If you are new to the topic, it is worth understanding what a sanctions list actually is and why it affects your business first. The UN list is the original source of many restrictive measures that the EU subsequently implements into its own law. For a Polish company, the concrete question is: does the UN list need to be checked separately, or is the EU list sufficient?

Legal status as of: 2026-05-20.

TL;DR

• The UN list (UN Security Council Consolidated List) is a register of individuals and entities subject to sanctions adopted by the UN Security Council pursuant to its resolutions.¹
• The EU implements UN sanctions — following each Security Council resolution, the European Union issues its own regulation that transposes those measures into EU law.²
• The EU list is separate and broader — the EU goes further than the UN and lists individuals and entities that have never appeared on the UN list (for example, Russian oligarchs under the Regulation 269/2014 regime).³
• For a Polish company, the UN list is contained within the EU list — by checking the EU Consolidated List maintained by DG FISMA,⁴ you are indirectly verifying the entities on the UN list as well.
• Checking the UN list separately makes sense in two situations: when you operate globally outside the EU, or when you want to catch the gap between a UN resolution and its transposition into EU law.
• The penalty for ignoring the obligation in Poland is up to PLN 20 million (Article 6(2) of the Act of 13 April 2022).⁵

What the UN sanctions list is and who maintains it

The United Nations is not a typical legislator — it does not issue regulations or directives that bind companies directly. It operates through the Security Council, which, under the UN Charter, may adopt resolutions imposing restrictive measures on states, organisations, and private individuals. The result of those resolutions is the UN Security Council Consolidated List — a consolidated register of all entities subject to Security Council sanctions.¹

The list is managed by individual Sanctions Committees, each responsible for a specific regime. Committee 1267 deals with entities associated with ISIL (Da’esh) and Al-Qaida. Committee 1718 oversees sanctions against the Democratic People’s Republic of Korea. Committee 1737 administers the Iran regime. Each committee has its own working procedures, its own rules for listing and delisting entities, and its own sub-list — but together they form a single consolidated document publicly available at un.org/securitycouncil/content/un-sc-consolidated-list.¹

It is important to understand the legal nature of this list. A UN Security Council resolution is binding on UN member states — not on companies directly. A Polish company does not read Security Council resolutions and is not required to interpret their text independently. The obligation for companies arises only when a given state (or the EU on behalf of its members) transposes the measures from a resolution into its own national or EU law.

Legal basis — UN Security Council resolutions

The UN Security Council operates under the United Nations Charter of 1945. Resolutions adopted under Chapter VII of the Charter are binding on all UN member states and oblige them to take action — including introducing restrictive measures against designated entities.

Each sanctions regime has a founding resolution and dozens of updating resolutions. The Security Council maintains separate sanctions regimes targeting, among others, terrorist groups (Al-Qaida and ISIL), the Democratic People’s Republic of Korea, and other states and entities designated by resolution. These resolutions require states to freeze assets, impose travel bans, and enforce arms embargoes against the listed individuals and entities.

For a Polish company, Security Council resolutions have indirect relevance — they appear in the preambles of EU regulations as the justification for the measures imposed. When you see a reference to a specific Security Council resolution in an EU regulation, you can trace where the sanction originated and what its political rationale was. You do not need to read the resolutions themselves — what is binding on you is the EU regulation that implements their content.²

The UN list vs the EU list — the EU implements, but goes further

This is the key point to understand clearly: the UN list and the EU list are two separate documents, even though one flows from the other.

The implementation mechanism

When the UN Security Council adopts a resolution imposing restrictive measures on a given entity or group of entities, the European Union responds with its own Council regulation. That regulation implements the measures from the UN resolution, but at the same time makes them part of EU law — directly applicable in all EU member states, including Poland.² From that point on, an entity on the UN list is also an entity on the EU list and is subject to all the requirements of EU regulations.

EU regulations apply directly in every member state without the need for separate national legislation.² This means that when the EU implements a UN resolution, the measures imposed become binding on Polish companies automatically — without any additional act of the Polish Parliament.

Where the EU list goes beyond the UN list

The EU does not limit itself to implementing UN decisions. The Council of the EU adopts its own restrictive measures in cases where there is no consensus at the UN level — either because the matter is strictly European, or because a veto by Russia or China would block a Security Council resolution.

