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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:

 

I. Consolidated sanctions lists covering natural and legal persons

  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)
  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 Articles 118 and 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 and on the basis of Chapter VII of the Charter of the United Nations, concerning threats to international peace and security caused by acts of terrorism;
  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. Belgian Financial Sanctions;
  17. Canadian Listed Terrorist Entities;
  18. Czech Republic National Sanctions;
  19. Estonia International Sanctions Act List;
  20. EU Council Official Journal Sanctioned Entities;
  21. EU Consolidated Travel Bans;
  22. EU Sanctions Map;
  23. Ireland Unlawful Organisation (Suppression) Orders;
  24. Israel Prevention of Distribution and Financing of WMDs designations;
  25. Japan Economic Sanctions and List of Eligible People 
  26. Latvia FIU Sanctions;
  27. Lithuanian International Sanctions;
  28. Moldovan Sanctions for Terrorism and Proliferation of WMD;
  29. Monaco National Fund Freezing List;
  30. New Zealand Russia Sanctions;
  31. Romania Government Decision No. 1.272/2005: List of Suspected Terrorists;
  32. UK FCDO Sanctions List;
  33. Ukraine SFMS Blacklist;
  34. US Trade Consolidated Screening List (CSL);
  35. US FinCEN 311 and 9714 Special Measures;
  36. WorldBank Debarred Providers;
  37. US State Department Cuba Sanctions.

II. Sectoral, financial and economic lists covering natural or legal persons, entities or bodies subject to restrictive measures:

  1. Council Regulation (EU) No 833/2014 of 31 July 2014 concerning restrictive measures in view of Russia's actions destabilising the situation in Ukraine;
  2. Council Regulation (EC) No 765/2006 of 18 May 2006 concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine;
  3. 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;
  4. 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;
  5. Council Regulation (EU) No 359/2011 of 12 April 2011 concerning restrictive measures directed against certain persons, entities and bodies in view of the situation in Iran;
  6. Council Regulation (EU) 2020/1998 of 7 December 2020 concerning restrictive measures against serious human rights violations and abuses;
  7. Council Regulation (EU) 2024/2642 of 8 October 2024 concerning restrictive measures in view of Russia’s destabilising activities;
  8. Council Regulation (EC) No 1183/2005 of 18 July 2005 concerning restrictive measures in view of the situation in the Democratic Republic of the Congo;
  9. Council Regulation (EU) 2024/1485 of 27 May 2024 concerning restrictive measures in view of the situation in Russia;
  10. Council Regulation (EU) 2018/1542 of 15 October 2018 concerning restrictive measures against the proliferation and use of chemical weapons;
  11. Council Regulation (EU) 2019/796 of 17 May 2019 concerning restrictive measures against cyber-attacks threatening the Union or its Member States;
  12. Council Regulation (EU) No 267/2012 of 23 March 2012 concerning restrictive measures against Iran and repealing Regulation (EU) No 961/2010;
  13. Council Regulation (EU) No 36/2012 of 18 January 2012 concerning restrictive measures in view of the situation in Syria and repealing Regulation (EU) No 442/2011.

 

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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