What Is a Sanctions List and Why Does It Apply to Your Business?

A sanctions list is an official register of natural persons, companies, organisations, vessels and aircraft subject to restrictive measures — issued by the EU, the UN or national authorities — and in Poland it applies to your business regardless of sector, not just to banks. Council Regulation (EU) No 269/2014¹ and the Act of 13 April 2022² are directly binding on every legal and natural person conducting business on the territory of the Republic of Poland. This article explains what a sanctions list is, which of the five main lists apply to your business, how to screen a counterparty, and what penalties can result from failing to do so.

Legal status as of: 2026-05-20.

TL;DR — Key Points in 60 Seconds

• What is a sanctions list — a register of persons, entities, vessels and aircraft subject to asset freezes and transaction prohibitions, maintained by the EU, the UN, the USA, the United Kingdom and — in Poland — by the MSWiA (Ministry of Internal Affairs and Administration).
• Five main lists — EU Consolidated List / FSD, UN, OFAC (USA), UK OFSI, and the Polish MSWiA list.
• Directly binding on Polish companies — the EU list (Regulation No 269/2014¹, No 833/2014³) and the Polish MSWiA list (Act of 13 April 2022²).
• Who must screen — every company in the EU is subject to the regulations; EU regulations are directly applicable without the need for transposition.⁴
• Effect of listing — asset freeze + prohibition on making funds available + prohibition on entering into transactions.
• Penalty for failure to screen in Poland — up to PLN 20 million (Article 6(2) of the Act of 13 April 2022).⁵
• Where to look — Consolidated List DG FISMA⁶ at webgate.ec.europa.eu/fsd/fsf, EU Sanctions Map⁷ at sanctionsmap.eu, MSWiA list⁸ at gov.pl/web/mswia.

What Is a Sanctions List — A Plain-Language Definition

A sanctions list — also referred to as a sanctions register, a list of restrictive measures, or in English a “consolidated list” or “SDN list” — is a structured register containing specific entries for each designated subject. Each entry consists of the name or company name, aliases and former names, date and place of birth (for natural persons), identifiers such as passport number or the equivalent of a national tax or company registration number, role or affiliations (for example “director of a subsidiary”), the grounds for listing, the date of listing, and the authority that made the listing.

An important clarification: “restrictive measures” is the official term in EU law and must be distinguished from criminal, tax, disciplinary or sporting sanctions. When the media refer to a “sanction for a missing tax number” or a “disciplinary sanction against an official” — that is an entirely different context. This article deals exclusively with economic sanctions and the lists maintained by EU, UN and national authorities.

Why does this matter for your business? Because entering into a contract, accepting a payment or providing a service to a listed person or entity is prohibited by law — regardless of whether you were aware of it or not. This is not a matter of goodwill; it is a directly binding obligation under EU law.⁴

Five Sanctions Lists You Should Know

There is no single global sanctions list. Several parallel registers exist, maintained by different authorities, with different geographical scope and different degrees of binding force for Polish companies. The table below sets out the most important ones.

More detail on the specifics of each list appears in the sections that follow. If you are interested in a detailed comparison of the EU, UN, OFAC and Polish lists, read the overview of the four main sanctions lists.

EU Sanctions List — Regulation No 269/2014 and Related Instruments

What Is the EU Sanctions List

The EU sanctions list is primarily Annex I to 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.¹ This Regulation concerns natural persons and entities subject to asset freezes in connection with Russian aggression. It is complemented by Council Regulation (EU) No 833/2014 of 31 July 2014,³ which introduces sectoral prohibitions — restrictions on trade in goods and services that cannot be attributed to specific persons but to entire categories (for example, a ban on the export of military technology or on the import of crude oil).

For Belarus, the equivalent instrument is Council Regulation (EU) No 765/2006 of 18 May 2006.¹⁰ There are also many geographical sanctions packages concerning Iran, Syria, North Korea, Mali, Myanmar and others — each with its own regulation and its own list of designated entities. All these lists are available in one place: the consolidated database maintained by DG FISMA (the Directorate-General for Financial Stability, Financial Services and Capital Markets Union within the European Commission).⁹

More on how individual EU sanctions packages against Russia have changed the scope of the list can be found in the article on EU sanctions packages against Russia.

