Poland passes crypto freeze bill in 240–202 sanctions vote

Poland’s lower house has passed a sanctions bill covering cryptocurrency freezes by 240 votes to 202, sending the proposal to the Senate for consideration.

Summary

• Lawmakers approved the sanctions proposal on Nov. 6, with one abstention and 17 members not voting.
• Crypto holdings would fall within financial assets subject to freezes involving designated people and companies.
• Court challenges would not automatically stop restrictions imposed through the interior minister’s sanctions list.
• The proposal addresses sanctions enforcement, while Poland’s separate crypto licensing legislation remains caught in a political dispute.

The Sejm’s voting record shows that lawmakers approved the government-backed Act on Restrictive Measures during its Nov. 6 sitting. The proposal would give authorities a national framework for imposing sanctions and enforcing restrictions on money, property, and other assets.

As crypto.news previously reported on Nov. 9, the legislation still requires Senate consideration and presidential approval before becoming law.

Poland’s crypto freeze proposal targets sanctioned holders

In its original draft, the government explicitly included crypto assets within the definition of financial funds, alongside bank deposits, account balances, securities, dividends and credit.

The crypto definition refers to Article 3 of the European Union’s Markets in Crypto-Assets Regulation, known as MiCA. The draft defines freezing as preventing movements, transfers, use, or transactions that change an asset’s ownership, location, value, or availability.

Restrictions would apply to people and entities placed on a national sanctions list maintained by the interior minister. The proposed listing grounds include support for sanctioned states, certain personal or financial connections, and foreign interference or information manipulation directed against Poland’s security.

Banks and exchanges holding assets for listed customers would have to comply with applicable restrictions. As the Nov. 9 coverage explained, enforcement involving self-custodied wallets would depend on identifying assets and restricting dealings with sanctioned holders.

A listing order would not itself provide authorities with the private keys needed to move funds from a personal wallet. Service providers could, however, be prohibited from processing transactions or making assets available to a designated customer.

Administrative decisions would take effect before court review

Articles 8 and 9 of the government’s draft set out an administrative process in which the interior minister issues listing decisions and publishes them in the ministry’s public information bulletin.

Decisions would become enforceable the day after publication. Listed parties could challenge them in an administrative court, but the draft provides that a contested decision remains in force until the judgment becomes final.

The proposal allows the minister to specify which funds or economic resources a restriction covers. It permits limiting the explanation accompanying a decision on national security or public order grounds.

Exceptions appear in Article 10 of the original draft. Authorities could authorize access to frozen resources for basic needs, including food, housing, medicine, taxes and utilities, as well as reasonable legal fees and certain maintenance costs. Access would depend on a separate decision and its conditions.

Sanctions changes build on Poland’s existing national list

The government’s project description says existing sanctions provisions are scattered across different laws, complicating implementation for businesses. Its proposal would organize responsibilities, information sharing, supervision and penalties.

During a Sept. 3 parliamentary debate, Deputy Interior Minister Czesław Mroczek explained that Poland’s existing national system operates under an April 2022 law addressing support for Russia’s aggression against Ukraine.

At that time, he said the list contained 554 entries: 119 businesses and 435 individuals. Of the businesses, 99 were linked to Russian capital and 20 to Belarusian capital.

Mroczek said the new legislation would allow national measures to address situations beyond Russia and Belarus. The government says the proposal implements EU Directive 2024/1226 on offenses and penalties involving violations of EU sanctions.

MiCA licensing remains a separate legislative dispute

Poland’s attempt to establish domestic crypto supervision has followed a different parliamentary path. President Karol Nawrocki issued his third veto on June 11, objecting to the government’s proposed framework while saying he supported effective consumer protection.

The Sejm’s September override attempt failed with 241 votes in favor, 198 against, and three abstentions. Passing the legislation again required 266 votes. The rejected bill would have designated the Polish Financial Supervision Authority as the country’s crypto regulator.

In the United States, the Treasury’s Office of Foreign Assets Control already applies the same sanctions obligations to digital currency and traditional money. Its guidance requires people subject to US jurisdiction to block covered property belonging to designated parties and avoid prohibited transactions, including dealings intended to evade sanctions.