Under the legislative text, the minister would maintain a public list of designated people and entities and specify which restrictions apply. Financial assets explicitly include crypto assets, using the definition in the EU’s Markets in Crypto-Assets Regulation, alongside deposits, account balances and securities. Other covered property includes movable and immovable assets that can generate money, goods or services.
The restrictions would cover assets owned, held or controlled by listed parties and prohibit making funds or economic resources available to them. Freezing means preventing transfers and use; it does not, by itself, transfer ownership to the government.
Administrative asset freezes are already part of Poland’s 2022 sanctions legislation, which gave the interior minister immediately enforceable listing powers linked to Russian aggression against Ukraine and repression in Russia and Belarus. The new bill creates a broader framework rather than introducing ministerial sanctions decisions for the first time.
Court Challenges Would Follow the Freeze
The minister’s designation would become enforceable the day after publication in the ministry’s public information bulletin. Affected parties could challenge it in an administrative court, but filing a challenge would not automatically suspend the restrictions. The text also says the challenged decision retains force until the judgment becomes final.
The individual-listing provisions contain no automatic expiry date. Listed people or entities could request removal, and exemptions could permit access to frozen resources for basic needs, legal fees and certain other expenses. The separate 24-month limit in the bill applies to government restrictions on economic cooperation with a country, not to individual asset freezes.
Eligibility includes people or entities supporting EU-sanctioned states, certain directly associated parties, and those whose resources are considered likely to support specified targets. It also reaches people initiating, carrying out, coordinating or financing information interference benefiting sanctioned states or entities. That provision requires a demonstrated risk of a real and serious threat; the text excludes ordinary expression and journalism unless they constitute the specified deliberate activity.
Legal institute Ordo Iuris argued in an October analysis that the listing grounds and delayed judicial relief threaten property rights and freedom of expression. Those are the institute’s legal objections, not a court ruling.
Self-custody presents a practical enforcement limit. In a general analysis of crypto freezes, law firm Norton Rose Fulbright explains that exchanges can prevent assets leaving accounts they control, while restrictions on service providers do not themselves prevent peer-to-peer transfers on public decentralized networks.
The bill’s commencement clause provides for most provisions to take effect 30 days after official publication.