What a Typical Entry Looks Like

Each entry on the EU list contains: the full name or company name, all known aliases and former names (particularly important for transliterations from Cyrillic — the same individual may appear as “Ivanov”, “Iwanow” and “Ivanoff”), the date and place of birth (for natural persons), available identifiers (passport number, the equivalent of a national personal identification or company registration number in the country of incorporation), role or organisational affiliations, the grounds for listing, and the date of listing.

How Often It Is Updated

The EU sanctions list is updated very frequently — in practice after each sanctions package, and these are adopted several times a year, often several times within a single month.¹⁴ Beyond full packages, individual additions or removals of entries also occur. For this reason, it is not possible to download the list once and use it for a year — it requires continuous updating.

As an entry point for non-specialists, we recommend the EU Sanctions Map⁷ available at sanctionsmap.eu. It allows browsing of sanctions packages by country, sector and date. For automated integration (XML/JSON), the FSD database at webgate.ec.europa.eu/fsd/fsf⁶ is available.

Polish Sanctions List — MSWiA

Legal Basis

The Polish sanctions list exists separately from the EU list — it is maintained by the Minister of Internal Affairs and Administration (MSWiA) on the basis of the Act of 13 April 2022 on special solutions to counter the support of aggression against Ukraine and to protect national security (Journal of Laws 2022, item 835).² This Act created a national sanctions instrument independent of the EU list — supplementing it in relation to entities connected with Poland or carrying on business here.

Article 2 of the Act sets out the grounds for listing: an entity may be listed if there are reasonable grounds to suspect that it supports aggression against Ukraine or poses a threat to national security. Article 4 of the Act governs the procedure for listing and delisting — the decision rests with the minister responsible for internal affairs.

Who May Initiate a Listing

Entities may be added to the national list at the initiative of a broad range of authorities: the Head of the ABW (Internal Security Agency), the Head of the AW (Foreign Intelligence Agency), the Head of KAS (National Revenue Administration), the Polish Financial Supervision Authority (KNF), the National Bank of Poland (NBP), the Supreme Audit Office (NIK) and others. This broad remit means the MSWiA list may include entities that differ from those on the EU list.

What a Listing on the Polish List Means

A listing on the MSWiA list produces effects analogous to those under the EU list: freezing of all funds and economic resources of the entity, a prohibition on third parties making any funds available to it, and exclusion from public procurement procedures.² The Act additionally introduces a prohibition on importing coal from listed entities (Article 12 of the Act).

Where to Find the List

The current MSWiA list is published on government websites at gov.pl/web/mswia/lista-osob-i-podmiotow-objetych-sankcjami⁸ and is updated after each ministerial decision. The list can be downloaded in PDF and XLSX format. Statistics on the number of listed entities are discussed in the article EU sanctions list in numbers (2026).

UN Sanctions List

The UN Security Council imposes sanctions on the basis of the United Nations Charter and successive resolutions. Each sanctions regime has its own supervisory committee — Committee 1267 (Al-Qaeda and Da’esh), Committee 1718 (North Korea), Committee 1737 (Iran) and others. The UN Consolidated List covering all those subject to these measures is available at un.org/securitycouncil/content/un-sc-consolidated-list.¹¹

For a Polish company, the key point is that UN sanctions do not operate in Poland directly — they enter the Polish legal order through EU regulations.⁴ The European Union implements Security Council resolutions into its own law and places the persons and entities covered by them on the EU Consolidated List. There is no separate “Polish UN list” as a public register — by checking the DG FISMA Consolidated List, you are simultaneously verifying the UN list indirectly.

This is worth knowing because a reader searching for a “UN sanctions list” for due-diligence purposes in Poland should refer to the EU list — that is the binding instrument and it encompasses entities from the UN lists.

OFAC Sanctions List — SDN List (USA)

What Is the SDN List

OFAC (the Office of Foreign Assets Control) is an agency of the U.S. Department of the Treasury responsible for administering and enforcing United States economic sanctions. It maintains the SDN List — the Specially Designated Nationals and Blocked Persons List¹² — which is the most comprehensive and most frequently cited sanctions list in the world. In addition to the SDN List, OFAC maintains sectoral lists (SSI, NS-MBS, FSE and others) that do not block entities outright but restrict specific categories of transactions with them.

