Poland’s lower house, the Sejm, has approved a bill that would strengthen the country’s sanctions regime and explicitly bring crypto assets into the category of funds authorities may freeze when imposing sanctions. The move is intended to broaden the legal basis for restrictive measures and clarify that digital assets can be treated as sanctionable holdings under national procedures.
According to official parliamentary records, lawmakers backed the government-backed Act on Restrictive Measures on Friday by 240 votes to 202, with one abstention. The legislation was forwarded to the Senate on Monday, where it will face further review before potentially moving to the president for final consideration.
Key takeaways
- The Sejm approved an act expanding Poland’s sanctions framework and explicitly allowing crypto assets to be frozen as part of restrictive measures.
- Crypto assets are included in the bill by reference to the EU’s Markets in Crypto-Assets Regulation (MiCA), linking Poland’s approach to existing EU definitions.
- The Polish interior minister would oversee the national sanctions list, with designations taking effect the day after publication.
- Targets can challenge listings in administrative court, but the bill permits enforcement before a court decision.
- The Senate has 30 days to approve, amend, or reject the bill; if it does nothing, the measure advances under Poland’s constitutional rules.
What Poland’s bill changes for sanctions enforcement
The approved legislation aims to broaden the scope of Poland’s national restrictive measures. While Poland already maintains a sanctions list established under a 2022 law intended to counter support for Russia’s invasion of Ukraine, the new act would update and expand the grounds on which national sanctions can be imposed.
The bill adds references to certain foreign interference and information manipulation activities, describing them as threats that can justify sanctions under national security concerns. This matters because it potentially enlarges the range of scenarios in which authorities can designate individuals or organizations and freeze relevant assets.
Most notably for the crypto sector, the act explicitly includes crypto assets—defined in line with the EU’s MiCA—in the financial resources that can be frozen when sanctions are applied.
Why crypto assets are now expressly sanctionable
In the text passed by the Sejm, crypto assets are explicitly treated as funds that authorities could freeze under sanctions. The bill’s wording ties those crypto assets to the same definition used under the EU’s Markets in Crypto-Assets Regulation (MiCA), as noted in the legislative materials referenced by parliamentary documents.
For market participants, the practical impact is not limited to holding centralized exchange accounts. A sanctions framework that explicitly names crypto assets can influence how compliance teams across exchanges, custodians, and other service providers assess customer holdings and counterparties—even if broader enforcement details will ultimately depend on how Poland implements the act in practice.
Because the bill anchors crypto definitions to MiCA, it also suggests an effort to reduce ambiguity about which digital assets are intended to fall within the sanctionable categories—an issue that has been a recurring challenge for regulators operating across multiple jurisdictions.
How the sanctions list would be managed
The bill assigns responsibility for overseeing Poland’s sanctions list to the interior minister. Under the proposed process described in the legislative summary, sanctions designations would take effect the day after authorities publish the decision.
Once listed, affected individuals and companies would have the right to challenge the designation in administrative court. However, the act also allows enforcement to proceed before a court ruling is issued, meaning targets may face asset-freezing consequences immediately even while litigation is ongoing.
This “effective upon publication” approach is a key feature for compliance planning. For businesses, it emphasizes the importance of rapid operational response after official listings appear, including screening, account status changes, and risk controls that can be executed within days rather than weeks.
Senate timeline and constitutional path forward
After approval in the Sejm, the bill heads to the Senate, which has 30 days to approve, amend, or reject the legislation. If the Senate takes no action within that period, Poland’s Constitution treats the bill as approved in the form passed by the Sejm.
As a result, the legislative outcome could hinge on whether the Senate actively revises the text. If it does not, the measure would proceed to the president for consideration in its current form.
Either way, the next step for readers and industry stakeholders is to monitor how the crypto-related provisions are operationalized—particularly how authorities will interpret and apply the MiCA-based definition of crypto assets in real-world freezing decisions.
With Poland tightening its sanctions toolkit and explicitly extending it to digital assets, the key uncertainty is how quickly and consistently compliance processes will adapt once the Senate and presidential stages are completed. Market participants should watch for the first practical listings under the expanded framework and any administrative-court challenges that could clarify how enforcement works while legal disputes are pending.






