The question of who controls a Polish company is not answered by the commercial register alone. Sanctions and PEP screening adds a second layer: it establishes whether any person in the ownership or management chain is subject to an asset freeze, a travel ban, or a designation that restricts counterparty dealings. That layer is the subject of this page.
Control, in the sanctions context, means something precise. EU Regulation 269/2014 and its successive amendments define "owned or controlled" to include indirect ownership above 50 percent and effective control through other means. A Polish entity with a clean registry record may still fall within the scope of a designation if its ultimate beneficial owner is listed. Establishing that connection — or ruling it out — requires screening at every level of the ownership chain, not only at the registered shareholder level.
Source: EU Financial Sanctions Files (EFSF) · extracted 2026-09-15
What the Polish national sanctions list covers
Poland enacted its autonomous sanctions framework under the Act of 13 April 2022 on special solutions in the field of countering support for aggression against Ukraine (Dz.U. 2022 poz. 835) and subsequent amendments. The national list (Lista sankcyjna) is maintained by the Minister of Internal Affairs and Administration and published in Monitor Polski.
The list designates natural persons and legal entities subject to asset freezes and prohibitions on making funds or economic resources available. Each entry states the legal basis, the date of designation, and the identifying data used at the time of listing — typically name, date of birth, nationality, and, where available, a national identifier.
The EU Consolidated Sanctions List, maintained by the European Commission, operates in parallel. Polish obliged entities must screen against both. The two lists are not identical: the national list may include persons not designated at EU level, and EU designations apply directly in Poland without transposition.
Source: Monitor Polski / isap.sejm.gov.pl · extracted 2026-09-20
Source: EU Financial Sanctions Files — European Commission · extracted 2026-09-15
PEP registers: what is searchable and what is not
Poland does not maintain a single, consolidated, publicly searchable PEP register. PEP status is determined by reference to the statutory definition in the Act of 1 March 2018 on counteracting money laundering and financing of terrorism (AML Act), which transposes the EU's Fourth and Fifth AML Directives.
The AML Act defines PEPs by function: members of parliament, senior government officials, members of supreme courts, senior central bank officials, ambassadors, senior military officers, members of supervisory and management bodies of state-owned enterprises, and equivalent functions at EU and international level. The definition extends to family members and close associates.
No single database publishes a current, verified list of all persons meeting this definition in Poland. Screening relies on cross-referencing:
- Official government and parliamentary websites (sejm.gov.pl, gov.pl)
- The State Electoral Commission register (pkw.gov.pl)
- Public company supervisory board disclosures (KRS entries for state-controlled entities)
- Commercial PEP databases aggregating open-source data
Each of these sources has a different update cycle and a different scope. A person who left a qualifying function within the preceding twelve months remains a PEP under the AML Act. That status does not appear as a flag in any single official register.
Source: Sejm RP / sejm.gov.pl · extracted 2026-09-18
Source: Państwowa Komisja Wyborcza / pkw.gov.pl · extracted 2026-09-18
The CRBR layer: beneficial owners and the sanctions connection
The Central Register of Beneficial Owners (Centralny Rejestr Beneficjentów Rzeczywistych, CRBR) is maintained by the Minister of Finance. It records the beneficial owners of Polish companies, foundations, and trusts as declared by the obliged entity. Access is public and free of charge.
This register is public and free of charge. What you are paying for is the removed path: registration, national identifier, language, electronic signature, declaration of legitimate interest.
The CRBR entry names the beneficial owner, their nationality, country of residence, and the nature and extent of control. It does not verify the declaration. The declared beneficial owner may differ from the person who exercises effective control in practice. Discrepancies between the CRBR entry and the ownership structure visible in the KRS (National Court Register) are themselves a finding.
Sanctions screening against the CRBR requires matching the declared beneficial owner against both the Polish national list and the EU Consolidated Sanctions List. A match at this level triggers the asset-freeze and dealing-prohibition provisions regardless of whether the Polish entity itself is designated.
Source: CRBR — Ministerstwo Finansów / crbr.podatki.gov.pl · extracted 2026-09-20
[СВЕРИТЬ местным консультантом до публикации] The CJEU ruling in joined cases C-37/20 and C-601/20 (WM and Sovim, November 2022) found that unrestricted public access to UBO registers is incompatible with the Charter of Fundamental Rights. Poland's CRBR remains publicly accessible; the legal basis for that access and any pending legislative adjustment should be verified before relying on this source for compliance purposes.
What the screening covers across the ownership chain
A complete sanctions and PEP screen for a Polish entity covers four levels:
| Level | What is checked | Primary source |
|---|---|---|
| Entity itself | Direct designation on Polish or EU list | Lista sankcyjna, EFSF |
| Registered shareholders | Designation of named shareholders | KRS + Lista sankcyjna, EFSF |
| Declared beneficial owners | Designation of CRBR-declared UBOs | CRBR + Lista sankcyjna, EFSF |
| Management and supervisory board | PEP status, designation | KRS + AML Act definition, EFSF |
Each level requires a separate query. A negative result at one level does not substitute for a query at another.