Does the SDN List Apply to Polish Companies?

Directly — no. The SDN List is US law, applicable to “US persons” (persons and entities connected with the United States) and to transactions passing through the US financial system. However, your company may be indirectly exposed to OFAC risk in four situations. First, if a transaction is settled in US dollars — USD clearing passes through US correspondent banks, which are required to screen against the SDN List. Second, if the counterparty or beneficial owner (UBO) is a US person. Third, if the exported goods contain components subject to US export controls (US-origin goods). Fourth, if your company has a subsidiary, branch or joint venture in the USA.

A separate issue is secondary sanctions: the USA may impose restrictions on entities from third countries that conduct significant business with certain countries subject to US sanctions (Iran, Russia, Belarus in certain sectors). The SDN List is available at ofac.treasury.gov.¹²

UK Sanctions List — OFSI

Since Brexit, the United Kingdom has maintained its own sanctions register independently of the EU. OFSI (the Office of Financial Sanctions Implementation) within HM Treasury publishes the UK Consolidated List of Financial Sanctions Targets¹³ at gov.uk/government/publications/financial-sanctions-consolidated-list-of-targets.

The UK list is not identical to the EU list — the United Kingdom may designate different entities, and since 2020 the differences have been widening. For a Polish company, the OFSI list is relevant when you have British counterparties, sterling-denominated flows or subsidiaries in the UK. If your business has no touchpoint with the United Kingdom whatsoever, OFSI is less critical — though it is worth including it as a precautionary measure during due diligence.

What It Means to Be on a Sanctions List — Consequences for Your Business

Being on a sanctions list is not solely a problem for the listed entity. It is primarily a problem for you as that entity’s counterparty, supplier, landlord or service provider. Understanding this mechanism is essential.

Consequences for the listed person or entity:

• Asset freeze — all bank accounts, real property, shares and economic resources become unavailable.
• Prohibition on disposing of one’s own assets — a listed entity cannot independently transfer funds, sell real property or pay dividends.
• Prohibition on receiving any services without the authorisation of the competent authority.
• Exclusion from public procurement procedures.²

Consequences for your company as a counterparty or service provider:

• Prohibition on entering into new transactions with a listed entity — even if the contract had been negotiated beforehand.
• Obligation to freeze the listed entity’s funds if such funds are in your possession (for example, an advance payment made by a client).
• Obligation to report the match to the competent authority — KAS (National Revenue Administration), MSWiA or GIIF (General Inspector of Financial Information)¹⁵ — depending on the context.
• A contract concluded in breach of sanctions is void by operation of law — meaning you cannot enforce it or claim payment.²

Ownership rule:

EU sanctions cover not only the directly listed entity but also any company in which that entity holds more than 50% of the shares or exercises control over it.¹⁶ This means you must screen not only the counterparty itself but also its beneficial owners.

Who Must Screen Sanctions Lists in Poland

This is the question that SME owners ask most frequently: “is this only for banks?” The answer is unequivocal — no.

EU regulations are directly applicable legal acts.⁴ This means that Regulation 269/2014¹, 833/2014³ and related instruments apply to every natural and legal person on the territory of the EU — with no exceptions based on sector, company size or legal form. Banks and financial institutions have additional obligations under the Anti-Money Laundering Act (AML)¹⁷, but this does not mean that other businesses are exempt from sanctions obligations.

The Polish Act of 13 April 2022² imposes equivalent obligations on all persons carrying on business in the territory of the Republic of Poland. The Head of KAS¹⁸ is the authority empowered to carry out inspections and impose penalties — not only in the financial sector.

Sectors in which the screening obligation is most frequently overlooked:

• Travel agencies and OTAs — selling package holidays, booking hotels, issuing tickets for or on behalf of listed persons.
• Estate agents — intermediating in the sale or rental of real property to citizens from listed countries.
• Leasing — leasing of luxury cars, construction equipment, industrial machinery.
• E-commerce — selling goods subject to prohibitions under the CN codes listed in Regulation 833/2014.³
• Insurance — brokers or agents serving listed clients.
• Telecommunications and ISPs — providing internet access, telephony or cloud services to listed entities.

