What the bill does
Poland’s lower house, the Sejm, passed the government’s restrictive-measures bill on Nov. 6 by 240 votes to 202, with one abstention. The vote moves the bill, originally numbered 3003, to the Senate. Presidential approval would still be needed before it becomes law. The core change is administrative: the interior minister could freeze cryptocurrency holdings, bank balances, and other property under national sanctions without first getting a court order. For exchanges and custodians, that means blocking access to assets tied to a designated customer before judicial review.
Scope and enforcement
The bill would require the minister to keep a public list of designated people and entities and state which restrictions apply. Financial assets include crypto assets using the EU Markets in Crypto-Assets Regulation definition, along with deposits, account balances, and securities. Covered property also includes movable and immovable assets that can produce money, goods, or services. Freezing prevents transfers and use. It does not by itself transfer ownership to the government. The rules extend listing grounds beyond the Russia- and Belarus-focused system adopted in 2022. They include certain foreign-backed information operations that threaten national security. That part requires a demonstrated risk of a real and serious threat, and the text excludes ordinary expression and journalism unless the activity is deliberate and specified.
Court review and timing
A designation would be enforceable the day after publication in the ministry’s public information bulletin. Perhaps the most contested point is timing. Affected parties could challenge it in an administrative court, but filing a challenge would not automatically suspend the restrictions. The text says a challenged decision keeps force until the judgment becomes final. Individual listings have no automatic expiry date. Listed parties could request removal, and exemptions could allow access for basic needs, legal fees, and some other expenses. The bill’s separate 24-month limit applies to government restrictions on economic cooperation with a country, not to individual asset freezes.
Practical limits and objections
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 objections, not a court ruling. Self-custody is a practical limit. Norton Rose Fulbright has explained in a general analysis that exchanges can stop assets leaving accounts they control, but restrictions on service providers do not themselves stop peer-to-peer transfers on public decentralized networks. Most provisions would take effect 30 days after official publication.