Source: Krajowy Rejestr Sądowy / rejestr.io / KRS online · extracted 2026-09-20
Where the sources disagree
Three types of discrepancy arise regularly in Polish sanctions and PEP screening.
CRBR versus KRS. The declared beneficial owner in the CRBR may not match the ownership structure visible in the KRS. This occurs where the declaration has not been updated following a share transfer, or where the declaring entity has applied the control test differently from the register's expectation. The discrepancy is a finding, not a data error to be resolved by choosing one source.
National list versus EU list. The Polish national list and the EU Consolidated Sanctions List are maintained independently. A person may appear on one and not the other. Screening against only one list is incomplete for compliance purposes under Polish AML law.
Commercial PEP databases versus official sources. Commercial databases aggregate open-source data and apply their own update cycles. A person may be flagged as a PEP in a commercial database but not meet the statutory definition under the Polish AML Act, or vice versa. The statutory definition governs; commercial flags require verification against the primary source.
Source: VLO analytical desk · verified 2026-10-01
The limit of what the sources allow
The Polish and EU sanctions lists show designations that have been formally made and published. They do not show:
- Persons under investigation but not yet designated
- Beneficial owners who exercise control through structures not captured by the CRBR declaration
- PEP status acquired in a third-country jurisdiction not mirrored in Polish or EU databases
- Informal control relationships — board influence, veto rights, economic dependency — that fall below the statutory ownership thresholds
- Historical designations that have been lifted and removed from the current list
The CRBR declaration is self-reported. The register does not verify the accuracy of the declared beneficial owner. Where the declared UBO is a legal entity rather than a natural person, the chain continues upward and must be traced through the jurisdiction of that entity.
The AML Act's PEP definition covers persons who have held a qualifying function within the preceding twelve months. No official register publishes a time-stamped record of when a person left a qualifying function. Establishing that a person is no longer a PEP requires documentary evidence of the date of departure from the function.
The ceiling of what the sources allow is stated before any engagement. Where the chain breaks — at a foreign holding layer, at an undeclared beneficial owner, or at a third-country PEP register — that break is identified and documented as a finding, not papered over.
FAQ
Does a clean result on the EU Financial Sanctions Files mean the counterparty is not sanctioned? A negative result on the EFSF means the entity or individual is not on the EU Consolidated Sanctions List at the time of the query. It does not cover the Polish national list, third-country autonomous sanctions regimes, or sectoral restrictions that operate below the level of a full designation. A complete screen requires querying both lists and, where relevant, the sanctions regimes of other jurisdictions with a connection to the transaction.
Is the CRBR reliable as a source of beneficial ownership for sanctions purposes? The CRBR is the primary official source for declared beneficial ownership in Poland. It is not a verified register: the data reflects the declaration made by the obliged entity. Where the declared structure is inconsistent with the KRS ownership chain, or where the declared UBO is itself a legal entity, the CRBR entry is a starting point, not a conclusion. The discrepancy between declared and actual control is itself a material finding.
What is the update frequency of the Polish national sanctions list? The Lista sankcyjna is updated by ministerial decision published in Monitor Polski. There is no fixed update cycle: designations are made as decisions are taken. Screening against a version of the list that is more than a few days old carries a gap risk. The EU Financial Sanctions Files are updated on each day the European Commission publishes a new designation.
Does PEP status affect the validity of a transaction under Polish law? PEP status does not automatically invalidate a transaction. It triggers enhanced due diligence obligations for obliged entities under the AML Act. The legal consequences of a transaction with a PEP depend on whether the obliged entity complied with those obligations and whether the PEP is also subject to a sanctions designation. This page describes what the sources establish; it does not qualify the legal consequences.
Can a foreign national be a PEP for Polish AML purposes? Yes. The Polish AML Act's definition of PEP covers persons who hold or have held qualifying functions in any state or at international level, not only in Poland. A foreign national who is a senior official of a foreign government, central bank, or state-owned enterprise meets the definition. Screening for PEP status therefore requires checking the person's functions in their country of origin and in any international organisation with which they are affiliated.
Sources
- Lista sankcyjna — Ministerstwo Spraw Wewnętrznych i Administracji — https://www.gov.pl/web/mswia/lista-sankcyjna — extracted 2026-09-20
- EU Financial Sanctions Files — European Commission — https://www.eeas.europa.eu/eeas/european-union-sanctions_en — extracted 2026-09-15
- Centralny Rejestr Beneficjentów Rzeczywistych (CRBR) — Ministerstwo Finansów — https://crbr.podatki.gov.pl — extracted 2026-09-20
- Krajowy Rejestr Sądowy (KRS) — Ministerstwo Sprawiedliwości — https://ekrs.ms.gov.pl — extracted 2026-09-20
- Ustawa z dnia 1 marca 2018 r. o przeciwdziałaniu praniu pieniędzy oraz finansowaniu terroryzmu — isap.sejm.gov.pl — extracted 2026-09-18
- Sejm RP — https://www.sejm.gov.pl — extracted 2026-09-18
- Państwowa Komisja Wyborcza — https://pkw.gov.pl — extracted 2026-09-18
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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