If you want to know more about whether your company has a sanctions screening obligation at all, read does my company need to conduct sanctions screening. Sector-specific obligations can be found on the industry pages: travel agencies and tourism, real estate, insurance.

How to Check Whether a Counterparty Is on the Sanctions List — Procedure

Checking a counterparty is not a one-off process — it should be repeated for each new transaction and at least once per quarter for existing counterparties. Here is how to do it step by step.

1. Download the current lists. The EU Consolidated List (DG FISMA)⁶ can be downloaded in XML or JSON format from webgate.ec.europa.eu/fsd/fsf. The Polish MSWiA list⁸ can be downloaded in XLSX or PDF format from gov.pl/web/mswia. Add the OFAC SDN List¹² and the UK OFSI List¹³ if required.

2. Search for the counterparty’s full name or company name and that of their beneficial owner (UBO). Screening the counterparty without verifying the UBO is an error that may expose you to liability.

3. Compare identifiers. A name alone is not sufficient — you must compare the date of birth, passport number, national identification number, tax identification number or company registration number, and country of residence. You are verifying whether this is the same person, not merely whether the letters match.

4. Check aliases and former names. Sanctions lists include Cyrillic transliterations, abbreviated names, trading names and former company names. The same entity may appear simultaneously as “Petrov”, “Pietrow” and “Petrow” — all versions should be searched.

5. Apply the ownership rule. Check whether the counterparty is owned by or under the control of a listed entity — the threshold is more than 50% of shares or equivalent control.¹⁶ Holding structures and complex ownership chains are a favoured method of sanctions circumvention.

6. Document the result of the verification. Record the date of the check, the version of the list used (for example, the EU list as of date X), the result (CLEAR / POSSIBLE / MATCH) and the name of the person who carried out the verification. This match register is your evidence of due diligence in the event of an inspection by the Head of KAS.¹⁸

7. In the event of a match — freeze the transaction and notify the authority. Do not take unilateral action without a legal basis or the required authorisation. Report the match to the Head of KAS, MSWiA or GIIF¹⁵ depending on the context of the case.

What to Do With a False Positive

Not every match is a confirmed hit. The three-state classification model distinguishes: MATCH (definite match — identifiers confirm this is the same person), POSSIBLE (the overlap requires manual verification — for example, a name match without confirmed date of birth) and CLEAR (no match). In the case of POSSIBLE, you must take additional verification steps and document your decision — it is precisely that documentation that determines whether the authority considers your diligence sufficient.

Penalties for Failing to Screen the Sanctions List

Poland — Administrative Penalty

The Act of 13 April 2022 provides in Article 6(2) for a financial penalty of up to PLN 20,000,000 (PLN 20 million) for breaching obligations relating to the freezing of funds or the prohibition on making funds available.⁵ The penalty is imposed by the Head of the National Revenue Administration (KAS)¹⁸ by way of an administrative decision. In addition to this penalty, Article 7(7) of the Act provides for sanctions for breaches in the area of public procurement (authority: the President of the Public Procurement Office) and Article 12(2) provides for sanctions for breach of the prohibition on importing coal (authority: the Head of KAS).²

Directive 2024/1226 — Criminal Liability

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 measures¹⁹ criminalises sanctions violations — it introduces criminal liability for natural persons (including custodial sentences) and financial penalties for legal persons. The transposition deadline for this Directive expired on 20 May 2025.¹⁹ In Poland, work on the implementing national legislation is ongoing — the status of the legislative process is subject to change, so before taking compliance decisions it is advisable to check the current position on the Government Legislation Centre website.

The specific penalty thresholds in national law — for both natural and legal persons — will be set out in the implementing legislation. Until then, the administrative penalties under the Act of 13 April 2022 apply.⁵ A detailed overview of all forms of liability can be found in the article penalties for breaching EU sanctions in Poland. The state of implementation in Poland and eight other EU Member States is discussed in the article transposition of Directive 2024/1226.

