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SANCTIONS

Responsible establishment of economic and business relations requires acting in accordance with the provisions of the law in the field of counteracting money laundering and terrorist financing, counteracting support for the aggression of the Russian Federation against Ukraine launched on February 24, 2022, as well as other sanctions imposed by international bodies such as the United Nations and the European Commission. As a trustworthy partner, KRUK S.A. strives to comply with the highest standards in this respect in order to prevent the risk of the KRUK Group companies being used for criminal purposes.

In order to ensure full transparency of our activities and due to the obligation not to cooperate with sanctioned persons and entities or persons and entities associated with them, we carry out verification of persons and entities with the following lists:

  1. Consolidated United Nations Security Council Sanctions List (UN);
  2. European Union Consolidated Financial Sanctions List (consolidated list of entities and persons subject to financial sanctions for reasons specified in legal acts of the European Union, on the basis of, inter alia, Council Regulation (EU) No 269/2014 of 17 March 2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, Council Regulation (EU) No 208/2014 of 5 March 2014 concerning restrictive measures directed against certain persons, entities and bodies in view of the situation in Ukraine, Council Regulation (EC) No 881/2002 of 27 May 2002 imposing certain specific restrictive measures directed against certain persons and entities associated with Usama bin Laden, the Al-Qaida network and the Taliban, and repealing Council Regulation (EC) No 467/2001 prohibiting the export of certain goods and services to Afghanistan, strengthening the flight ban and extending the freeze of funds and other financial resources in respect of the Taliban of Afghanistan;
  3. OFAC Specially Designated Nationals List (SDN List);
  4. OFAC Consolidated Sanctions List (Non-SDN Lists);
  5. Consolidated list of financial sanctions targets in the UK (Office of Financial Sanctions Implementation HMT);
  6. Polish sanctions list on countering support for aggression against Ukraine (Ministry of Internal Affairs and Administration) - created on the basis of decisions of the Minister of Internal Affairs and Administration issued on the basis of the Act of 13 April 2022 on specific solutions for countering support for aggression against Ukraine and serving to protect national security;
  7. Sanction List of the General Inspector of Financial Information pursuant to Article 120 of the AML Act - created and updated on the basis of the decision of the General Inspector of Financial Information to include on the list of persons and entities subject to specific restrictive measures;
  8. Netherlands Police Nationale Opsparingslijst (Wanted);
  9. Dutch National Sanctionlist Terrorism;
  10. Australian DFAT Sanctions List;
  11. Canada Special Economic Measures Act Sanctions;
  12. Swiss SECO Sanctions/Embargoes;
  13. Kyrgyz FIU National List;
  14. US Denied Persons List;
  15. French Freezing of Assets;
  16. List of sectoral sanctions – Russia (prepared on the basis of Council Regulation (EU) No 833/2014 of 31 July 2014 concerning restrictive measures in view of Russia's actions destabilising the situation in Ukraine);
  17. List of sectoral sanctions – Belarus (prepared on the basis of Council Regulation (EC) No 765/2006 of 18 May 2006 concerning restrictive measures against President Lukashenko and certain officials of Belarus);
  18. List of sectoral sanctions - North Korea (prepared on the basis of Council Regulation (EU) 2017/1509 of 30 August 2017 concerning restrictive measures against the Democratic People's Republic of Korea and repealing Regulation (EC) No 329/2007);
  19. List of persons and related entities on restrictive measures against serious human rights violations and abuses (prepared on the basis of Council Regulation (EU) 2020/1998 of 7 December 2020 concerning restrictive measures against serious human rights violations and abuses).

We consider Sanctioned Countries to be countries or territories listed in the following lists:

  1. High-Risk Jurisdictions subject to a Call for Action (the so-called FATF "black list")
  2. Commission Delegated Regulation (EU) 2016/1675 of 14 July 2016 supplementing Directive (EU) 2015/849 of the European Parliament and of the Council by identifying high-risk third countries with strategic deficiencies;
  3. Council Regulation (EU) No 692/2014 of 23 June 2014 concerning restrictions on the import into the Union of goods originating in Crimea or Sevastopol, in response to the illegal annexation of Crimea and Sevastopol;
  4. Council Regulation (EU) 2022/263 of 23 February 2022 concerning restrictive measures in response to the recognition of the non-government controlled areas of the Donetsk and Luhansk oblasts of Ukraine and the ordering of Russian armed forces into those areas
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