Polish Sejm advances bill explicitly covering crypto in sanctions freezes
Poland’s lower house has advanced a sanctions bill whose government draft explicitly includes crypto assets among the resources that can be frozen. The proposal still needs Senate consideration and presidential approval. Under its appeal process, restrictions would remain in place until a court judgment becomes final.
- Passed the Sejm on Nov. 6, 2025, by 240 votes to 202.
- The government draft includes crypto assets in the scope of sanctions freezes.
- A court challenge would not automatically suspend a listing.
- The bill is separate from Poland’s stalled crypto-supervision legislation.
What the sanctions bill proposes
The Sejm approved the government-backed Act on Restrictive Measures on Nov. 6, 2025. The recorded vote was 240 in favor, 202 against and one abstention. Seventeen members did not vote. The proposal now goes to the Senate and would also need presidential approval to become law.
The government’s draft includes crypto assets among “financial funds” that may be restricted, alongside bank deposits, account balances, securities, dividends and credit. It uses Article 3 of the EU’s Markets in Crypto-Assets Regulation (MiCA) to define a crypto asset.
The draft defines a freeze broadly. It could prevent the movement, transfer or use of an asset, or transactions that change its ownership, location, value or availability. In practice, a freeze could block access to an asset or dealings with it without transferring it to the state.
The interior minister would maintain the proposed national list. The grounds outlined in the draft include support for sanctioned states, specified personal or financial connections, and foreign interference or information manipulation directed against Poland’s security. These are summaries of the proposed grounds, not a complete account of every criterion.
The provisions described here come from the government draft. The available information does not establish whether the final text approved by the Sejm changed any of its wording.
What a freeze could mean for crypto holders
Banks and exchanges that hold assets for a listed customer would have to follow applicable restrictions. A service provider could be barred from processing that customer’s transactions or making their assets available.
Self-custody works differently. Someone with a self-custodied wallet controls its private keys, the credentials needed to authorize transactions, instead of relying on an exchange or other intermediary. A listing decision would not give the government those keys or, by itself, let officials move funds from the wallet.
That does not make self-custodied assets immune to sanctions. The proposed rules could restrict a listed person’s dealings with assets, including through businesses or other intermediaries. But the draft, as described, does not explain how authorities would identify particular self-custodied assets or enforce restrictions in individual cases.
Restrictions could remain during a court challenge
Under Articles 8 and 9 of the draft, the interior minister would issue listing decisions and publish them in the ministry’s public information bulletin. A decision would take effect the day after publication.
A listed person or entity could challenge the decision in an administrative court. Filing a challenge would not suspend it, though. The restrictions would remain in force until the court’s judgment became final. That raises a due-process concern. Even someone who eventually wins in court could remain subject to restrictions while the case proceeds.
The minister could specify which funds or economic resources are restricted. The draft also lets authorities limit the explanation accompanying a decision on national-security or public-order grounds. Protecting sensitive information may be legitimate, but withholding the basis for a decision can make it harder for a listed party to challenge it effectively.
The draft proposes exceptions for essential expenses. Article 10 would allow authorities, through a separate decision, to authorize access to frozen resources for needs such as food, housing, medicine, taxes and utilities, as well as reasonable legal fees and certain maintenance costs. Access would depend on the conditions set in that decision. It would not be automatic.
Existing sanctions and a separate crypto bill
Poland’s national sanctions system currently operates under an April 2022 law addressing support for Russia’s aggression against Ukraine. During a parliamentary debate on Sept. 3, 2025, Deputy Interior Minister Czesław Mroczek said the existing list had 554 entries: 119 businesses and 435 individuals. Of those businesses, 99 were linked to Russian capital and 20 to Belarusian capital.
The government says the proposal would bring responsibilities, information sharing, supervision and penalties now spread across different laws into a more organized framework. It also says the measure would implement EU Directive 2024/1226, which concerns offenses and penalties for violations of EU sanctions, and extend national measures beyond the existing Russia- and Belarus-related context.
This sanctions proposal is separate from Poland’s effort to establish domestic crypto supervision. That bill would have designated the Polish Financial Supervision Authority as the country’s crypto regulator. President Andrzej Duda vetoed it on June 11, 2025. In September 2025, the Sejm failed to override the veto: 241 members voted in favor, 198 against and three abstained, short of the 266 votes required.
The two measures address different issues. The sanctions bill concerns restrictions on assets belonging to designated people and entities. The stalled legislation concerns oversight of crypto businesses. A country can pursue one while its broader approach to regulating the industry remains unsettled.
There is a limited parallel with U.S. policy. The U.S. Treasury’s Office of Foreign Assets Control applies sanctions rules to digital currency as well as traditional money in cases covered by U.S. jurisdiction. That does not mean every crypto user worldwide is subject to U.S. rules, and it does not determine how Poland’s proposal would be applied.
Key questions and answers
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Did the Sejm approve the sanctions proposal?
Yes. It passed on Nov. 6, 2025, by 240 votes to 202, with one abstention and 17 members not voting.
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Is the proposal law?
The Sejm has approved it, but it still needs Senate consideration and presidential approval.
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Would the proposed freezes cover crypto assets?
The government draft expressly includes crypto assets among “financial funds” that may be restricted. The available information does not establish whether the final Sejm-approved text changed that wording.
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Would appealing a listing pause the restrictions?
No. Under the draft, a listing would remain in force until the court judgment became final.
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Could a listing order take funds from a self-custodied wallet?
The order would not give authorities the wallet’s private keys. The draft does not explain exactly how officials would identify or enforce restrictions on particular self-custodied assets.
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Is this the same as Poland’s crypto-supervision bill?
No. The sanctions proposal concerns restrictions on designated people’s assets. The separate, vetoed bill would have established domestic supervision of crypto businesses.
The next steps are Senate consideration and presidential approval. If the proposal becomes law, its practical reach will depend in part on how authorities apply the listing criteria and enforce restrictions involving self-custodied assets.