The clearest example is the sanctions regime against Russia built up after 2014. Council Regulation (EU) No 269/2014 of 17 March 2014³ and Council Regulation (EU) No 833/2014 of 31 July 2014⁶ — both concern Russia, both impose restrictive measures on hundreds of individuals and entities. Neither has a counterpart in a UN Security Council resolution, because Russia, as a permanent member of the Security Council, would veto any such resolution. The EU list therefore contains hundreds of entries that are not on the UN list and never will be.

The situation with the Belarus regime is similar — Council Regulation (EU) No 765/2006 of 18 May 2006⁷ imposes restrictive measures on entities associated with the Lukashenko regime. The UN list does not cover most of those individuals.

Practical conclusion: which list is broader

The EU list is broader than the UN list in every sanctions regime concerning Russia, Belarus, and several other jurisdictions. The UN list is broader or the sole source in regimes where the EU has no measures of its own (for example, certain African regimes, the Taliban, and parts of the Iran regime). In those latter cases, however, the EU in practice still implements UN sanctions, so the difference mainly concerns the transitional period between a UN resolution and its EU transposition.

From the perspective of a Polish company operating exclusively within the EU, with no contracts in Africa or the Middle East: by checking the DG FISMA Consolidated List,⁴ you are indirectly verifying all entities on the UN list that the EU has already implemented. The EU list is the primary compliance instrument for companies in Poland.

How to check a counterparty on the UN list — step by step

If, despite the above, you wish to check a counterparty directly on the UN list — either because you operate globally, or because you want to maintain full documentation from all sources — here is how to do it.

Step 1. Go to the UN Security Council website. The official address of the consolidated list is un.org/securitycouncil/content/un-sc-consolidated-list.¹ The website offers an online search tool and the option to download the entire list in XML or PDF format.

Step 2. Download the current version of the list. The UN list is updated after every decision by a sanctions committee. Do not rely on a file saved a month ago — always verify using the current version. In XML format, you can integrate the list with your system or cross-reference it with other lists.

Step 3. Search using the full name of the individual or company. Enter all known variants: transliterations from Cyrillic, Arabic-script spellings, aliases, and former names. The UN list contains entries in multiple languages and transliterations — the same person may appear under several name variants.

Step 4. Compare identifiers, not just names. Names alone are never sufficient. Check the date and place of birth, passport numbers, tax identification numbers, and other data given in the entry. Only cross-referencing several identifiers gives you confidence that you are looking at the same person — in our article on how to read a sanctions list entry, we explain which fields to focus on.

Step 5. Check which regime and committee the entry belongs to. Every entry on the UN list is assigned to a specific sanctions regime (e.g. 1267 — ISIL/Al-Qaida, 1718 — North Korea). Knowing the origin of an entry helps you understand what type of measures apply and whether they have already been implemented by the EU.

Step 6. Verify the EU implementation status. Check whether the entity on the UN list is also listed in the DG FISMA Consolidated List.⁴ If it is — you have double confirmation. If not — transposition may still be in progress; in that case, consult a lawyer before signing any contract.

Step 7. Document the outcome. Record the date of the check, the version of the list (or its publication date), the result of the screening, and the name of the person who conducted it. This documentation is your proof of due diligence in the event of an inspection by the Head of KAS (Krajowa Administracja Skarbowa — the National Revenue Administration).⁸

Does a Polish company have to check the UN list separately

Short answer: for most Polish SMEs — no, you do not need to check the UN list as a separate document. The EU list plus the Polish MSWiA list suffice.⁹

EU regulations are directly applicable in all member states without the need for national transposition.² The European Union implements UN Security Council resolutions through its own regulations, so every entity on the UN list that the EU has already implemented is also visible on the DG FISMA consolidated list.⁴ By checking that list, you are simultaneously — and indirectly — covering the entire content of the UN list for the implemented regimes.

The Polish Act of 13 April 2022 on special solutions for countering the support of aggression against Ukraine and for protecting national security (Journal of Laws 2022, item 835)¹⁰ imposes on Polish companies obligations arising from EU regulations and creates the national MSWiA list.⁹ That Act does not impose a separate obligation to check the UN list — it does so indirectly through EU regulations.

