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More and more publicly available sanctions lists | PRO HR Compliance

2022.07.07

Legislation passed by European Union institutions and member states, including Poland, in response to Russian aggression against Ukraine, has established new sanctions lists.

These include individuals, including entrepreneurs, and companies, whose activities may support Russian aggression. The list, maintained in Poland by the Minister of Interior , complements already available sanctions lists maintained by EU institutions and the United Nations.

A number of prohibitions apply to the sanctioned entities with respect to entering into or continuing a business relationship with them.

Obtaining information on whether a Polish company does any business with companies or individuals on the sanctions list is the responsibility of the company, in practice its legal or compliance department. The company needs to make sure that there are no sanctioned entities among the its customers, suppliers or collaborators and put in place a mechanism to prevent such collaboration in the future.

The act on special solutions to prevent support for the aggression against Ukraine and to protect national security of 13 April 2022 refers to EU regulations, which have the same binding force as, for example, GDPR.

This ensures that there is no concern that obtaining personal data of sanctioned individuals and entities will be incompliant with the personal data processing rules.

The obligation to verify business partners in these circumstances is particularly important because violations of the prohibitions set out in the EU regulations (including the ban on importing goods from Luhansk and Donetsk regions) are crimes punishable by imprisonment from 3 to 15 years. 

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