Poland maintains several official lists relevant to sanctions screening and politically exposed person (PEP) identification. An extract from these sources establishes, at a fixed point in time, whether a named individual or entity appears on any list maintained by Polish authorities or transposed EU instruments. The angle here is control: who controls the company, and whether that person is subject to asset-freezing measures or qualifies as a PEP under applicable definitions.
The extract does not establish innocence. It establishes presence or absence on a defined set of lists as of the extraction date. That distinction matters before any transaction closes.
What the extract coversNamed individuals and legal entities checked against Polish national sanctions lists, EU consolidated sanctions lists transposed into Polish law, and PEP registers maintained under AML/CFT frameworks. Verified: 09.10.2026. Primary Polish authorityGeneralny Inspektor Informacji Finansowej (GIIF) — the General Inspector of Financial Information — administers the national AML register and PEP-related obligations under the Act of 1 March 2018 on counteracting money laundering and financing of terrorism. Source: GIIF · verified 09.10.2026. EU layerThe EU Consolidated Sanctions List (maintained by the European External Action Service) applies directly in Poland. Entries on this list are legally binding without separate national transposition. Source: EEAS · verified 09.10.2026. Coverage levelLevel A — the extract covers the primary official lists. It does not cover commercial screening databases or third-country unilateral sanctions lists (US OFAC, UK OFSI, UN) unless those are explicitly included in the scope ordered.Poland's AML framework is built on the Act of 1 March 2018 (ustawa AML), which implements the EU's Fourth and Fifth Anti-Money Laundering Directives. The framework assigns screening obligations to obligated institutions and establishes the registers against which screening is performed.
The national sanctions list (lista sankcyjna) is maintained by the Minister of Finance and published in the Official Journal of the Republic of Poland (Dziennik Ustaw). It designates individuals and entities subject to asset-freezing measures under Polish national law. The EU Consolidated Sanctions List operates in parallel and takes precedence where it conflicts with national entries.
The PEP register does not function as a single searchable database in Poland. Instead, obligated institutions are required to identify PEPs using defined criteria set out in the AML Act. These criteria cover: current and former holders of prominent public functions in Poland and abroad, their immediate family members, and known close associates. The extract maps the applicable criteria against the named subject and records the outcome.
The Central Register of Beneficial Owners (CRBR — Centralny Rejestr Beneficjentów Rzeczywistych) is a separate instrument. It records declared beneficial owners of Polish legal entities. A CRBR extract is not a sanctions check, but it is the primary source for identifying who controls the entity being screened. Control identification and sanctions screening are two distinct steps; this service covers both within a single extract.
Source: GIIF / Ministerstwo Finansów · extracted 09.10.2026
A sanctions check on the legal entity alone is insufficient. Asset-freezing measures frequently target the natural person who controls the entity, not the entity itself. If the controlling shareholder or ultimate beneficial owner appears on a sanctions list, the entity's assets may be subject to freezing obligations regardless of whether the entity is named.
The extract therefore proceeds in two stages. First, the controlling structure is established using CRBR data and, where available, filed corporate documents. Second, each identified controller is screened against the applicable lists. The result states: who controls the entity, whether any controller appears on a covered list, and at what level of the ownership chain the exposure, if any, is located.
This approach reflects the control angle: the question is not only whether the counterparty is listed, but whether the person who actually directs it is listed.
Source: CRBR (Centralny Rejestr Beneficjentów Rzeczywistych) · extracted 09.10.2026
The extract is produced in the following sequence:
Standard turnaround is two to three business days from confirmation of subject details. Extended scope (multiple jurisdictions, complex ownership chains) may require additional time, stated at the time of order.
The ceiling of what the sources allow is stated before payment. The following limits apply to every extract produced from Polish official sources.
The national sanctions list is not exhaustive. Polish national designations cover a defined set of subjects. An individual or entity not appearing on the Polish list may appear on EU, UN, OFAC, or OFSI lists. The extract states which lists were checked and which were not.
CRBR reflects declarations, not verified ownership. The beneficial owner recorded in CRBR is the person declared by the entity's management. The register does not independently verify the accuracy of that declaration. A discrepancy between the declared beneficial owner and the actual controlling person will not appear in CRBR data alone.