When checking the UN list separately makes sense

There are situations in which going directly to the UN list is worthwhile:

• You operate globally, outside the EU — for example, you have counterparties in Africa, the Middle East, or Asia, where EU law does not apply as domestic law. Your foreign partner may expect you to verify them directly against the UN list.
• You want to catch the gap between a UN resolution and its EU transposition — several weeks may pass between the adoption of a Security Council resolution and the publication of the corresponding EU regulation. During that window, an entity is on the UN list but not yet on the EU list. For companies involved in international trade or logistics, this gap matters.
• Your compliance policy requires full documentation from the primary source — some large companies and investment funds verify counterparties against all lists independently and document each check separately. If this requirement arises from your risk policy or from an agreement with an investor, check the UN list directly.
• The contract contains a sanctions clause referring to the UN — international agreements, particularly those with Anglo-American partners, frequently include compliance clauses that refer explicitly to UN resolutions. In that case, you have a contractual obligation to screen against the UN list, regardless of what EU law requires.

If none of those situations applies to you, your minimum compliance obligation is the EU list and the Polish MSWiA list. For more on which lists apply to Polish companies and how they compare, see the article EU, UN, OFAC, and MSWiA sanctions lists — a guide.

How Sanqto can help

Manually checking the UN list, the EU list, and the Polish MSWiA list for every new transaction is time-consuming and prone to human error — especially when you are processing dozens or hundreds of clients each month. Sanqto automates this process: it consolidates data from the UN Consolidated List,¹ the DG FISMA Consolidated List,⁴ and the MSWiA list⁹ into a single database, updates it automatically, and returns a result in one of three states — MATCH, POSSIBLE, or CLEAR. The software runs on-premise, which means your counterparty data never leaves your company’s infrastructure. If you run a business in one of the sectors where the sanction screening obligation arises most frequently, see the industry pages: travel agencies and tourism or insurance agencies.

FAQ — frequently asked questions

What is the UN sanctions list?

The UN sanctions list (UN Security Council Consolidated List) is a consolidated register of individuals and entities subject to restrictive measures — asset freezes, travel bans, and arms embargoes — imposed by the UN Security Council pursuant to its resolutions.¹ The list is managed by the individual Sanctions Committees of the Security Council and is publicly available at un.org/securitycouncil/content/un-sc-consolidated-list.

Are the UN list and the EU list the same thing?

No. They are two separate documents maintained by different bodies. The UN list covers entities designated by UN Security Council resolutions, whereas the EU list — the DG FISMA Consolidated List⁴ — is a database maintained by the European Commission containing entities designated by Council of the EU regulations.³⁶ The EU implements UN measures into its own law, but also establishes many additional measures that are not on the UN list at all. The EU list is broader.

Is a Polish company obliged to check the UN list?

There is no direct obligation to check the UN list as a separate document. EU regulations,² which implement UN resolutions, are directly applicable in Poland — by checking the DG FISMA Consolidated List,⁴ you are indirectly verifying all entities on the UN list that the EU has already transposed. The minimum obligation for a Polish company is the EU list and the Polish MSWiA list.⁹

How often is the UN list updated?

The UN list is updated after every decision of the relevant Sanctions Committee — this may happen several times a month or less frequently, depending on the committee’s activity. There is no fixed schedule. It is therefore important to use the current version for every significant check, rather than a file downloaded weeks ago — we discuss the pace of changes across all lists in the article on sanctions list updates.

What should I do if a counterparty is on the UN list but not on the EU list?

This means the EU has not yet implemented the relevant UN resolution, or the entity is on the UN list solely under a regime that the EU treats differently. In that situation, you have no direct legal obligation under EU law with respect to that particular entity — but you do face legal and reputational risk. Recommendation: suspend the transaction and consult a lawyer or compliance adviser before making a decision.

Where exactly can I find the UN list online?

The UN list is available on the official UN Security Council website at un.org/securitycouncil/content/un-sc-consolidated-list.¹ You can browse it using the online search tool or download it in XML and PDF format. This is the only official source — do not rely on copies maintained by private parties without the ability to verify their currency.

Legal basis

• UN Security Council Consolidated List — maintained by the Sanctions Committees of the UN Security Council — un.org/securitycouncil/content/un-sc-consolidated-list
• 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
• Council Regulation (EU) No 765/2006 of 18 May 2006 concerning restrictive measures in respect of Belarus — CELEX 32006R0765
• 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 13 April 2022 on special solutions for countering the support of aggression against Ukraine and for protecting national security (Journal of Laws 2022, item 835) — ISAP
• EU Consolidated List / Financial Sanctions Database — DG FISMA, European Commission — finance.ec.europa.eu / webgate.ec.europa.eu/fsd/fsf
• Polish sanctions list (MSWiA — Ministry of the Interior and Administration) — gov.pl/web/mswia/lista-osob-i-podmiotow-objetych-sankcjami

Footnotes

Information, not legal advice. This article is informational and educational in nature. 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.