The first Polish sanctions list published — with 50 entities on it

The moment has come, which will be remembered by all AML departments in Poland — on April 26, 2022, the first Polish sanctions list was published. Polish sanctions list includes, inter alia, PAO Gazprom, which owns 48% of the shares of the Polish company EUROPOL GAZ S.A., Novatek and the well-known in Poland, Go Sport Polska.

The first Polish sanctions list 2022

1st sanctions list of Poland — what entities are on the sanctions list and why

The first ever sanction list made by Poland was created in accordance with the so-called the sanction law, which was passed by the Polish parliament in mid-April 2022. As you can guess, its genesis is closely related to the ongoing war in Ukraine. It includes Poland’s sanctions against Russia — to be more exact, it contains mainly entities importing Russian coal to Poland, but also the names and surnames of Russian oligarchs.

The sanctions list of Poland was developed by the Polish Ministry of the Ministry of Internal Affairs and Administration and was officially announced on April 26, 2022. Mariusz Kamiński, Minister of The Ministry of Internal Affairs and Administration in Poland, added that Poland’s sanctions list will be expanded in the future and will also include people and entities supporting the regime of the Belarusian dictator Lukashenka.

Polish sanctions list — link to the official list on the Polish Ministry of Interior and Administration website (available only in polish)

An interesting fact is that the new Polish sanctions law also completely prohibits the promotion of symbols and names that support Russia’s aggression against Ukraine. Any violation will be punishable by a fine or up to two years’ imprisonment.

Poland’s sanctions against Russia 2022: names of entrepreneurs

The first Polish sanctions list includes 15 Russian entrepreneurs, including:

  • Wiaczesław Mosze Kantor — entry ban to Poland. The entrepreneur controls the following companies: Opansa Enterprises Limited, Rainbee Holdings Limited, ACRON PAO, NORICA HOLDING Sàrl, on which Polish sanctions have also been imposed. Kantor also holds a 20% stake in Azoty SA, a company owned by the Polish State Treasury
  • Tatiana Bakalczuk — sanctioned with the freezing of assets, a ban on cooperation and a ban on staying in Poland. She’s the founder and the owner of OOO Wildberries — the largest Russian online sales network providing individual customers with a very wide range of goods, including the most popular foreign brands. Since 2021, the company has been linked through its owner to Standard — Credit Bank (now Wildberries Bank) and VTB Bank.
  • Oleg Deripaska — a pro-Kremlin oligarch closely associated with the Russian government and President Vladimir Putin. Deripaska is committed to supporting the government of the Russian Federation and gaining benefits on economic activity in Russian enterprises of strategic importance, including in the energy, mining and military sectors. He is the real beneficiary of many companies in the construction industry in Poland — was banned from staying in Poland.
  • Mikhail Fridman — sanctions include prohibition to enter Poland. Mikhail Fridman is the founder of ALFA Bank — the largest Russian private bank, the fifth largest bank in the Russian Federation sanctioned by the United States of America under Executive Order 14024. According to the available data, the oligarch is the informal leader of the influence group centered around Alfa Bank’s shareholders.
  • Sait-Salam Gucerijew — sanction measures have been applied in the form of freezing assets, prohibiting cooperation and prohibiting entry into Poland. Sait-Salam Gucerjew is the brother of Mikhail Gucerjew, who has been sanctioned by the European Union, Ukraine and Great Britain. As M. Gucerjew was placed under sanctions, he took steps to change the ownership structure of his entities. He’s brother, Mikhail Gurerjew is a prominent Russian businessman, involved in Belarus, among others in the energy, potassium and hospitality sectors. As a longtime acquaintance of Alexander Lukashenka, he amassed considerable wealth and influence among the political elite of Belarus.
  • Igor Iwanowicz Sieczyn — indirectly associated with polish company IRL Polska Spółka z o.o., but he is also CEO of Rosneft, the Russian state-owned oil company and one of the world’s largest producers of crude oil. It’s one of Vladimir Putin’s most trusted and closest advisers and his personal friend. Polish sanctions for him consist of prohibition to entry into Poland.

Why is Putin not on the list, for example? Let us remind you that the sanction list of Poland supplements the EU sanction lists — so there is no need to duplicate the sanctions.

Poland’s sanctions against Russia 2022: companies

Poland’s sanctions list also lists 35 companies, including:

  • AXIOMA DR IT Sp. z o.o. (NIP 9452185008)
  • EUROCHEM POLSKA Sp. z o.o. (NIP 5252796604)
  • GO SPORT POLSKA Sp. z o.o. (NIP 9511861015)
  • IRL Polska Sp. z o.o. (NIP 5252539965)
  • KASPERSKY Lab Polska Sp. z o.o. (NIP 5732447128) and other companies from the Kaspersky group
  • KTK Polska Sp. z o.o. (NIP 5833152191)
  • Novatek Green Energy Sp. z o.o. (NIP 9452133282), which is controlled by the Russian concern OAO Novatek
  • MAGA FOODS Sp. z o.o. (NIP 5223071732)
  • WILDBERRIES Sp. z o.o. (NIP 7010921260)
  • PAO Gazprom (owner of 48% of shares in Polish company EUROPOL GAZ S.A.)
  • BELOIL Polska Sp. z o.o. (NIP 7010259849)

Important information for AML in Poland: a penalty of PLN 20 million for failure to respect Poland’s sanctions against Russia

For non-compliance with the sanctions from the Polish sanctions list, Polish entities obliged to apply AML procedures may be punished with an administrative fine of PLN 20 million (4,2 mln EUR).

In Poland and other EU countries obligated AML institutions include, among others, banks, payment operators, notaries, auction houses and antique stores, which were also covered by the 5th Anti-Money Laundering Directive a year ago. You can read more about AML obligations and obligated companies here:

Types of sanctions included in the first sanctions list of Poland

The first Polish sanction list includes several types of sanction. People (mentioned by name and surname) have been subject to sanctions such as: freezing of all assets and economic resources and entry to the list of foreigners who are not welcome in the Republic of Poland. It is also forbidden to transfer any funds to this person (directly and indirectly).

The sanction measures that were applied on the first Polish sanctions list against companies include the freezing of any assets, the absolute prohibition of providing these entities with any economic resources. They also cannot participate in the public procurement procedure or competition in Poland.

Moreover, the Polish government emphasizes that activities aimed at disclosing all other Russian entities in Poland are ongoing. This process may be time-consuming due to the fact that such companies are often registered in the so-called tax havens, but their owners are Russian oligarchs. The decision to enter or remove entities from the polish sanctions list is issued by the head of the Polish Ministry of Interior and Administration, ex officio or at the request of Polish secret services, the Polish National Prosecutor, the Polish General Inspector of Financial Information, the Polish Financial Supervision Authority or the President of the National Bank of Poland.

Data from 38 of the world’s most important sanctions lists provided via API Sanctions Lists

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