PEP status is criteria-based, not list-based. There is no single Polish PEP list to query. The assessment applies statutory criteria to the identified persons. If a person holds a qualifying function not publicly disclosed, the assessment will not capture it.
Historical entries. The extract reflects the state of the lists on the extraction date. It does not establish whether a subject was listed at an earlier date and subsequently removed. A historical screening covering a specified prior period is available as a separate scope item.
Negative result is not clearance. Absence from the checked lists on the extraction date does not constitute a legal determination that the subject is not subject to sanctions or does not qualify as a PEP. It establishes only that no entry was found on the specified lists on the specified date.
Source: EU Consolidated Sanctions List (EEAS) · extracted 09.10.2026
Discrepancies between sources are recorded as findings, not resolved editorially.
The most common discrepancy in Polish screening: the CRBR records one beneficial owner, while filed corporate documents (available via KRS) show a different ownership structure. This occurs when a CRBR update has not been filed following a share transfer, or when the declared beneficial owner does not match the person with actual voting control.
A second discrepancy type: an entity appears on the EU Consolidated Sanctions List but not on the Polish national sanctions list, or vice versa. Both lists are checked; both results are reported.
Where discrepancies are found, the extract states the source of each conflicting entry, the date of each record, and the nature of the conflict. Resolution of the discrepancy — whether through legal analysis or further document retrieval — falls outside the scope of the extract and is addressed separately.
| Tier | Price | What is included | Not included |
|---|---|---|---|
| Signal | €440 | Entity name check against EU Consolidated Sanctions List and Polish national sanctions list; CRBR beneficial owner identification; PEP criteria assessment for identified controllers; written extract with source and extraction date | UN, OFAC, OFSI list checks; historical screening; multiple-entity batch; complex ownership chain analysis |
| Standard | €890 | All Signal scope; plus UN Consolidated Sanctions List, OFAC SDN List, and UK OFSI Consolidated List; KRS document review to verify CRBR ownership data; discrepancy note where sources conflict | Historical screening; batch orders of more than three entities; legal qualification of findings |
| Extended | €1,800 | All Standard scope; plus historical screening for a specified 12-month prior period; batch coverage of up to five related entities; ownership chain mapping to ultimate natural person across intermediate holding layers; full discrepancy analysis with source reconciliation | Legal advice; representation; qualification of findings as to legal consequences; entities outside Poland |
What is the difference between a sanctions check and a PEP check? A sanctions check establishes whether a named person or entity appears on an asset-freezing or restrictive-measures list maintained by a competent authority. A PEP check applies statutory criteria to determine whether a natural person holds or has held a prominent public function that triggers enhanced due diligence obligations. The two checks address different risk categories and use different sources. This extract covers both.
Does the extract cover EU sanctions only, or also US and UK sanctions? Signal tier covers EU and Polish national lists. Standard and Extended tiers add UN, OFAC, and OFSI lists. The extract states which lists were checked in each case.
What if the beneficial owner declared in CRBR differs from the actual controller? The extract records the CRBR entry and flags any discrepancy found in KRS documents. It does not resolve the discrepancy. Resolving a beneficial ownership dispute requires legal analysis outside the scope of the extract.
How current is the extract? Each extract carries the date on which each source was queried. Lists are checked on the day of production. The extract does not update automatically after delivery.
Can the extract be used for AML compliance purposes? The extract is a factual compilation from official sources. Whether it satisfies the due diligence requirements of a particular obligated institution under the AML Act depends on that institution's internal procedures and the nature of the business relationship. That determination is a legal question outside the scope of the extract.
What identifier is needed to run the check? For legal entities: full registered name and NIP (tax identification number) or KRS number. For natural persons: full name and, where available, PESEL or date and place of birth. Incomplete identifiers may affect the reliability of the result; this is noted in the extract where relevant.
Disclaimer: This report is a factual compilation from official registers and public sources. It is provided for informational purposes only, does not constitute legal advice, and contains no legal qualification of the facts established. VLO Law Firm assumes no liability for actions taken or not taken based on this material. For advice regarding your particular situation, please contact info@vlolawfirm.com.
Author: Katharina Berg — Partner, Central Europe, VLO Law Firm