SANCTIONS LISTS AND WATCHLISTS EXPLAINED · GUIDEUPDATED 2026-09-04
Sanctions Lists and Watchlists Explained
Poland's MSWiA sanctions list: 554 listings in force, one XLSX, no API
Poland's national list under the Act of 13 April 2022: 437 persons, 131 entities, four measures, Cyrillic name forms, and an XLSX on gov.pl with no feed.
A counterparty can be on Poland's national sanctions list and in no EU annex at all, which is the whole reason the list has to be screened on its own. It is kept by the Minister of the Interior and Administration, MSWiA, under the Act of 13 April 2022 on special measures to counter support for the aggression against Ukraine and to protect national security, published at Dz.U. 2022 poz. 835 and in force since 16 April 2022. Names go on by ministerial decision. The register lives on the MSWiA page at gov.pl as two HTML tables, persons and entities, with a downloadable XLSX of the same content; each row states the identifying data, the reasons for listing, the specific sanction measures applied, the date of listing and, where one exists, the date of removal. The first version went up on 26 April 2022 and the page has carried 168 published versions since. There is no XML, no CSV, no API and no delta feed, so screening it means polling the page and diffing what changed.
What this workflow covers
SCOPE- 437 persons and 131 entities in the published tables on 4 September 2026; 435 persons and 119 entities carried no removal date, so 554 listings were in force
- Four measures in the 'Zastosowane środki sankcyjne' column: (a) freezing of all funds and economic resources, (b) a prohibition on making them available to or for the listed person, (c) a prohibition on knowing and intentional participation in circumvention, and (d) for individuals entry in the register of foreigners whose presence in Poland is undesirable, for entities exclusion from public procurement procedures and competitions
- Definitions of funds and economic resources come from Council Regulation (EU) No 269/2014; the undesirable-foreigner measure runs through Article 434 of the Act of 12 December 2013 on foreigners
- Per row: name or company name, identifying data (date of birth for persons; registered seat and registration identifiers for entities), a full narrative justification, the measures applied, the listing date and the removal date
- Names appear in Latin script with the Russian-language form in parentheses for many entries, for example 'HARUTYUNYAN Armen Seryozhaevich (w języku rosyjskim: АРУТЮНЯН Армен Серёжаевич)', so a matcher without Cyrillic handling loses hits
- Source page https://www.gov.pl/web/mswia/lista-osob-i-podmiotow-objetych-sankcjami, with the XLSX attachment 'Lista sankcyjna - tabela' (about 200 KB)
- 168 published versions between 26 April 2022 and 26 May 2026, visible only in the page's own version history; there is no change notification
- Three registers and no superset: the MSWiA list, the Ministry of Finance's restrictive-measures records under Article 118 of the AML act, and the EU regime administered through the Council regulations
- Likely false positives: Polish, Russian and Belarusian names romanised inconsistently between the Polish and EU lists, entity rows giving a trading name rather than a registered one, and rows whose identifying data is a seat address with no KRS or NIP number
- Not every listing carries every measure, and procurement exclusion applies to entities specifically
Key statistics
DATA- Rows published on the MSWiA list, 4 September 2026
- 437 persons and 131 entities; 554 with no removal date
- Counted from the MSWiA published tables
- Published versions of the list page
- 168, from 26 April 2022 to 26 May 2026
- MSWiA page version history
- Legal basis
- Act of 13 April 2022, Dz.U. 2022 poz. 835, in force 16 April 2022
- Sejm ELI register
Compliance glossary
TERMS- Lista sankcyjna
- The Polish national sanctions list of persons and entities kept by MSWiA under the Act of 13 April 2022. It is separate from the EU consolidated list and is published as HTML tables with an XLSX attachment.
- Środki sankcyjne
- The sanction measures column of the list. It names which of the asset freeze, availability prohibition, anti-circumvention prohibition, undesirable-foreigner entry or procurement exclusion apply to that specific listing.
- Uzasadnienie wpisu
- The published statement of reasons for a listing. It is the narrative a reviewer reads when deciding whether a candidate match is plausible, and it usually names the connection to the Russian aggression against Ukraine.
- Data wykreślenia z listy
- The removal date column. A row with a removal date is a historic listing, retained on the page for the record; a row with an empty removal date is currently in force.
- Wykaz cudzoziemców niepożądanych
- The register of foreigners whose presence on Polish territory is undesirable, under Article 434 of the Act of 12 December 2013 on foreigners. Entry into it is one of the measures applied to listed individuals.
Authoritative references
SOURCES- 01Lista osób i podmiotów objętych sankcjami
Ministerstwo Spraw Wewnętrznych i Administracji
- 02
- 03Decyzje ministra SWiA w sprawie wpisu na listę sankcyjną
Ministerstwo Spraw Wewnętrznych i Administracji
Frequently asked questions
Q&A- Czym jest lista sankcyjna MSWiA?
- To krajowa lista osób i podmiotów objętych sankcjami, prowadzona przez ministra właściwego do spraw wewnętrznych na podstawie ustawy z dnia 13 kwietnia 2022 r. (Dz.U. 2022 poz. 835). Wpis następuje decyzją ministra, a lista jest publikowana na stronie MSWiA w serwisie gov.pl wraz z uzasadnieniem wpisu i wskazaniem zastosowanych środków sankcyjnych.
- Do we need an account or a licence to check the Polish sanctions list?
- No. Both tables are published free on the MSWiA page at gov.pl, and the same content is attached as an XLSX of roughly 200 KB, with no registration, key or fee. What is missing is machine-readable delivery: no XML, CSV, API or change feed, so automated screening means parsing the page or the spreadsheet yourself.
- How often does the MSWiA list change?
- Irregularly, whenever the minister issues listing or delisting decisions. The only public signal of cadence is the page's own version history, which showed 168 published versions between 26 April 2022 and 26 May 2026. There is no notification service, so a screening programme has to poll and diff.
- If we screen the EU consolidated list, are Polish listings covered?
- No. The Polish list is a separate national instrument. Some names overlap with EU designations and some do not, and the identifying data and romanisation can differ between the two registers for the same person. Screening the EU consolidated list alone leaves the Polish national listings unchecked.
- We have a hit on the Polish list. What does the row tell us?
- Which measures apply, in the 'Zastosowane środki sankcyjne' column: the freeze, the availability prohibition, the anti-circumvention prohibition, and the undesirable-foreigner or procurement-exclusion measure. They are not identical across entries, so read the row before acting. Under Polish law the listing is an asset-freeze-level signal, and the narrative justification on the same row is what a reviewer reads to judge whether the match is plausible.
- Does the Polish list matter for public procurement?
- Yes, for entities. One of the published measures is exclusion from a public procurement procedure or competition, applied per listing. That makes the list operationally relevant to contracting authorities and bidders in Poland, not only to banks and payment firms.
- Where is the Polish sanctions list file, and how do we version it?
- On the MSWiA page itself: the attachment labelled 'Lista sankcyjna - tabela' is an XLSX of about 200 KB carrying the same rows as the HTML tables. Take the date in the attachment name as the version you screened against and keep a copy, because earlier versions are only available by contacting the BIP editorial team. ScreenVeritAI screens the MSWiA list by default as one of the main jurisdictions on the coverage register, and since earlier versions of the page are only available on request, the Quick Check's point-in-time evidence PDF is the practical record of what the list said on the day you checked.
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