Sanctions and PEP — a procedure that survives an inspection.
Sanctions and PEP — a procedure that survives an inspection.
Two different duties: sanctions apply to every business and mean a ban; PEP applies to obliged entities and means enhanced measures. Here is how to combine them into one process.
- Sanctions: MSWiA, EU, OFAC
- KNF warnings
- Beneficial owners (CRBR)
- Financials and filings
- Bankruptcy, liquidation, KRZ
- VAT status and accounts
- Press coverage
- 0–100 risk score and PDF
Money back if the report cannot be generated
For companies: the first 2 reports free (in Polish)
What the law says
Sanctions. EU regulations and the Act of 13 April 2022 on special measures to counter support for the aggression against Ukraine impose restrictive measures: freezing funds and economic resources and a ban on making them available to listed persons and entities — on the EU lists and the national list kept by the Ministry of the Interior (MSWiA). The duty binds every business, not only obliged entities, and a breach carries a fine of up to PLN 20,000,000. The AML Act additionally requires obliged entities to apply specific restrictive measures (art. 117–118).
PEP. A politically exposed person is, among others, a head of state, minister, member of parliament, supreme court judge, ambassador or member of the management body of a state-owned enterprise (art. 2(2)(11)). Towards a PEP client an obliged entity: obtains senior management approval for the relationship, establishes the source of wealth and source of funds, and applies enhanced ongoing monitoring (art. 46(2)). The same rules cover a PEP's family members and known close associates — RCA (art. 46(6)). Status is established through risk-based procedures, including a client declaration made under criminal liability (art. 46(1)). A PEP hit means enhanced measures (art. 43(2)), not a ban.
Texts: AML Act, Sanctions Act.
Six steps from a list of people to a record in the file.
Establish the people
Board, proxy holders, shareholders, beneficial owners — from KRS and the CRBR. You screen the company and each of them; sanctions also reach entities controlled by listed persons.
Screen each one
The MSWiA list, the EU consolidated list, OFAC SDN, KNF warnings. Search with spelling and transliteration variants: Aleksandr/Alexander/Александр, female surname forms, middle names.
Assess the hit
A matching surname is not yet an identification. Compare date of birth, citizenship, country, function. Record why you judged the hit true or false.
Respond
A sanctions hit: stop the transaction, freeze the assets, notify the GIIF and the competent authority — without telling the client. A PEP hit: management approval, source of wealth, enhanced measures.
Record the list version and date
For every check: which list, in which version or as of which date, who checked, the result. Without it you cannot prove the person was not listed on the day.
Repeat
Lists change every few days. How often you re-screen follows the client's risk level; under EDD — very often.
Five mistakes that void a screening.
Each means a check was formally done — and there is no evidence of it.
How the report helps
The complete AMLA dossier screens the company and every established person — board, proxy holders, shareholders, CRBR owners — against OpenSanctions (incl. the MSWiA list), the EU consolidated list, OFAC SDN and KNF warnings. Each hit shows the match strength, the compared attributes and the list retrieval date, and the whole result lands in the "Sanctions and PEP" domain with points and the source. Obliged entities that make a declaration at checkout also see PEP and RCA status.
The PDF carries an identifier and a timestamp — that is the record from step 5. Step 6 you perform by ordering the report again: a new report shows the lists as of the day of the check. A subscription with change alerts is planned. Persons whose KRS data is masked are not screened automatically — the report says so.
See also: sanctions lists in force, sanctions screening, counterparty monitoring. Scoring rules: methodology.
Legal status as of October 2026. Information only, not legal advice.
Sanctions, PEP and KNF warnings are in the full report.
The free check covers the registers. Screening of the company and every person against sanctions lists, plus PEP and RCA status, is in the AMLA dossier.
Questions about sanctions and PEP.
Screen a counterparty against the lists.
The company and every person — MSWiA, EU, OFAC SDN, KNF — with the list retrieval date and a timestamp, in up to 3 minutes.