How Sanqto Helps With Sanctions List Management

Manually screening five sanctions lists — the EU list, the Polish MSWiA list, the UN list, OFAC and UK OFSI — for every transaction is time-consuming and error-prone. Sanqto automates this process: the system automatically downloads the current versions of the lists from DG FISMA,⁹ MSWiA,⁸ OFAC¹² and OFSI,¹³ so your company always operates on up-to-date data without the need to download files manually every week. The verification result is returned in one of three states — MATCH, POSSIBLE or CLEAR — in under 30 ms.²⁰ The software operates on-premise: your counterparty data never leaves your company’s infrastructure.²⁰ The implementation package includes a sanctions policy, a match register, a role-specific instruction and document templates — everything you will need during a KAS inspection.

Frequently Asked Questions (FAQ)

What is a sanctions list?

A sanctions list is an official register of natural persons, entities, vessels and aircraft subject to restrictive measures — asset freezes, transaction prohibitions and service prohibitions — issued by EU, UN or national authorities (in Poland: MSWiA). There is no single global list — several parallel registers exist, of which the most important for Polish companies are the EU Consolidated List and the Polish MSWiA list.

Who maintains the sanctions list in Poland?

The Polish sanctions list is maintained by the Minister of Internal Affairs and Administration (MSWiA) on the basis of the Act of 13 April 2022 (Journal of Laws 2022, item 835).²⁸ Independently of this, the EU Consolidated List maintained by DG FISMA of the European Commission is directly binding on every Polish company.⁹

Where can I check the EU sanctions list?

The EU Consolidated List can be found in the FSD (Financial Sanctions Database) maintained by DG FISMA⁶ at webgate.ec.europa.eu/fsd/fsf — it is available for download in XML and JSON format. If you prefer an interactive browser, use the EU Sanctions Map⁷ at sanctionsmap.eu.

Does the OFAC list apply to Polish companies?

Directly — no. The OFAC SDN List¹² is US law, applicable to persons and entities connected with the United States. Indirectly — yes, if your company settles transactions in US dollars (cleared through US banks), has counterparties or beneficial owners who are US persons, exports goods containing US-origin components, or has a subsidiary in the USA.

How often is the EU sanctions list updated?

The EU sanctions list is updated very frequently — in practice after each sanctions package, and individual additions or removals of entries occur between full packages.¹⁴ The recommended minimum is to check for updates once a week; companies with a large number of counterparties should use automated list downloads.

What are the penalties for failing to screen the sanctions list?

In Poland, an administrative penalty of up to PLN 20 million, imposed by the Head of KAS (Article 6(2) of the Act of 13 April 2022).⁵ Following implementation of Directive 2024/1226,¹⁹ criminal liability for natural persons (custodial sentence) and financial penalties for legal persons will be added. Furthermore, a contract concluded in breach of sanctions is void by operation of law.²

Is being on a sanctions list public information?

Yes. All the main sanctions lists — EU,⁶ UN,¹¹ OFAC SDN,¹² UK OFSI¹³ and the Polish MSWiA list⁸ — are publicly available online. The designation of an entity is not secret; it is an instrument of political and economic pressure that works only when it is widely known.

Does a small company also need to screen the sanctions list?

Yes. EU regulations are directly applicable to every natural and legal person in the territory of the EU, regardless of company size.⁴ There is no employment or turnover threshold below which the obligation would not apply. The Act of 13 April 2022² imposes equivalent obligations on all persons carrying on business in Poland.

Legal Basis and Sources

• 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 to counter the support of aggression against Ukraine and to protect national security (Journal of Laws 2022, item 835) — ISAP
• Act of 1 March 2018 on counteracting money laundering and the financing of terrorism (Journal of Laws 2018, item 723) — ISAP
• EU Consolidated List / Financial Sanctions Database (DG FISMA) — webgate.ec.europa.eu/fsd/fsf
• EU Sanctions Map — sanctionsmap.eu
• Polish MSWiA sanctions list — gov.pl/web/mswia
• UN Security Council Consolidated List — un.org/securitycouncil
• OFAC Specially Designated Nationals List (SDN) — ofac.treasury.gov
• UK OFSI Consolidated List of Financial Sanctions Targets — gov.uk

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 business depend on your activity profile and require individual assessment — if in doubt, consult a lawyer or compliance adviser.