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Non-European Sanctions Act - a Chilling Threat to Political Decisions


  • The sanctions law signed by the President may lead to arbitrary and political decisions to freeze the assets of companies and individuals.

  • An administrative decision with immediate enforceability containing a one-sentence justification may be the basis for blacklisting entities subject to selected sanctions.

  • The Minister of the Interior is authorised to limit the scope of the justification provided for reasons of state security or public order - this threatens to harm the interest of the entity applying for such a decision.

  • The Sanctions Act does not provide for in-depth international cooperation and excludes the obligation to inform other member states and the European Commission about the sanctions applied on the basis of the Act.

Contact to the author:

Eliza Rutynowska, FOR lawyer

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